Agree a NOTOC should be supplied for notifiable goods.
Just making the point that anything in the hold poses some risk .....
Last time I looked in an "empty" hold it was full of rubbish such as old bagage labels, bits of tie-down rope etc. I think there was an Air Canada 767 a number of years ago that had just such rubbish set alight by a faulty water heater mat. Fortunately it happened on approach.