TIP | Limitation of Liability Hearings | Deposition of Edward Wilding - Resumed.

Limitation of Liability Hearings

Deposition of EDWARD WILDING, Resumed.

Re: Steamship Titanic:

New York, May 14, 1915.

Met pursuant to adjournment, as before.


EDWARD WILDING
resumes the stand.

CROSS EXAMINATION CONTINUED BY MR. BROUGHAM:

Q. About watertight decks, if they are placed above the waterline they would confine the water below, if the damage occurred below the waterline, would they not?
- It depends on the extent of the damage, because there are other openings in the ship's side. Damage, as soon as it occurs, alters the waterline.

Q. That is true, but that depends upon the height the watertight deck is placed above the waterline, does it not?
- Yes.

Q. Assuming that the damage below the waterline would not be sufficient to sink the vessel down to the watertight deck, then you would not have any such submergence as to bring water into any other compartment, would you?
- No.

Q. Also if it occurred in two compartments, the damage below the waterline, while that might sink the vessel, so that the watertight deck might be ultimately below the waterline, still the water would be excluded by the side of the ship?
- There are openings in the ship's side; it is not watertight.

Q. I said usually?
- It usually is not, at sea.

Q. You are speaking of the deadlights in the cabins?
- Which are usually open at sea.

Q. Assuming all those deadlights closed, then the ship would be watertight?
- Quite right.

Q. Assuming the watertight decks to be above the waterline, still, if the damage occurred above the watertight deck, it would be above the waterline too, and no water could get in?
- Quite right.

Q. And if the damage was both above and below the watertight deck, while the water would enter the compartments, that situation would merely be the same as if there was no watertight deck in that particular compartment?
- Quite right.

Q. So that whenever the watertight deck fulfils the purpose of a watertight deck, it is a measure of safety, is it not?
- It may be; it depends on the circumstances.

Q. Well, wherever it fulfils the purpose for which a watertight deck is constructed, then it is a measure of safety, is it not?
- It depends on the circumstances of the accident that it has to meet.

Q. It is the circumstance that you have discussed previously that you have in mind, is it not, of the deadlights being open, perhaps?
- Assuming that the ship's side is watertight and the deck watertight, except where locally damaged, then it will serve the purpose of a watertight deck and it will, against accidents, limited as you have described, be a measure of safety.

Q. In reference to longitudinal bulkheads, watertight, you have said that if one compartment was flooded, while the ship might list, still the boats could be launched on the other side?
- Probably.

Q. And if two compartments were flooded, it would be doubtful?
- Yes.

Q. And if three were flooded, it could be impossible?
- Yes; I believe so.

Q. That depends altogether upon the length and breadth and height of the compartments that are flooded, does it not?
- Quite.

Q. Inasmuch as it does depend upon that, it depends upon the distance the longitudinal bulkhead is placed from the skin, of the ship?
- That is involved in the size of the compartments.

Q. It is obvious that longitudinal bulkheads could be so placed, even with four of these compartments between the skin of the ship and the longitudinal bulkhead flooded, there would not be such great listing as to destroy the balance of the ship to such an extent as to make it impossible to launch lifeboats on the other side?
- It would be possible if the longitudinal bulkhead was placed in such a position that it virtually became an inner skin instead of a longitudinal bulkhead.

Q. What is the limit?
- The things merge into one another.

Q. An inner skin is in effect a longitudinal bulkhead?
- It is the limit of a longitudinal bulkhead, yes.

Q. And it may be anywhere from 30 inches to 5 feet from the skin of the ship?
- Something of that sort.

Q. And still be either an inner skin or a longitudinal bulkhead? Are you familiar with the distance the longitudinal bulkheads are in the Mauretania from the outer skin?
- In the Lusitania I was familiar.

Q. In the Mauretania?
- I never saw the Mauretania; I was never on board of her.

Q. Do you know whether she is constructed precisely like the Lusitania?
- I believe not precisely; though generally.

Q. Do you know as to the dimensions that we are speaking of now?
- I couldn't say from examination. I have never been on board of the Mauretania.

Q. Do you know the distances of the longitudinal bulkheads in the Lusitania from the outer skin?
- My memory is 13 to 15 feet.

Q. But in some places it is less, is it not, forward?
- It probably gets narrower where the ship's side comes in forward.

Q. Do you know anything about the watertight decks of the Mauretania and the Lusitania, and where they are placed and the extent of them?
- Only generally.

Q. Do you know whether they have watertight decks in the forepeak?
- There is, I am sure, one at the top of the forepeak.

Q. Do you know whether they have one in No. 1 hold?
- Yes.

Q. Do you know the height of that above the waterline?
- About at the waterline.

Q. Well, about means what?
- About at the waterline.

Q. Is that above?
- It depends on the loading of the ship. I mean it is close to the waterline. It is not at the top of the watertight bulkheads.

Q. No, but it is above the load waterline, is it not?
- I believe just below the load waterline.

Q. But you are not sure?
- I am not sure. You have plans, I believe.

Q. In No. 2 hold do you know where the watertight deck is located?
- A little lower than in No. 1.

Q. In the coal bunkers, just aft of No. 2 hold of the Mauretania and Lusitania, do you know where the watertight deck is placed?
- In No. 3 hold –

Q. You think I am referring to No. 3 hold?
- I understood you to finish your question to the extent of saying in the watertight No. 2 hold, and I was saying that the bunker was aft No. 3 hold, not at No. 2.

Q. Then what you speak of as No. 3 hold, do you know where the watertight decks are in the Mauretania and Lusitania?
- There is no watertight deck in No. 3 hold.

Q. To your knowledge?
- There is one hold forward of the machinery space in which there is no watertight deck; that I am certain about.

Q. But you don't know which one that is?
- I believe that is No. 3; the one immediately forward of the boilers.

Q. What you mean by there being no watertight deck is that that loading hatch on the open deck is not made watertight?
- Only weather tight.

Q. But is it not a fact that it is trunked in?
- Lightly trunked in, but the trunk is not stiffened for watertight decks.

Q. But it is trunked here to the open deck?
- Yes, up to the weather deck.

Q. Do you know where the longitudinal bulkhead is placed in the No. 3 hold, as you call it, or the spare bunkers, as I call it?
- I am not familiar enough with the ship to say whether there is a longitudinal bulkhead there or not.

Q. Did you ever have the dimensions of the Mauretania before you, giving the cubic contents of the different compartments of the Mauretania?
- No.

Q. Or of the Lusitania?
- No.

Q. Do you know the distance the longitudinal bulkhead in No. 1 boiler room is from the skin of the ship, of the Mauretania or Lusitania?
- No.

Q. Do you know the height of the coal compartment there?
- No.

Q. Did you ever know it?
- No.

Q. That is true of each one of the coal bunkers of the Mauretania and Lusitania?
- The Mauretania I know very little about; the Lusitania a little more, but not details.

Q. You didn't ever know the cubic contents of the coal bunkers of these ships, precisely?
- No; I have been told them, but I don't remember.

Q. Were you given the figures in detail as to each bunker?
- I was never informed.

Q. Do you know the height of that watertight deck over the coal bunkers of the Mauretania or Lusitania?
- I know it was at the top of the bunkers; I don't know its level vertical feet and inches.

Q. I think you testified in the Lord Mersey investigation that, if the Titanic had struck head on, she would be afloat today, in your opinion?
- I did.

Q. That is your opinion still, is it?
- Absolutely.

Q. You testified then that she would have crumpled up like an accordion for about a hundred feet?
- 80 to a hundred, I think I said.

Q. As to the expense of maintaining watertight decks in cargo ships, that depends upon circumstances, does it not?
- yes.

Q. If the cargo is heavy, there may be damage to the rubber packing, and if it is light, there will not?
- Quite right.

Q. And if they are very careful in loading or unloading they may not have any expense for two or three months?
- Quite right.

Q. And the expense of maintaining the deck watertight merely is the expense of the packing to keep the hatch covers watertight?
- Provided the conditions are such that the deck itself remains watertight, yes.

Q. When you say that, you mean provided the rivets do not start so as to make a seam come loose?
- With the working of the ship in a seaway, and so on.

Q. The working of the ship in a seaway would have an effect to make the transverse bulkheads open a seam?
- No.

Q. That is impossible, you think?
- Not the same type of working; the principal stresses in a ship in a seaway are longitudinal and are felt by materials running longitudinally.

Q. Is it not true that in the panting of a ship the stresses are transverse the ship?
- Yes.

Q. Isn't that the main stress felt by a large ship in a seaway?
- No; a very minor stress.

Q. Which particular longitudinal parts of the ship are they that feel the greater stress?
- The keel, the bridge deck sheer strake and the bridge deck stringer.

Q. And the stress fore and aft on a deck is never sufficient, to your knowledge, to sheer off the rivets and the plates and so on, if the ship is properly constructed?
- I have seen a ship classed by Lloyds, and therefore presumably properly constructed, with the deck rivets sheered off.

Q. Now, please answer the question. If the ship is properly constructed, the stress is not great enough to sheer the rivets, ordinarily, is it?
- The assumption is that a ship -- you must define what you mean by a ship properly constructed.

Q. I mean a ship that you would call properly constructed.
- It happens to be a ship that we built and that Lloyds approved.

Q. Did you consider it properly constructed?
- We did.

Q. Is that a usual thing with all the ships that you construct?
- No.

Q. It is an unusual thing, is it not?
- It is.

Q. And the only instance you know of is the one that you referred to in answer to my question?
- The ships built by us, yes.

Q. As to lifeboats furnished on ships that you build, who fixed the number to be furnished on the Amerika,which you built for the Hamburg-American line?
- The Seeberufsgen-ossenschaft, usually referred to for convenience S. B. G.

Q. The S. B. G. merely establishes rules like the British Board of Trade; is that not the fact?
- Something of the same sort.

Q. And that constitutes the German law as to the minimum requirement in lifeboat, equipment for a German ship; that is true, is it not?
- I am not quite sure it is the standard of equipment for the German ships, but whether it is the German law or not I am not sure.

Q. But, as a matter of actual fact, for the Amerika you furnished the minimum requirement? You have so testified?
- I don't know.

Q. But if you did, who then is it who fixes the number to be furnished?
- I couldn't say.

Q. Isn't it a fact that the owner specified the number?
- I really don't know.

Q. Do you mean you don't remember?
- I don't remember. The Amerika is now nine years old.

Q. Do you remember as to the President Lincoln and the President Grant?

Objected to as immaterial.

- I remember the ships. I don't know whether I can answer any question about that.

Q. Do you remember as to the boating of those two boats, who specified the number?
- I don't know.

Q. Did you build the Amerika and these other two vessels for the Hamburg-American line on the contract plan, similar to the one that you build ships for the White Star: Line on?
- I an not familiar with the terms on which they were built. I was not then in charge of the designing department.

Q. Were you present at the meetings with the White Star Line officials when the number of lifeboats to be furnished for the Titanic was discussed?
- No.

Q. Will you tell us what the telephone arrangement was from the crow's-nest to the bridge on the Titanic?
- Graham's loud speaking navy telephone.

Q. In that telephone what is necessary to make the signal first to the bridge and then does the officer attend at tie telephone before communication is established?
- You ring the bell to draw the attention of the people you wish to call; you press a button to ring the bell to draw the attention of the people you wish to call.

Q. Where is the instrument on the bridge located?
- I think in the wheelhouse.

Q. Are you sure?
- Not quite, but it usually is and I believe it is in that case. I am not sure, though.

Q. As to bulkhead doors in the longitudinal subdivisions which form the sides of the coal bunkers through which coal is to be trimmed, those bulkhead doors will close right through the coal, will they not?
- They may have to, when the bunkers are full.

Q. As a matter of fact, you have seen them closed right through the coal, have you not?
- No.

Q. Never?
- No.

Q. In the Navy?
- No; they don't build the watertight doors in that way; they screen them.

Q. You have never seen a watertight bulkhead closed through coal then?
- I have not, and I have seen it fail to close when there was a piece of wood in the way.

Q. But you testified before Lord Mersey's Commission that your bulkhead doors would close through a piece of wood, chop it right off?
- I did.

Q. There is a tremendous cutting force?
- They are much heavier doors, the doors are particularly heavy.

Q. Heavier than what?
- Than doors that are fitted on coal bunkers.

Q. Are they heavier than the doors on the Mauretania and Lusitania?
- I believe about five times the weight.

Q. But you don't know?
- We didn't make the doors; I haven't positive knowledge.

Q. And you don't know how the Mauretania doors are closed, do you?
- Yes.

Q. How?
- Partly by hand and partly by the Stone-Lloyd system.

Q. They are closed by hydraulic power, are they not?
- About half of them.

Q. But all of them at the coal bunkers are closed by hydraulic power, are they not?
- No, less than half.

Q. That is your information?
- In the Lusitania, because I have seen them; but I haven't seen the Mauretania.

Q. But there is no difficulty in arranging it so that they can close, notwithstanding they form the doors through which the coal is trimmed.
- Difficulty in insuring that they will close, yes.

Q. I wasn't talking about insuring. The difficulty in arranging it so that they can be closed is what, if any?
- The difficulty in arranging that they shall be closed is simply the resistance of the coal made so great that it cannot be forced through them; that the door cannot be forced through the coal.

Q. That is the only difficulty?
- The only difficulty, provided the door is properly kept. </p>

Q. On the Titanic, after the watertight bulkhead doors were closed from the bridge, could they be opened locally?
- Yes, if permission is given by the bridge.

Q. I am speaking as to the mechanical arrangement.
- I say if permission is given by the bridge.

Q. What do you mean by that?
- The switch on the bridge has to be reversed. I put it that the closing of the doors on the bridge is effected by closing the switch. Before those doors can be opened locally the switch has to be brought back.

Q. Why?
- Because the closing of the switch on the captain's bridge takes out the clutch through which the doors are operated, locally.

Q. I understood they were worked by a Worm?
- So they are.

Q. But isn't there any other connection with that worm than the electric clutch?
- The worm which operates the doors is not workable locally.

Q. Is it workable above the deck?
- From the top of the watertight bulkhead, yes.

Q. Then it can be opened from that point after it has been closed at the bridge, without permission from the bridge?
- Only by the order of an officer from the bridge, who has the key.

Q. I am speaking physically rather than as to the human details of the thing.
- Physically, yes, it being a Board of Trade requirement that it should be so.

Q. Now in your answers of yesterday you stated that you had at one time figured out that the Mauretania would have sunk in a certain number of minutes if she had sustained the same injury as the Titanic. What was the number of minutes?
- Pardon one, I think the question was slightly different. It was if the Titanic was constructed in the same general manner as the Mauretania, would she have sunk. That is my memory of the question.

Q. That was the quest ion you thought you were answering?
- That was the question I thought I was answering.

Q. You said you figured it out once. What did that figuring consist of?
- An estimate of what flooding would have taken place in consequence of the damage.

Q. Did you have in mind placing the longitudinal subdivisions of the ship precisely the same relative positions as they are in the Mauretania and Lusitania?
- As nearly as you can in a different type of ship.

Q. So there was considerable difference in your figuring?
- There were differences.

Q. And you didn't know at the time you did this figuring exactly the dimensions of the bunker space in the Mauretania, did you?
- Not exactly; only generally.

Q. And you didn't know the location of the watertight decks, did you?
- Yes, generally.

Q. Well, generally is not enlightening.
- Sufficiently in general to enable me to make a drawing with a similar arrangement. It cannot be the same in feet and inches, so that it didn't worry me that I didn't know the feet and inches scale.

Q. Have you the drawing?
- No.

Q. What did you do with it?
- I don't know.

Q. When did you make it?
- It was made in 1912.

Q. How long a time did you spend in figuring out the matter?
- My assistants were at it for two or three days.

Q. Do you know now the distance that you then placed the longitudinal watertight bulkheads from the outer skin of the ship, as you reconstructed it for that purpose?
- I couldn't say; I only remember the general result.

Q. The general result was that she would, as laid down by you in the drawing, list to such an extent that she would ship water over the top of the bulkheads; but that was also assuming the deadlights of the cabins open, was it not?
- It was, which we had proof were open at the time.

Q. It didn't involve the assumption they might have been closed before the listing had proceeded to that extent?
- They were proved to be open as the ship was going down.

Mr. Kinnicutt:
Objected to on the ground that the witness has no personal knowledge of what happened at that time and I move to strike out the answer.

Decision reserved.

Q. (repeated) It didn't involve the assumption that they might have been closed before the listing had proceeded to that extent?
- No; it involved the assumption that they were open.

Q. I did not assume that there was a watertight deck in good working condition in immediately above the head of the bulkhead, or transverse longitudinal bulkhead, did it?
- It assumed a watertight deck at the same general position as that in the Lusitania.

Q. Was that watertight deck about the level of the water?
- Somewhere about that; it was years ago and I didn't do much about it myself and I am not very clear about it.

Q. And it did not assume that any effort would be made to trim the ship against that listing, did it?
- No.

Q. What compartments did it assume were flooded?
- It assumed damage back to No. 4 boiler room, to the position in No. 4 boiler room.

Q. In which compartment did you assume that the water entered then?
- Back to the position of No. 4 boiler room, such as, in the arrangement then drawn out, it could gain access to.

Q. In every one of them?
- Such as it could gain access to, yes.