VI.—The Board of Trade's Administration.
Reading edition
The court was invited by the board of trade—
"to report upon the rules and regulations made under the merchant shipping acts, 1894-1906, and the administration of those acts, and of such rules and regulations so far as the consideration thereof is material to this casualty" (No. 26 of the questions submitted to the court by the board of trade).
Charges were made against the board of trade during the progress of the inquiry of a twofold kind. First, it was said that the board had been negligent in that they had failed to keep up to date their rules and regulations relating generally to the provision of life-saving appliances at sea, and, secondly, it was said that their officials had in the particular instance of the Titanic failed to exercise due care in the supervision of the vessel's plans and the inspection of the work done upon her.
With reference to the first of these charges, it was reduced in the course of the inquiry to a charge of neglect to keep the board's scale for the provision of lifeboat accommodation up to date. The circumstances are these: In March, 1886, the board appointed a departmental committee, consisting of three of their principal officers, to inquire into the question of boats, rafts, and life-saving apparatus carried by sea-going merchant ships. In their report this committee pointed out that, as regards boats for ocean-going steamers carrying large numbers of passengers, the boats would be of little use in saving life (although they might for a time prolong its existence) unless succor were at hand from other ships or from proximity to shore; and speaking with special reference to passenger steam vessels carrying emigrants across the Atlantic to ports on the east coast of North America, they said as follows:
Considering the number of vessels employed in this trade, and the large number of passengers they carry, and also taking into consideration the stormy character of the ocean they have to cross, and the thick and foggy weather encountered, we think this class is the most important of any, and we can not pass over the fact that of late years this traffic has been carried on with remarkable immunity from loss of life.
The boat accommodation these vessels are forced to carry when sailing with emigrants is regulated by the scale in the passengers act, 1855, which provides for boat accommodation for 216 people as a maximum, so that, supposing a vessel leaves with 1,000 passengers and 200 crew under the present statutory requirements, she need only carry sufficient boat accommodation for 216 of these people. Thus it will be seen that the boats carried by this class of vessels are also quite inadequate as an effectual means of saving life should a disaster happen to a ship with her full complement of passengers on board. We are glad to be able to say that there are many liberal and careful shipowners who do all in their power to provide for the safety of their passengers by equipping their vessels with boats far in excess of the number required by statute. But, at the same time, there are others carrying large numbers of emigrants who do no more than they are required to do by law.
We have gone into this question with reference to this class of vessels very fully, and have visited many of them, and we think that the boats required by act should be increased 100 per cent., and in addition to them that the owners should be induced to carry sufficient collapsible boats and approved rafts, so that each ship shall have sufficient life-saving gear for all on board at any one time, provided, as said before, that no ship need carry more boat accommodation than is sufficient for all on board at that time.
In 1887 a select committee of the House of Commons, of which Lord Charles Beresford was the chairman, was appointed to report on saving life at sea, and they found in their report—
That many passenger ships could not, without great inconvenience, carry so many of the ordinary wooden boats as would suffice to carry the whole of the passengers and crew with safety in bad weather. Under such circumstances the crew would not be sufficient to man so many boats; nor could they all be got into the water in sufficient time in the event of very rapid foundering. Having regard, however, to the fact that accidents occur probably as often in moderate weather as in bad, and having regard also to the fact that the very cause of the accident frequently incapacitates many of the boats, and to the further fact that an insufficiency of boats undoubtedly tends to cause panic, we are of opinion that all sea-going passenger ships should be compelled by law to carry such boats, and other life-saving apparatus, as would in the aggregate best provide for the safety of all on board in moderate weather.
As a result of these reports, the merchant shipping (life-saving appliances) act, 1888, appears to have been passed, under which rules were made by the board of trade at different dates. The merchant shipping act, 1894, repealed the act of 1888, and substituted therefor sections 427 to 431 and the seventeenth schedule of the new act. Under this act (1894) a table showing the minimum number of boats to be placed under davits and their minimum cubic contents was issued by the board. It was dated March 9, 1894, and came into operation on June 1 of that year. This table was based on the gross tonnage of the vessels to which it was to apply, and not upon the numbers carried, and it provided that the number of boats and their capacity should increase as the tonnage increased. The table, however, stopped short at the point where the gross tonnage of the vessels reached "10,000 and upwards." As to all such vessels, whatever their size might be, the minimum number of boats under davits was fixed by the table at 16, with a total minimum capacity of 5,500 cubic feet.
But as regarded emigrant steamships there was a rule which provided that if the boats under davits required by the table did not furnish sufficient accommodation for all on board, then additional boats of approved description (whether under davits or not) or approved life rafts should be carried, and that these additional boats or rafts should be of at least such carrying capacity that they and the boats required by the table should provide together in vessels of 5,000 tons and upwards three-fourths more than the minimum cubic contents required by the table, so that in the case of an emigrant ship such as the Titanic the requirements under the rules and table together exacted a provision of 9,625 cubic feet of lifeboat and raft accommodation (5,500 feet in boats under davits with three-fourths, namely, 4,125, added). Taken at 10 cubic feet per person, this would be equivalent to a provision for 962 persons. No doubt at the time these rules were made and this table was drawn up it was thought that, having regard to the size of vessels then built and building, it was unnecessary to carry the table further. The largest emigrant steamer then afloat was the Lucania, of 12,952 tons.
In the report of the select committee of the House of Commons a reference to water-tight bulkheads had been made, which was in the following terms:
Though the question of construction was clearly not included in the reference to the committee, still they think it only right to state, after having heard the evidence, that the proper placing of bulkheads, so as to enable a ship to keep afloat for some length of time after an accident has occurred, is most important for saving life at sea, and a thing upon which the full efficiency of life-saving appliances largely depends.
This passage probably explains the insertion in the board of trade's rules for life-saving appliances of rule No. 12, which is as follows:
Water-tight compartments.—When ships of any class are divided into efficient water-tight compartments to the satisfaction of the board of trade, they shall only be required to carry additional boats, rafts and buoyant apparatus of one-half of the capacity required by these rules, but the exemption shall not extend to life jackets or similar approved articles of equal buoyancy suitable to be worn on the person.
If this rule had become applicable to the Titanic, then the total cubical lifeboat or raft accommodation which she would have been required to carry would not have been more than 7,562 (equivalent to accommodation for 756 persons). It did not, however, become applicable for the owners never required the board of trade to express any opinion under the rule as to the efficiency of the water-tight compartments. The Titanic, in fact, carried boat accommodation for 1,178 persons, a number far in excess of the requirements of the table and rules, and therefore no concession under rule 12 was needed. Speaking generally, recourse to this rule (12) by shipowners has been so insignificant that the rule itself may be regarded as of no practical account.
The foregoing rules with the table were laid before Parliament in the usual way, and so received the required statutory sanction.
After 1894 steamers were built of a much larger tonnage than 10,000, the increase culminating in the Titanic, with a gross tonnage of 46,328. As the vessels built increased in size, one would have thought the necessity for increased lifeboat accommodation would grow; but the rules and table remained stationary and nothing was done to them by way of change. The explanation of this long delay (from 1894-1912) was given before me by Sir Alfred Chalmers, who had served under the board of trade as nautical adviser from 1896 to August, 1911. He is now retired. I think it will be well if I give his explanation in his own words. He says:
I considered the matter very closely from time to time. I first of all considered the record of the trade—that is to say, the record of the casualties—and to see what immunity from loss there was. I found it was the safest mode of travel in the world, and I thought it was neither right nor the duty of a state department to impose regulations upon that mode of travel as long as the record was a clean one. Secondly, I found that as ships grew bigger there were such improvements made in their construction that they were stronger and better ships, both from the point of view of water-tight compartments and also absolute strength, and I considered that that was the road along which the shipowners were going to travel, and that they should not be interfered with. I then went to the maximum that is down in the table, 16 boats and upward, together with the supplementary boats, and I considered from my experience that that was the maximum number that could be rapidly dealt with at sea and that could be safely housed without incumbering the vessel's decks unduly. In the next place I considered that the traffic was very safe on account of the routes, the definite routes being agreed upon by the different companies, which tended to lessen the risk of collision and to avoid ice and fog. Then again, there was the question of wireless telegraphy, which had already come into force on board of these passenger ships. I was seized of the fact that in July, 1901, the Lucania had been fitted with wireless telegraphy, and the Cunard Line generally fitted it during that year to all their ships. The Allan Line fitted it in 1902, and I am not sure that in 1904 it had not become quite general on the trans-Atlantic ships. That, of course, entered into my consideration as well. Then another point was the manning. It was quite evident to me that if you went on crowding the ships with boats you would require a crew which were not required otherwise for the safe navigation of the ship, or for the proper upkeep of the ship, but you are providing a crew which would be carried uselessly across the ocean, that never would be required to man the boats. Then the last point, and not the least, was this, that the voluntary action of the owners was carrying them beyond the requirements of our scale, and when voluntary action on the part of shipowners is doing that, I think that any state department should hold its hand before it steps in to make a hard and fast scale for that particular type of shipping. I considered that that scale fitted all sizes of ships that were then afloat, and I did not consider it necessary to increase it, and that was my advice to Sir Walter Howell.
I appreciate this explanation, and I think there is much force in it. At the same time, it seems to me that it does not justify the delay. Even taking all these matters into consideration, it can not be that the provision for boat accommodation made in 1894 for vessels of 10,000 tons and upward remained sufficient to 1910, when vessels of 45,000 tons were being built. Two considerations demonstrate this. The first is that some shipowners recognized the insufficiency of the requirements of the board of trade, and voluntarily exceeded those requirements by providing larger boat accommodation than the old rules and table exacted. The second is that shortly before Sir Alfred Chalmers left the board of trade, the board had begun to direct attention to the amending of their rules in this connection.
It appears that in November, 1910, a question was asked in the House of Commons as to whether the attention of the president of the board of trade had been called to the fact that the Olympic, a sister ship of the Titanic, was provided with 14 lifeboats only. The answer given was that the Olympic (which was then in course of construction) would carry 14 lifeboats and two ordinary boats of an aggregate capacity of 9,752 cubic feet, which was in excess of the requirements of the statutory rules. On February 15, 1911, a further question was asked as to the date of the last regulations, and whether, having regard to the increased tonnage of modern ships, the desirability of revising the regulations would be considered by the board of trade. The answer by the president was:
Those regulations were last revised in 1894. The question of their further revision is engaging the serious attention of the board of trade, and I have decided to refer the matter to the merchant shipping advisory committee for consideration and advice.
Three days afterwards, namely, on February 18, 1911, a circular letter was sent out by the board of trade to the board's principal officers at Liverpool, London, and Glasgow asking each of those gentlemen to draft such an extension of the existing boat scale as he might think satisfactory and reasonable for the conditions of large passenger steamers. This circular letter was answered by the principal officer in Glasgow (Mr. Harris) on February 24, 1911, by the principal officer in London (Mr. Park) on February 27, 1911, and by the principal officer in Liverpool (Mr. Young) on March 3, 1911. It is sufficient to say of these answers that they all suggested a large extension of the statutory requirements.
Meanwhile, namely, on February 28, 1911, Mr. Archer, the board of trade's principal ship surveyor, had also drawn up a scale. This was a more exacting scale than that of any of the three principal officers. By his scale a vessel of the tonnage of the Titanic would have had to carry boat accommodation equivalent to at least 24,937 cubic feet, which would have been sufficient to hold all and more than all the persons who were on board at the time of the disaster (2,201). It would not, however, have been nearly sufficient to have held all that the vessel might lawfully have carried, viz, 3,547, and it is to be observed with reference to Mr. Archer's scale that in it he suggests an extension of rule 12, by which (if the vessel were divided into efficient water-tight compartments) the total boat accommodation might be reduced much more than rule 12 as it stands would permit. If this reduction be taken into account, the boat accommodation would fall so that it would be sufficient only for 1,750 persons. Mr. Archer's view was that shipowners should be encouraged to increase the floatability of the ships they built, and that the way to encourage them was to relax the legal requirements as to boats as their plans advanced in that direction. The great object was so to build the ship that in the event of a disaster she would be her own lifeboat.[4]
Having obtained these four reports, the board of trade, on April 4, 1911, submitted the matter to their advisory committee, and obtained the committee's report on July 4, 1911. The following are copies (with omissions of immaterial passages) of the board of trade's letter of April 4, 1911, and of the advisory committee's report of July 4, 1911:
Board of Trade, Marine Department, 7 Whitehall Gardens, London, SW., April 4, 1911.
SIR: I am directed by the board of trade to inclose herewith, for the information of the merchant shipping advisory committee, a copy of a question asked in the House of Commons on February 15 and of the answer given by the president of the board of trade with reference to the life-saving appliances rules made under section 427 of the merchant shipping act, 1894.
The board are of opinion that the table in the appendix to the rules should be extended upward in the form indicated in the accompanying scale, so as to provide for vessels of tonnage up to 50,000 tons gross and upward.
It appears to the board that the number of boats and the boat capacity need not necessarily increase in a regular proportion according to the increase in tonnage, and that due regard should be paid to what is reasonable and practicable in passenger steamers exceeding 10,000 tons. * * *
I am to state that the board would be obliged if the merchant shipping advisory committee would be so good as to suggest in what manner the scale (see accompanying copy) should be continued upward, having due regard to the considerations indicated above.
I am further to state that the board would be glad to learn whether the advisory committee are of opinion that rule 12 should or should not be revised so as to exempt altogether from the requirement of additional boats or rafts those vessels which are divided into efficient water-tight compartments to the satisfaction of the board of trade. * * *
I am, etc., WALTER J. HOWELL.
The SECRETARY, Merchant Shipping Advisory Committee
Merchant Shipping Advisory Committee, July 4, 1911.
SIR: We have the honor to report that your letter of April 4 with reference to the minimum number of lifeboats to be earned on vessels of 10,000 tons gross tonnage and upward, and your letter of May 17 on the subject of the depth of lifeboats, have been very carefully considered by the merchant shipping advisory committee and that it was unanimously decided at a meeting held on the 29th ultimo to adopt the report of a subcommittee which was specially appointed to inquire into these questions.
A copy of the report is accordingly forwarded herewith, and the committee desire us to suggest for the consideration of the board of trade that effect should be given to the recommendations contained in it.
We are, etc.,
NORMAN HILL, Chairman. R. W. MATTHEW, Secretary.
SIR WALTER J. HOWELL, Assistant Secretary Marine Department, Board of Trade.
REPORT OF THE LIFE-SAVING APPLIANCES SUBCOMMITTEE TO THE MERCHANT SHIPPING ADVISORY COMMITTEE.
In accordance with the decision of the merchant shipping advisory committee, at their meeting on Friday, April 28, we have given careful consideration to the latter of April 4 from the board of trade, in which the committee were asked to advise: (1) As to the manner in which the table in the appendix to the Life-Saving Appliances Rules should be extended so as to provide for vessels of tonnage up to 50,000 tons gross and upward; and (2) as to whether rule 12 should or should not be revised so as to exempt altogether from the requirement of additional boats and (or) rafts, those vessels which are divided into efficient water-tight compartments to the satisfaction of the board of trade.
In considering these questions, we have had specially in mind the fact that the number of passengers carried does not necessarily increase in proportion to the increase in the tonnage of the vessel. This is particularly true in the case of vessels exceeding 10,000 tons, a type of vessel which is practically only built to provide special accommodation for large numbers of first and second class passengers.
Similarly there is no fixed relation between the tonnage of vessels and the deck space available for the carrying of lifeboats under davits. Increase in the length of a vessel is only one of the factors, and often not the most material factor contributing to the increase in its tonnage, and it should also be remembered, in estimating the space available for the launching of lifeboats, that it is impossible to place davits forward of the bridge, and very undesirable to have them on the quarters of the vessel.
We are strongly of opinion that every encouragement should be given to secure the provision of vessels which by their construction have been rendered as unsinkable as possible, and which are provided with efficient means for communicating with the shore or with other vessels in case of disaster.
In view of these considerations, we have agreed upon the following recommendations:
1. That it is questionable whether it is practicable to increase the number of davits.
2. That any increase in the number of lifeboats to be carried can probably be best effected by providing for the launching of further boats from the existing davits.
3. That the table should be extended in the manner indicated below, viz.:
Gross tonnage. Minimum number of boats to be placed under davits. Minimum number of additional boats to be readily available for attachment to davits. Total minimum cubic contents of boats required by columns 2 and 3.
Cubic feet.
10,000 and under 12,000 16——,500
12,000 and under 20,0001626,200
20,000 and under 35,0001646,900
35,000 and under 45,0001667,600
45,000 and upward1688,300
It is further recommended that all passenger vessels of 10,000 tons gross tonnage and upward should be required to be fitted with wireless telegraphy apparatus.
4. That the rules should be amended so as to admit of decked lifeboats of an approved type being stowed on top of one another or under an open lifeboat, subject to suitable arrangements being made for launching promptly the boats so stowed.
5. That the additional boats and rafts required under the provisions of Division A, class 1(d) of the Life-Saving Appliances Rules shall be of at least such carrying capacity that they, and the boats required by columns 2 and 3 of the above table, provide together three-fourths more than the minimum cubic contents required by column 4 of that table.
6. That vessels divided into efficient water-tight compartments to the satisfaction of the board of trade should (provided they are fitted with wireless telegraphy apparatus) be exempt from the requirement of additional boats and (or) rafts. The committee suggest, in this connection, that the board of trade should review the requirements designed to attain the standards as to water-tight compartments at present enforced by them under rule 12, having regard to the developments of shipbuilding since the report of the committee on the spacing and construction of water-tight bulkheads.
We have also had before us the board's further letter of May 17 inquiring whether, in the opinion of the advisory committee, it would be advisable to prescribe a maximum depth for lifeboats as compared with their breadth, and, if so, what that proportion should be.
In connection with this letter we have been supplied by the board of trade with reports from their principal officers in Great Britain, giving the dimensions and cubic capacities of the various kinds of boats on five typical ships in each of eight ports.
We recommend that the board should be advised to alter the Life-Saving Appliances Rules so as to provide that, in future, the depth of lifeboats supplied to a British merchant vessel shall not exceed 44 per cent. of their breadth.
NORMAN HILL. S. CROSS. GEO. N. HAMPSON. T. ROYDEN. THOMAS SPENCER. A. M. CARLISLE. WM. THEODORE DOXFORD. ROBERT A. OGILVIE. T. ROME. J. HAVELOCK WILSON.
It will be observed that if effect had been given by the board of trade to the report of the advisory committee the requirements for a vessel of the size of the Titanic would have reached 14,525 cubic feet (8,300 plus three-fourths of 8,300, namely, 6,225), with, however, this qualification that if the vessel were divided into efficient water-tight compartments (as she probably was) and fitted with wireless telegraphy (as she certainly was) a provision of a boat capacity of 8,300 cubic feet, equivalent to space for 830 persons, would have been legally sufficient. This would have been much less than the accommodation with which the Titanic when she put to sea was, in fact, provided (namely, for 1,178 persons).
Effect, however, was not given to the report. A question arose with reference to the dimensions of lifeboats, and it was thought better to get that question settled before proceeding to revise the rules. The examination of this question involved making several experiments which caused delay; and it was not until April 16, 1912, that a reply was sent by the board of trade to the advisory committee. It will be noticed that the date of this reply is just after the disaster to the Titanic became known. I am, however, quite satisfied that instructions for the preparation of this letter had been given in the offices of the board of trade some days before the 16th, and that the letter was not sent in consequence of the disaster. It is desirable to set it out.
Board of Trade, Marine Department, 7 Whitehall Gardens, London, S. W., April 16, 1912.
SIR: With reference to your letter of the 4th July last respecting certain questions raised in connection with the proposed revision of the Life-Saving Appliances Rules, I am directed by the board of trade to state, for the information of the advisory committee, that they have given very careful consideration to the report of the life-saving appliances subcommittee which was forwarded with your letter.
As regards the recommendations with reference to the proposed extension of the table (appendix to the Life Saving Appliances Rules) showing the minimum number of boats to be placed under davits, the board are glad to observe that the committee agree that alterations and additions are now necessary to meet the changed conditions due to recent developments in the size of passenger steamships and in the number of persons which these vessels can accommodate.
The board of trade note that the gradations of tonnage in the extension of the scale suggested by the advisory committee are not the same as those in the form of scale submitted to them by the board; while the increase in the number of boats is not in the number to be placed under davits, but in the number of additional boats required to be readily available for attachments to davits. It is observed that the committee hold the view that "it is questionable whether it is practicable to increase the number of davits," and "that any increase in the number of lifeboats to be carried can probably be best effected by providing for the launching of further boats from the existing davits."
The board presume that, in arriving at these conclusions, the committee have had regard to ships already built rather than to new ships, as they see no reason why there would be any difficulty in having more than eight pairs of davits on each side of the ship, provided that the requirements of Life-Saving Appliances Rules were known before the plans were prepared.
The board are of opinion that a very careful and thorough revision of the table should now be made, and I am to transmit herewith a copy of a memorandum and tables prepared by the professional advisor to the marine department, containing a full and considered opinion on the subject of the extension of the boat scale and cognate questions.
As regards the proposed amendment of the rules, so as to admit of decked lifeboats of an approved type being stowed one above another, or under an open lifeboat, I am to state that this question is now under consideration, and a communication will be addressed to you shortly on the subject.
With reference to the advisory committee's recommendation regarding the amendment of rule 12 of the general rules, the board desire me to state that the questions raised in the recommendation are of wide application and of such importance that the board do not think that they can be adequately considered except by a committee of equal standing to the committee which reported in 1891 on the spacing and construction of water-tight bulkheads in the mercantile marine. The board have the question of the appointment of a committee under consideration.
In connection with the advisory committee's recommendation that the depth of lifeboats shall not exceed 44 per cent. of their breadth, I am to transmit herewith, for their consideration, a draft amendment of rules Nos. 1, 2, and 3 of the general rules with reference to the construction of ships' boats.
The board have made full inquiry into the question of the construction of ships' boats, and obtained some useful information as to the average depth of boat which is deemed desirable for safety and utility, and the ratio of that depth to the breadth, and they attach so much importance to this element of boat construction that they think it should receive the careful attention of the committee. The board think that the committee, in the light of this additional information, may reconsider the opinions expressed on this point in their letter of July 4.
I am therefore to transmit herewith copies of memoranda by the professional adviser to the marine department and the acting principal ship surveyor.
The board desire me to state that they would be glad to be furnished with the advisory committee's views as to the application of the proposed new rules and boat scale, e. g., whether they should apply to ships already built, and if so, to what extent. They regard it as of great importance, on the one hand, that all British vessels should be provided with a proper and sufficient equipment of life-saving appliances, and, on the other, that regulations should not be enforced without notice which would necessitate important structural alterations and consequent heavy expense in vessels already built.
I am to add that in order to make the constitution of the committee, when considering this question, agree with that of the statutory life-saving appliances committee indicated in the seventeenth schedule to the merchant shipping act, 1894, the board have followed the course adopted on previous occasions, and have invited Lloyd's Register of British and Foreign Shipping and the Institute of London Underwriters to select a representative who will be available to sit on the advisory committee when the question is under consideration.
I am, etc., WALTER J. HOWELL.
The SECRETARY, Merchant Shipping Advisory Committee, 7, Whitehall Gardens, S. W.
EXTENSION OF LIFE-SAVING APPARATUS TABLES.
It will be seen that I have given priority in importance to the form of ships' boats rather than to their number on the principle that a few reliable boats are of greater value than a large number of indifferent ones; but if the former desirable condition can be obtained by the proposed alterations in our rules as to measurement, etc., we are freer to approach the question of adding to the number of boats provided for in the existing tables.
As with the question of ratio D: B dealt with by the advisory committee last year, so with the question of boat increase and relative increase of cubic capacity dealt with by them on the same occasion, perhaps the board might inform the committee that they are not satisfied that a slightly different recommendation might not have been made had the matter been still further considered at the time.
Referring to the table of boat capacities computed by them particularly it might be helpful if the board laid before them for consideration the table, which I attach hereto and submit, as showing a more reasonable proportionate increase in capacity than appears so far, in my opinion, in the other papers before us. It will be seen in this statement that the number of boats recommended by the advisory committee is practically retained, but the unit of increase in capacity is put at 300 cubic feet.
Perhaps I should state here what actuated me in fixing upon this rate of increase. I realized that in all probability it would become the practice on these large liners to provide boats under davits which would contain the entire cubic feet required by the L. S. A. Rules, that is—the quantity required by rule under davits plus the addition of three-fourths and it occurred to me that if, after the figure 5,500 cubic feet the increase of capacity were uniform and moderate it would result in a total at 1-3/4 which would by incidence fit in with the scale of boats already recommended as requisite in the report of the advisory committee and in my own, i. e., assuming that the boats are of 500 cubic feet. Example: Take a vessel of 30,000 tons and under 35,000 tons, according to the table I submit she would be required to have by the 1-3/4 rule a total boat capacity of 12,500 cubic feet which at 500 cubic feet per boat equals 24 boats nearly. There should be no difficulty on the large ships in carrying this quantity under davits, i. e., 18 directly under davits and six boats inboard.
Please see incidental table attached.
(Mr. A. H. Young, professional adviser of the board of trade.)
MARCH 28, 1912.
Proposed extension of boat scale.
Gross tons. Boats. Minimum total cubic contents of boats required to be carried under davits.
Cubic feet.
10,000 and under 12,000165,500
12,000 and under 15,000185,800
15,000 and under 20,000206,100
20,000 and under 25,000226,400
25,000 and under 30,000246,700
30,000 and under 35,000247,000
35,000 and under 40,000247,300
40,000 and under 45,000247,600
45,000 and under 50,000267,900
50,000 and upward 268,200
Please see the accompanying incidental table showing how this number of boats can provide for the three-quarters additional capacity also, if of about 500 cubic feet per boat to 600 cubic feet.
A. H. Y.
Table of incidence (informative).
Gross tons. Number of boats. Cubic feet. Cubic feet additional. Total cubic feet at 1-3/4. Equivalent boats.
At 500 cubic feet. At 600 cubic feet.
10,000 and under 12,000 165,5004,125 9,6251916
12,000 and under 15,000185,8004,35010,1502016
15,000 and under 20,000206,1004,57510,6752118
20,000 and under 25,000226,4004,80011,2002219
25,000 and under 30,000246,7005,02511,7252420
30,000 and under 35,000247,0005,25012,2502420
35,000 and under 40,000247,3005,47512,7752521
40,000 and under 45,000247,6005,70013,3002622
45,000 and under 50,000267,9005,92513,8252723
50,000 and upward 268,2006,15014,3502824
One-fourth of the above boats may be carried inboard, but they should not exceed 500 cubic feet in capacity, so that they may be readily drawn up to the davits.
A. H. Y.
MARCH 30, 1912.
DRAFT AMENDMENT OF GENERAL RULES.
(1) Boats.—All boats shall be constructed and properly equipped as provided by these rules, and shall be of such form and proportions that they shall have sufficient freeboard, and ample stability in a seaway, when loaded with their full complement of persons and equipment.
All thwart and side seats must be fitted as low in the boat as practicable, and bottom boards must be fitted so that the thwarts shall not be more than 2 feet 9 inches above them.
All boats and other life-saving appliances are to be kept ready for use to the satisfaction of the board of trade. Internal buoyancy apparatus may be constructed of wood, or of copper or yellow metal of not less than 18 ounces to the superficial foot, or of other durable material.
SECTION (A). A boat of this section shall be a lifeboat of whaleboat form, properly constructed of wood or metal, having for every 10 cubic feet of her capacity, computed as in rule (2), at least 1 cubic foot of strong and serviceable inclosed air-tight compartments, so constructed that water can not find its way into them. In the case of metal boats an addition will have to be made to the cubic capacity of the air-tight compartments, so as to give them buoyancy equal to that of the wooden boat.
SEC. (B). A boat of this section shall be a lifeboat, of whaleboat form properly constructed of wood or metal, having inside and outside buoyancy apparatus together equal in efficiency to the buoyancy apparatus provided for a boat of section (A). At least one-half of the buoyancy apparatus must be attached to the outside of the boat.
SEC. (C). A boat of this section shall be a lifeboat, properly constructed of wood or metal, having some buoyancy apparatus attached to the inside and (or) outside of the boat, equal in efficiency to one-half of the buoyancy apparatus provided for a boat of section (A) or section (B). At least one-half of the buoyancy apparatus must be attached to the outside of the boat.
SEC. (D). A boat of this section shall be a properly constructed boat of wood or metal.
SEC. (E). A boat of this section shall be a boat of approved construction, form, and material, and may be collapsible.
(2) Cubic capacity.—The cubic capacity of an open boat and of a deck boat of section (D) or section (E) shall be ascertained by multiplying the product of the length, breadth, and depth by 6, subject, however, to the following provisions:
The length shall be measured from the foreside of the rabbet on the stem to the afterside of the rabbet on the sternpost, and the breadth shall be measured from the outside of plank to the outside of plank amidships. The actual depth shall be measured from the top of the gunwale to the top of the bottom plank next to the keel, but the depth used in calculating the cubic capacity shall not in any case exceed 3.6 feet; and if the actual depth measured is equal to or less than 3.6 feet, the depth used in calculating the cubic capacity shall not exceed 45 per cent of the breadth measured, as indicated above.
If the oars are pulled in rowlocks, the bottom of the rowlock is to be considered as the gunwale in measuring the depth of the boat.
If any question is raised requiring absolute accuracy, the cubic capacity of a boat shall be ascertained by Stirling's rule, subject to the foregoing provisions as to depth.
(3) Number of persons for boats.—(A) Subject to the provisions of paragraphs (b) (c) and (d) of this clause the number of persons[5] an open boat of section (A) shall be deemed fit to carry shall be the number of cubic feet ascertained as in rule (2) divided by 10, and the number of persons[6] an open boat of section (B) or section (C), or an open or decked boat of section (D) or section (E) shall be deemed fit to carry shall be the number of cubic feet ascertained as in rule (2) divided by 8. The space in the boat shall be sufficient for the seating of the persons carried in it and for the proper use of the oars.
(B) An open boat of section (A) or section (B) or section (C) or section (D) or section (E) shall not be deemed to be fit to carry the number of persons ascertained as in paragraph (A) of this clause unless the boat is so constructed that it has a mean sheer of at least half an inch for each foot of its length and that the boat's half-girth amidships measured outside the planking from the side of the keel to the top of the gunwale is at least equal to nine-tenths of the sum of the boat's depth inside and half its maximum breadth amidships, and that the mean of the half-girths measured in the same manner at two points, one-quarter of the length of the boat from the stem and sternpost, respectively, is at least equal to eight-tenths of the sum of the depth inside and half the maximum breadth amidships.
(C)—A decked boat of section (D) or section (E) shall not be deemed to be fit to carry the number of persons ascertained as in paragraph (A) of this clause, unless the top of the deck amidships is at a height above the water approved by the board of trade, when the boat is so loaded.
(D)—If the surveyor is doubtful as to the number of persons any open or decked boat is fit to carry, he may require the boat to be tested afloat with the intended number of persons on board.
(E)—The rules numbers 1, 2, and 3, as now amended, are not to be retrospective, and are to apply only to boats built after.
SHIP'S BOATS.
The salient feature of the reports of the board's officers on this subject is the consensus of opinion that the form of a boat is the chief factor to be considered in determining its value as a life-saving appliance.
It has been found that while there are many boats of good form supplied to ships, there is yet a large proportion where the boats are not only not so good, but which can only be regarded as unsafe if they had on board anything approaching the number of persons for which they measure.
It is the latter type we are chiefly concerned with; how is it that the form has so deteriorated as to create this concern in our minds? I think the cause is not far to seek; it appears to be the outcome of (1) the shipowner's desire to carry the maximum number of persons in the minimum number of boats; (2) in the efforts of the ship-builder, as a rule, to carry out the specification in which he has contracted to supply the owners with boats at a price, often very low, and naturally he does not sublet his contract with the boatbuilder at a loss; (3) the aim of the competing boatbuilder, which is to build his boats at as little cost price as possible, and yet to provide accommodation for the prescribed number of persons. He is probably limited as to length, and therefore relies on the breadth and depth; in this direction, he is unintentionally assisted by the board's rule for measurement, viz,
L × B × D × .6 10
or 8; so long, therefore, as he can obtain his breadth at one point for measurement purposes, it is quite immaterial to him how soon he fines away to the ends, with the result that the stability of the boat becomes almost entirely dependent upon the form of a very limited midship section, or the still smaller proportion of same that would be under water when in the loaded condition.
The boatbuilder may be further restricted as to breadth, and, therefore, he again detracts from the form a boat should have by dispensing with sheer and increasing the depth from keel to gunwale amidships. This method of building boats enables him to obtain the capacity required by the owner at the expense of the boat's stability and utility.
No doubt when the life-saving appliances rules came into being the divisors 10 and 8 for the different sections were deemed safe on the supposition that the usual full form of boat would not be largely departed from. Experience has shown, however, that form is frequently sacrificed for the unworthy objects referred to above, and it follows, therefore, that either the form should be improved or a heavier divisor laid down.
It would, I think, be more effective to deal with form and devise a rule by which we can insure that a boat will be reasonably safe with its load, not merely in smooth water, as in our recent test, but in a seaway. It is essential, therefore, to draw the attention of the advisory committee to the value the board attach to form, and particularly to that part of it under water, emphasizing the great necessity there is for an increase to the bearing surface of the under-water portion of boats, and this end can, no doubt, be best attained by the putting into practice of the suggestions made by the principal ship surveyor for amending the rules and which aim at prolonging the form or fullness of dimension of the midship body under water well toward the ends of the boat. It is well known that by extending the body in this way greater buoyancy and stability are secured without materially affecting the speed. It is often supposed that defective stability due to bad form can be rectified by the disposition of the persons or things, but anyone with real experience of boats in a seaway can not fail to realize that this is the wrong principle to work on. Granted, therefore, that the question of form must take priority, how can it be best attained? And if we refer to Mr. Archer's method of measurement, as stated in his amendment to the rules, it will be seen how simple and effective it is. For the purpose of illustration, we might take the model of a ship's boat obtained through the board's surveyors at Glasgow, the dimensions of which enlarged to scale represent a boat of
L B D 30.0 × 8.5 × 3.5
and is an embodiment of the proportions amidships and at quarter distance from each end proposed by Mr. Archer.
It can not be too strongly urged that for a ship's lifeboat to be fit to carry the number of persons it measures for in any degree of safety, whenever it may be required at sea, the under-water or bearing surface should be carried out to the ends as much as possible and all straight lines avoided. The bows of many of the existing types of boat are examples of the worst possible form for safety, and the counters are as bad, if they can be said to have any.
Depth.—It appears from the reports that the most generally approved ratio of depth to the breadth is 4 10.
This has been established not only by our long experience, but by the numerous tests recently conducted by the board's surveyors at various ports, and the attention of the advisory committee might be drawn to this fact.
It is, of course, necessary also to have a good freeboard, but a well-proportioned boat does not require so much freeboard as the commoner type, as with proper sheer and under-water surface she is easy in a seaway. If the gunwale is too high, there is loss of power over the oars, which is serious when for the safety of the boat she is required to be kept head-on to sea, and with a fresh breeze, even in a good boat, this is not always an easy matter.
It is a matter for consideration that at the tests made by our surveyors the conditions were most favorable, being usually in smooth water of a sheltered dock, and, in not a few instances, considerable anxiety was felt for the safety of those on board when crowded in accordance to the existing rules. If it was thus in smooth water, one dare hardly contemplate the results in a seaway. If the shipowner does not see to it that a safe type of boat is provided, then the number of persons to be accommodated in boats which do not come up to the proportions deemed safe by the board of trade should be very considerably curtailed.
A. H. Y.
MARCH 23, 1912.
CONSTRUCTION OF SHIP'S BOATS.
It will, I think, be useful to consider the principal factors that govern the dimensions of boats forming part of the life-saving apparatus in merchant ships.
The minimum number and capacity of boats are determined by the regulations, and the capacity is determined by the product of the length, breadth, and depth of the boats. As the space on the ship in which to stow the boats is generally limited, it is generally found easier to increase their depth than the length or breadth, and this is further encouraged, I believe, by the cost of boats being quoted at so much per foot in length. The builder or owner determines the dimensions of the boat; the boatbuilder is concerned merely with the construction and, in most cases, usually their form or lines.
Attention has been called by the mark lane surveyors to the form and proportions of the boats used in the Royal navy. The proportion of depth to breadth is greater than is apparent from the particulars given, as all boats larger than a 30-foot gig have 6-1/2-inch washboards above the gunwale, and even the gigs and many of the smaller boats have portable washboards. It must also be remembered that all the navy boats are square-sterned, except the whaleboat, and are designed with easy lines so as to make good sailers; no air cases are fitted, and the seats are kept very low. The boats are not provided simply as life-saving appliances; as a matter of fact, the life-saving equipment of a warship is extremely small. It is true that each type of boat is given a certain "life-saving capacity," which is ascertained by crowding in as many men as practicable with boat in still water and all equipment on board.
This number agrees closely with that obtained by the board's rule L × B × D × .6 8.
These boats, moreover, have a much smaller freeboard than is considered desirable in the merchant navy; but the occupants are all under discipline and in charge of experienced seamen. In the mercantile marine it may, and often does, happen, that the boats are crowded with panic-stricken men, women, and children, and instances have occurred, I believe, wherein there has not been a single man in the boat who has ever handled an oar before. Having these points in view, I do not agree that the navy type of boat is the most suitable for our purpose.
The chief desiderata in a ship's boat as a life-saving appliance are, (1) to carry the maximum number of people without overcrowding; and with (2) a reasonable amount of stability and freeboard; (3) and without undue interference with the use of oars.
(1) Is almost wholly dependent on the length and breadth of the boat; provided (2) is satisfied; depth has very little influence on it. For example, take a boat 30 × 9 × 3.5, 567 cubic feet by our rule, as a section (D) or (E) boat it should carry
567 8=72
people; such a boat should allow
30 × 9 × 8 72=3
square feet of area per person at the gunwale, which should be ample if all sit in the bottom who can not find seating room on the side benches or thwarts.
(2) Stability and freeboard are dependent upon the boat's breadth, depth, and form. The element of length does not enter into it, and it would be most unreasonable to limit the ratio of length to breadth, as suggested from Liverpool, or to limit the depth to the cube root of the length, as proposed by one of the London surveyors. Mr. Gemmell gives particulars, M. 26,298, of four boats tested, which proved to have ample accommodation and stability for the complements allowed by the regulations; the ratio of depth to breadth varied from 0.41 to 0.45.
Capt. O'Sullivan also reported five boats which he tested with ratios of D to B, varying from 0.4 to 0.44, all except one being satisfactory, the exception being rather tender and overcrowded, due to poor lines. The freeboards of all these boats when loaded were, I think, sufficient. The depth in no case exceeded 3.6, and only in one case did the ratio exceed 0.44.
The surveyors, Liverpool, tested a boat 3.75 deep and having a ratio of D/b = 0.41, which proved satisfactory.
Capt. Griffiths tested a boat 4.1 deep, having a ratio D/b = 0.455, which he considered to be unsafe with the full complement on board.
The consensus of opinion is that the depth should not exceed 3 feet 5 inches or 3 feet 6 inches, and the ratio of D/b should not exceed 0.44. This, however, is not sufficient to guarantee sufficient seating and stability. Capt. Clarke tested a boat 24.4 × 6.55 × 2.45, which was very unsafe with the rule complement on board. The ratio D/b is only 0.38 in this case. It will be seen, however, that this craft has exceptionally fine lines and is evidently quite unsuited to carry the rule complement. It is quite evident that the form of the boat must be taken into account.
The dimensions of boats vary so greatly that generally the boat builder builds his boats "to the eye," using only a midship mold; it follows that the forms of boats of the same dimensions will vary considerably and with different workmen. Something more is required than a limitation in the ratio of depth to breadth. It is desirable that the sheer should be ample, and the form not unduly fined away within the midship half length. From consideration of the particulars and lines of the boats mentioned in the surveyor's reports, I think a simple rule to regulate the form may be devised such as I will indicate later.
It is, I think, necessary to limit the depth as a factor for ascertaining the number to be accommodated. The increase of depth beyond a certain point, while unduly increasing the number of people that may be carried, increases proportionately the required air case capacity, to meet which the seats have to be raised with a corresponding increase in the height of the center of gravity and decrease in the stability and difficulty in rowing. A boat 3.6 deep would have the thwarts about 3 feet above the bottom, and any increase in this height makes it very difficult for any ordinary man to row when sitting down. In rough sea the men would have very little control over the oars if standing up. A further objection to the very deep boat is its small stability in the light condition. It is not, I believe, an unusual occurrence for such boats to capsize in rough weather, before the passengers or crew can be got into them, and I have myself seen such a boat capsize in dock with only two men in it; due to lumpy water and a stiff breeze catching it on the beam when coming out of the shelter afforded by the dock wall.
I do not think, however, any limit of depth should be imposed, except as a measure of capacity. Any rules that may be devised should be such as are of easy and ready application, and which will not bear harshly on the boats that have already been accepted. I therefore suggest that the present rules will sufficiently meet the case, with the following modification.
In no case should the depth to be used in general rule (2) exceed 3.6 feet and 45 per cent of the breadth. In all cases where the actual depth is 45 per cent of the breadth or less, the maximum number of persons, as ascertained by rule (3) should not be allowed unless the boat has been found capable of carrying that number by actual test in the water, or unless the boat has at least 1/2 inch of sheer per foot of length, and the half-girth amidships, measured outside the plank, from the side of the keel to the top of the gunwale, is at least 90 per cent of the sum of the depth and the half breadth, and the mean of the half girths as similarly measured at one quarter the boat's length from the stem and stern post are at least 80 per cent of the sum of the midship depth and half breadth.
The thwarts and side benches should be kept as low as practicable, and the bottom boards should be so fitted that the height of the thwarts above them will not exceed 2 feet 9 inches.
A. J. D.
JANUARY 27, 1912.
(Mr. A. J. Daniel, acting principal Ship Surveyor to the Board of Trade.)
It should be stated that the new committee on bulkheads mentioned in the paragraphs of this letter which deals with rule 12 has now been formed.
Subsequently Sir Walter Howell wrote and sent three letters to the Advisory Committee which were as follows:
Board of Trade, Marine Department, 7 Whitehall Gardens, London, S. W., April 20, 1912.
SIR: With reference to previous correspondence between the department and your committee respecting the revision of the statutory rules for life-saving appliances on British ships, and particularly to the letter from this department of April 16, I am directed by the board of trade to state that as an entirely new situation has been created by the recent disaster to the steamship Titanic they assume that the committee, in reconsidering the matter in connection with the suggestions already put before them by the board will have full regard to this new situation, and the facts of the disaster so far as ascertained.
As you are doubtless aware, suggestions have been made in the House of Commons and elsewhere to the effect that, in view of the loss of the Titanic, action should be taken by the board of trade in regard to certain questions other than those expressly dealt with in the life-saving appliances rules, e.g., in regard to (1) steamship routes in the North Atlantic; (2) the speed of steamers where there may be dangers to navigation; and (3) the provision and use of searchlights on large passenger steamers; and the board would be glad to know the committee's views in regard to these, and any other suggestions which may have come to their knowledge, intended to diminish the risk, or to mitigate the effects of accidents to passenger vessels at sea.
I am, etc.,
WALTER J. HOWELL.
The SECRETARY, Merchant Shipping Advisory Committee.
Board of Trade, Marine Department, 7 Whitehall Gardens, London, S. W., April 24, 1912.
SIR: With reference to previous correspondence between this department and your committee respecting the revision of the statutory rules for life-saving appliances on British ships, and particularly to the letter from this department of April 16, in which you were informed that the question of the proposed amendment of the rules so as to admit of decked lifeboats being stowed one above another or one under an open lifeboat, was under consideration, I am directed by the board of trade to state, for the information of your committee, that the board of trade will be glad if the committee will consider whether any, and if so what, amendments of the rules, and in particular of the rule of April 19, 1910, and the rule of June 14, 1911, are, in their opinion, desirable with the object of supplementing the boats immediately under davits by as much additional boat accommodation as is practicable, having regard to the new situation which has been created by the recent disaster to the steamship Titanic.
A plan illustrating the principle is being prepared so as to be in readiness for your committee by Friday.
I am, etc.,
WALTER J. HOWELL.
The SECRETARY, Merchant Shipping Advisory Committee.
Board of Trade, Marine Department, 7, Whitehall Gardens, London, S. W., April 25, 1912.
SIR: With reference to previous correspondence respecting the proposed revision of the statutory regulations as to boats and life-saving appliances on ships, I am directed by the board of trade to state, for the information of the merchant shipping advisory committee, that, apart from the questions which have been raised regarding the boat accommodation on vessels over 10,000 tons, it seems desirable to consider whether the provision of boats and other life-saving appliances required by the rules in the case of vessels under 10,000 tons is satisfactory, or whether the rules or the boat scale should be altered in respect of their application to such vessels; and the board would be glad to be favored with the observations of the committee on this point in addition to those that have already been referred to them.
I am, etc., WALTER J. HOWELL.
The SECRETARY, Merchant Shipping Advisory Committee.
To these letters the advisory committee sent the following answer:
Merchant Shipping Advisory Committee, 7, Whitehall Gardens, London, S. W., April 27, 1912.
SIR: We are desired by the merchant shipping advisory committee to inform you that your letters of the 16th, 20th, 24th, and 25th instant were brought before the committee at a meeting held yesterday.
The committee fully recognize that the proved impossibility of keeping such a vessel as the Titanic afloat after a collision with ice until the arrival of outside succor has created an entirely new situation which was neither in the contemplation of the board of trade nor of the committee in the consideration of the extension of the existing boat scale in regard to vessels of 10,000 tons and upward.
In advising on such extension in July last, the committee aimed at providing ample boat accommodation on large passenger vessels in accordance with the principles that were adopted by the original life-saving appliances committee, and which principles had apparently been fully justified by many years of experience. It is with satisfaction that the committee note that the board of trade, apart from the new possibilities demonstrated by the loss of the Titanic, agreed in the essentials with the recommendation of the committee.
In face of the new facts, the committee at their meeting yesterday reopened entirely the question of the revision of the boat scale for large passenger vessels with a view of providing the maximum of protection for the passengers and crew in the event of an overwhelming disaster, whilst at the same time maintaining the principles in regard to the stability and sea-going qualities of the ship itself, and to the prompt and efficient handling of the boats carried under the existing scale, which hitherto have proved not only essential to safety, but also adequate for all ordinary emergencies. The questions involved are not free from difficulty, but they will receive the immediate attention of the committee. Pending their consideration, the committee note that assurances have been received by the board of trade from representatives of most of the large passenger lines to the effect that every effort will be made to equip their vessels, at the earliest possible moment, with boats and rafts sufficient to accommodate all persons on board.
In regard to the recommendation forwarded with the committee's letter of July 4 last, that the board of trade should, having regard to the developments in ship building since the report of the committee of 1891 on spacing and construction of water-tight bulkheads, review the requirements designed to attain the standards at present enforced under rule 12, the advisory committee note that the board of trade have under consideration the appointment of a committee of equal standing to that of the committee of 1891. In view of the great importance of this question the advisory committee desire us respectfully to urge that such a committee be appointed at as early a date as possible.
The subject of the general revision of the statutory regulations as to boats and life-saving appliances on all ships, which, apart from the questions regarding the boat accommodation on vessels over 10,000 tons, is for the first time referred to the advisory committee by the letter of the 25th instant, together with the particular questions raised in the letters of the 16th, 20th, and 24th instant, are also receiving the immediate attention of the committee.
At yesterday's meeting subcommittees were appointed to give immediate consideration to the subjects requiring detailed examination. These subcommittees will pursue their inquiries concurrently, and we are desired by the advisory committee to inform you that their investigation into the revision of the life-saving appliances rules will be proceeded with as expeditiously as possible.
We are, etc.,
NORMAN HILL, Chairman. R. W. MATTHEW, Secretary.
Sir WALTER J. HOWELL, K. C. B., Assistant Secretary Marine Department, Board of Trade.
This letter was acknowledged by the board of trade on May 10, 1912, as follows:
Board of Trade, Marine Department, 7, Whitehall Gardens, London, S. W., May 10, 1912.
SIR: I am directed by the board of trade to acknowledge the receipt of, and to thank you for, your letter of April 27, stating that their letters of April 16, 20, 24, and 25 have been considered by the merchant shipping advisory committee.
The board observes with satisfaction that, in view of the entirely new situation which has arisen, the advisory committee have decided to reopen the question of the revision of the table in the life-saving appliances rules in so far as it governs the boat accommodation in vessels over 10,000 tons gross. The board are further glad to observe that the question of a general revision of the life-saving appliances rules is also under consideration by the committee, and in this connection they presume that, in considering the question of a general revision of the rules including the table, the committee will consider the principles on which the requirements as to boat accommodation should be based, including, inter alia, whether the table should continue to be based on tonnage. Any conclusion reached by the committee on this question would naturally affect the revision of the present table as applying to vessels of more than 10,000 tons, upon which the committee has already been engaged.
The board agree with the view expressed by the advisory committee that the appointment of another committee on the spacing and construction of water-tight bulkheads is desirable. Steps have already been taken by the president to form such a committee, and he hopes to be able to announce the names within a few days. A further communication on this point will be addressed to the committee in the course of a few days.
The board are glad to note that subcommittees have been appointed to deal concurrently with the subjects requiring detailed consideration in connection with the revision of the life-saving appliances rules.
The board desire me to add that they assume that the committee, in considering the matters referred to them, will have regard to all important aspects of the question of life-saving appliances, whether expressly dealt with in the statutory rules or not, and in particular to the essential question of the adequacy of the provision for lowering and manning the boats and rafts carried by vessels.
I am, etc., WALTER J. HOWELL.
The SECRETARY, Merchant Shipping Advisory Committee, 7, Whitehall Gardens, S. W.
This finishes the history of the action of the board of trade in relation to the provision of boat accommodation on emigrant ships. The outstanding circumstance in it is the omission, during so many years, to revise the rules of 1894 and this, I think, was blameable, notwithstanding the excuse or explanation put forward by Sir Alfred Chalmers. I am, however, doubtful whether even if the rules had been revised the change would have been such as to have required boat accommodation which would have increased the number of lives saved. Having regard to the recommendations of the advisory committee, the board of trade would probably not have felt justified in making rules which would have required more boat accommodation than that with which the Titanic was actually provided; and it is not to be forgotten that the Titanic boat accommodation was utilized to less than two-thirds of its capacity. These considerations, however, afford no excuse for the delay of the board of trade.
The gross tonnage of a vessel is not, in my opinion, a satisfactory basis on which to calculate the provision of boat accommodation. Hitherto, I believe, it has been accepted as the best basis by all nations. But there seems much more to be said in favor of making the number of lives carried the basis and for providing boat or raft accommodation for all on board. Rule 12 of the life-saving appliances rules of 1902, which deals with water-tight compartments and boat accommodation, ought to be abolished. The provision of such compartments is of supreme importance, but it is clear that it should not be sought at the expense of a decrease in boat accommodation. When naval architects have devised practical means for rendering ships unsinkable, the question of boat accommodation may have to be reconsidered, but until that time arrives boat accommodation should, where practicable, be carried for all on board. This suggestion may be thought by some to be extravagant. It has never been enforced in the mercantile marine of Great Britain, nor as far as I know in that of any foreign nation. But it appears, nevertheless, to be admitted by all that it is possible without undue inconvenience or undue interference with commerce to increase considerably in many cases the accommodation hitherto carried, and it seems, therefore, reasonable that the law should require an increase to be made. As far as foreign-going passenger and emigrant steamships are concerned, I am of opinion that, unless justification be shown for deviating from this course, such ships should carry boats or rafts for all on board.
With reference to the second branch of the complaint against the board of trade, namely that their officials had failed to exercise due care in the supervision of the vessel's plans and in the inspection of the work done upon her, the charges broke down. Suggestions were made that the board's requirements fell short of those of Lloyd's Registry; but no evidence was forthcoming to support the suggestions. The investigation of the charges took much time, but it only served to show that the officials had discharged their duties carefully and well.
POWERS OF THE BOARD OF TRADE AS REGARDS THE SUPERVISION OF DESIGNS OF VESSELS.
The Titanic was efficiently designed and constructed to meet the contingencies which she was intended to meet.
The bulkheads were of ample strength. They were sufficiently closely spaced and were carried up in the vessel to a height greater than sufficient to meet the requirements of the 1891 bulkheads committee.
But I am advised that the ship could have been further subdivided so that she would probably have remained afloat longer than she did. The board of trade have, however, apparently no power to exercise any real supervision in the matter of subdivision. All they have express power to insist upon in this connection with respect to any steam vessel is that there shall be four water-tight bulkheads—a provision quite inadequate for safety in a collision damaging the vessel abaft the collision bulkhead. They can also, if invited by the shipowner (but not otherwise), exercise supervision under rule 12. This supervision, I am told, they have been invited to exercise in only 103 cases over a period of 18 years. In 69 of these cases the board have expressed their satisfaction with the subdivision provided. It seems to me that the board should be empowered to require the production of the designs of all passenger steamers at an early period of their construction and to direct such alterations as may appear to them to be necessary and practicable for the purpose of securing proper water-tight subdivision.