CHINA was not named in Hong Kong's paper on piracy submitted to the International Maritime Organisation (IMO). But the paper calls for action to find out how much Chinese officials are involved. It admits that when ships are boarded by ''uniformed persons'' it causes difficulties as to what action to take. Incidents around Hong Kong waters reached a peak in April last year, but then fell significantly. There have been eight reports of piracy this year. The Hong Kong paper says firearms, including automatic weapons and rockets, were used in 32 out of 100 incidents. It adds: ''The reported manoeuvring of small boats operating in darkness and showing no navigation lights while sailing close to merchant ships in attempting to compel them to stop appears to have endangered the safety of ships and lives.'' In one case a crew was reported to have been locked up while boarders took charge of the ship and sailed it to another destination. ''In those circumstances the crew would have been unable to protect themselves in case of fire, collision or other emergency,'' it adds. The paper says: ''It is not possible to ascertain from the information available whether the uniformed persons referred to in the reports are in fact officials acting within their jurisdiction, officials acting without their jurisdiction, or private individuals. ''This places the Maritime Rescue Co-ordination Centre in a difficult position, particularly when a distress call has been initiated and assistance requested.'' The paper admits that experience indicates that help cannot generally be provided in response to incidents in distant waters in the South China Sea. The incidents are generally over before assistance can arrive. ''Merchant ships which might provide assistance for genuine distress incidents at sea may also be reluctant to approach the site of any incidents in which it is known that firearms are being used.'' Hong Kong proposes that the flag state of a vessel should take up any incidents with ''the administration concerned''. It urges the IMO to tell the flag state of the details of any such incidents. In an attempt to shed some light on the activities of Chinese officials, while still not identifying their origin, it says flag states should tell the IMO of the outcome of their inquiries and whether the incident should be classified as a crime.