British Wreck Commissioner's Inquiry


Board of Trade's Administration
Report of Life-Saving Appliances Subcommittee

Sir Walter J. Howell,
Assistant Secretary,
Marine Department,
Board of Trade.

In accordance with the decision of the Merchant Shipping Advisory Committee at their meeting on Friday, the 28th April, we have given careful consideration to the letter of the 4th April 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 upwards; 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 watertight 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 other vessels in the 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. Min. No. of Additional boats to be readily available for attachment to Davits. Total Min. Cub. Contents of boats req. by Col. 2 and 3.
10,000 and under 12,000
12,000 and under 20,000
20,000 and under 35,000
35,000 and under 45,000
45,000 and upwards

It is further recommended that all passenger vessels of 10,000 tons gross tonnage and upwards 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 watertight 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 watertight 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 watertight bulkheads.

We have also had before us the Board's further letter of the 17th May enquiring 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 of 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 percent of their breadth.


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 ¾ ths of 8,300, namely, 6,225), with, however, this qualification that if the vessel were divided into efficient watertight compartments (as she probably was) and fitted with wireless telegraphy (as she certainly was) a provision of 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 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 etter 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 the 16th April, 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.,
16th April, 1912.


With reference to your letter of the 4th July last respecting certain question 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 Sub-Committee 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 attachment 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 Committee of equal standing to the Committee which reported in 1891 on the Spacing and Construction of Watertight 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 percent 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 enquiry 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 breath, 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 light of this additional information, may reconsider the opinions expressed on this point in their letter of the 4th July.

I am therefore to transmit herewith copies of memoranda by the Professional Advisor to the Marine Department and 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.,

(Signed) Walter J. Howell.
The Secretary,
Merchant Shipping Advisory Committee,
7, Whitehall Gardens, S. W.