Limitation of Liability Hearings


Q. What would you say as to whether such provision was, from the point of view of safety, sufficient in a vessel of great size such as I have described?
- Considering safety primarily, I should regard provision against flooding two compartments only as being inadequate for safety.

Q. In the case of damage to the side of a vessel such as I have described, that is to say, over 800 feet long and divided into sixteen or more compartments, where there is damage beneath the waterline to a number of compartments, is the height of the transverse watertight bulkheads a material factor with reference to keeping the vessel afloat?
- Yes, particularly if they are not topped by a watertight deck.

Q. I show you a plan which has been introduced in this case as Claimants' Exhibit C, May 13, 1915; and I point out to you the height to which the various watertight bulkheads are shown to extend throughout the length of that vessel, excepting the first two bulkheads forward; and I state to you further that the third watertight bulkhead, which I will mark C, extends to a height of 16' 5' above the 34' 7" waterline; and the fourth bulkhead from the bow, which I will mark D, extends 15' 5" above the said waterline; and the fifth bulkhead, which I mark E, extends to 14' 5" above the said waterline; and the sixth bulkhead, which I mark F, extends to 12' 5" above the waterline; and the seventh, marked G, which extends to the height of 11' 5" above the waterline; and the eighth, which I mark H, which extends to the height of 11' 5" above the waterline; and the ninth, which I mark J, which extends to 10' 5" above the waterline; and the tenth, which I mark K, which extends to the height of 19' above the waterline; and to the next five bulkheads aft, which all extend to the same deck, namely, Deck D, as bulkhead K; and I ask you what you would say, in your opinion, as to whether these various bulkheads for a ship of this size and general description, carrying passengers, are sufficient in height, from the point of view of safety, assuming that the length of the vessel is 852' 5", and that the tonnage of the vessel is 46,328 tons, gross?
- I would not undertake to say, as to the sufficiency of these bulkheads, from the point of view of safety, without knowledge as to the amount of safety required; or, in other words, the amount of damage to be provided against. It is possible with full information as to the plans of the vessel (which I have not) to determine with sufficient accuracy the amount of damage which given bulkheads, extending to a given height, would provide against.

Q. Assuming that injuries which would damage the side of the vessel in five compartments, are the injuries which are to be guarded against, would you say that these bulkheads were of a sufficient height?
- Not to provide against injuries to five compartments below water. Against such injuries I consider the height of the bulkheads would be insufficient for safety.

Q. I show you the plan marked Petitioner's Exhibit 6, which has been described as the Flooding by Compartments Plan of the Steamship Titanic, and I ask you, assuming that this plan is correct, and assuming that the forepeak and the next four compartments aft were flooded, and that the damage to the hull of the vessel in the next compartment aft, namely, boiler room 5, was such as could be controlled by the pumps, whether the bulkheads were of sufficient height to prevent the sinking of the vessel?
- The plan shows that with the damage described, and the flooding at the waterline resulting, the water would have passed over the bulkheads between No. 5 and No. 6 boiler rooms, and the vessel would have sunk.

Q. Assuming likewise that this plan is correct, does it appear that if the bulkhead between boiler room 6 and boiler room 5 had been carried up one deck higher, that the ship would have floated in spite of the fact that the forepeak and the next four compartments aft were flooded?
- The plan shows that if the bulkhead between No. 5 and 6 boiler rooms had been carried one deck higher the water would have risen only a little over half way between E deck and D deck, the new top of the bulkhead being at D deck.

Q. Do you consider that with the state of the shipbuilding art with reference to large passenger ships being such as it was in the years 1909-1912, that a construction which would enable a ship of this general type and size, to float with not more than any two adjacent compartments flooded, was a minimum requirement at that time?
- I should say that from the point of view of safety such a construction was a minimum requirement at any time.

Q. Do you think that in order to guard against a ship of this type and size foundering in case of any kind of an accident such as could be reasonably anticipated on the North Atlantic Ocean, the height of the watertight transverse bulkheads in the forward part of the ship should, or should not have been higher than the bulkheads I have shown you in the plan in question, Claimants' Exhibit C, May 13, 1915?
- An answer to that would depend entirely upon the question of the amount of damage that could be reasonably anticipated. It is apparent from the diagram Petitioner's Exhibit 6 that damage admitting water to the five forward compartments would not be provided against by the bulkheads in question. Such damage is certainly possible. The question of what was to be reasonably anticipated is a question involving the dangers of navigation and other matters concerning which I would not undertake to give a positive opinion.

Q. Are you inclined to think that if you had been charged with the designing of such a vessel, that is to say, of the type and size in question, in the year about 1909, that you would have, as a naval constructor, limited the height of the third, fourth, fifth and sixth bulkheads to the heights which I have stated?
- Speaking for myself individually, I should not, for the reason that this extent of bulkheads is materially less than we would provide in naval practice, with which I am most familiar.

Q. I call your attention to the fact that up to and including the ninth watertight bulkhead aft, namely, bulkhead J, all the bulkheads, with the possible exception of the first two, extend only to what is designated as the "Upper deck" of the Steamship Titanic, and that all the bulkheads aft of bulkhead J extend to deck D. What is your opinion as to whether it was advisable to have the forward bulkheads lower than the aft bulkheads, or whether there was any occasion therefor, that you can observe?
- So far as I can judge from the spacing of the bulkheads the forward bulkheads are materially less safe than the aft bulkheads, because the latter extend one deck-height higher, and as a matter of fact I regard it very advisable, from the point of view of safety, to have the forward bulkheads higher than the aft bulkheads.

Q. Is there any reason suggested to you from an examination of this plan, why in fact these forward bulkheads were not carried up a deck higher?
- The only reason which has occurred to me, from an examination of the plan, is that if the forward bulkheads had been carried up a deck higher they would have somewhat interfered with the comfort of the first class passengers.

Q. In what particular?
- From the fact that it is more or less of an annoyance to get through the doors in watertight bulkheads, if doors are fitted, or to go up and come down again, in case doors are not fitted, and you wish to pass forward or aft on the deck.

Q. When there are doors fitted on such decks the only difficulty is stepping over the sills, is it not?
- That would be the main difficulty, The doors are necessarily narrower than the usual passage and the difficulty in passing people going in the opposite direction is greater.

Q. Have you had occasion in the past to examine the plan of the boat deck of the steamship Titanic ?
- I have, the plan as published in the technical press at about the time of her construction.

Q. I show you a plan which has been already introduced in evidence in this case, which is marked in the left hand corner "SS. Titanic " and the words underneath, "Scale 1/32 to the foot" and marked "No. 14" in the upper right hand corner; and ask you whether it shows, or purports to show, the boat deck of the Titanic ?
- That is right.

Q. From an examination of that plan, will you state whether or not it shows room for the carrying of more boats than actually were carried, as shown on the plan?
- The plan indicates room for the carrying of a number of boats more than shown on it.

Q. Can you state an approximate estimate of how many more boats could have been carried between the two groups of boats, assuming one boat to a set of davits?
- Apparently there is room for the installation of five more sets of davits on each side between the forward and aft groups of boats.

Q. Do you consider that with a ship of the type of the Titanic as shown in the large plan already referred to, that the carrying of a larger number of boats than is shown on this plan would have been an additional safeguard in case of foundering? A Not an additional safeguard against foundering; it would have been an additional safeguard for the life of the passengers.

Q. In April, 1912, was or was not gross tonnage of a ship of this type, shown in this plan to which I have referred, approximately the same under the English and under the American law?
- Yes, the gross tonnage under both English and American laws was intended to mean the internal cubic contents of the vessel, and the differences, if any, are minor in the prescriptions of the laws of the two countries.

Mr. Wells:
I suggest that whatever the law is on the subject is better shown by the law itself than by the testimony of the witness.

Q. This last answer that you have made would include the year 1912, would it not?
- Yes.

Q. If the gross tonnage of the steamship Titanic was under the English law 46,328 tons, gross, had she been an American vessel would the gross tonnage, in American tonnage, have been approximately the same?
- Very approximately, yes.

Q. Have you ever examined the midship section plan of the Titanic, or any plan sufficiently to know in a general way how the double bottom was constructed, and how the hull of the vessel was constructed above the. double bottom?
- Yes, in a general way; not as to the details of the scantlings.

Q. Would there have been, in your opinion, any practical difficulty in carrying the inner side of the double bottom higher up on the sides of the ship, so as to form an inner skin?
- No.

Q. Would such construction have afforded additional protection as against foundering in the case of lateral injuries to the hull below the waterline?
- Yes.

Q. Can you see any serious objection to the use of such construction in a vessel of this type?
- No, I would regard it as desirable.

Q. Would you regard the use of a watertight deck at a point above the waterline about one-fourth the draft of a ship, in a ship of the Titanic type, as desirable for the same purpose?
- Yes.

Q. Do you think there are any serious practical objections to the use of such watertight deck in such a ship?
- Not that I know of -- no serious objections.

Q. How does the principle of the inner skin differ, if at all, from the principle of the longitudinal bulkhead?
- In each case there is an additional skin of metal; in one case it is more or less intimately bound to and associated with the outer skin by means of the framing of the double bottom. In the case of the longitudinal bulkhead, this stands apart and is not connected with the outer skin except at the bottom. As a rule the inner skin follows nearly parallel the outer skin and is a comparatively short distance from it, say three to five feet. The longitudinal bulkhead is usually vertical and would be a greater distance from the outer skin, on the average.

Q. With an increase in the length of a ship, does the proper height of the transverse watertight bulkheads increase accordingly?
- Yes, for this reason: if you take a long ship and a short ship, divided similarly into the same number of compartments, and bilge one compartment, both ships will change trim to the same angle, and if the long ship is, say, twice the length of the short ship, the water will rise in it to twice the height, indicating that the bulkheads in the long ship should extend to twice the height above the undamaged waterline for the same relative safety.

Q. Then what would be safe watertight transverse bulkheads in a small ship would not be safe transverse bulkheads in a large ship?
- Not as regards height above the waterline.

Q. Assuming that in a large passenger ship the transverse watertight bulkheads were the minimum height for safety, would it not necessarily follow that a ship, we will say, 100 to 150 feet longer, should have higher transverse watertight bulkheads?
- Yes, unless its safety were to fall below the minimum prescribed for the shorter ship.

Q. With a ship of the approximate size and weight of the Titanic, state what your opinion is as to what extent outer plating one inch thick is a protection against damage to the hull?
- All. I can say to that is, that it would offer more protection than three-quarter inch plating, for instance, and less than inch and a quarter plating. A single skin of any thickness practicable for a merchant vessel would almost certainly be pierced by any heavy impact resulting from collision with another vessel or heavy floating object.


Q. One inch plating, Admiral, was of sufficient thickness for a vessel of that kind?
- Presumably as regards structural strength.

Q. If it were double along the turn of the bilge and in the wake of the upper decks, what if any effect would that have on the strength of the ship?
- It would increase it.

Q. You stated that in 1913 you were on a committee to do certain preliminary work in this country in preparation for the International Conference for the Safety of Life at Sea.
- Yes.

Q. Do you know what circumstances brought that conference about?

Mr. Brougham:
Objected to as immaterial.

- I think it was called by the British Government, as the immediate cause of it.

Q. Do you know whether the sinking of the Titanic had anything to do with it?
- I do not know of my own knowledge.

Q. Well what is your opinion, subject to Mr. Brougham's objection?
- My opinion is that it did.

Q. You stated that the means to provide against foundering were subdivision of the hull in various ways. With regard to large merchant vessels, do you know whether there were many that were built with longitudinal bulkheads abreast the engine and fire rooms and with watertight decks forward?
- At the time, so far as my knowledge goes, there were not many.

Q. You have in mind, I suppose, several ships that were in existence, about that time, with longitudinal bulkheads outboard of the engine and fire rooms?
- I have, the Mauretania and the Lusitania particularly.

Q. Tow vessels built for naval purposes had such longitudinal bulkheads before that time, did they not?
- Yes.

Q. And they were the inner boundary of coal bunkers, were they not?
- The inner boundaries of the coal bunkers in some cases in the wake of the boilers, and in other cases the outer boundaries of coal bunkers in the wake of the boiler, as well as inner boundaries. Forward and aft of the boiler spaces the longitudinal bulkheads were the boundaries of various compartments used for various purposes, such as magazines, storerooms, etc.

Q. The subdivision of vessels of war is much more minute than in the case of merchant vessels, is it not?
- Usually, above the inner bottom.

Q. And the disposition of the coal bunkers outboard of the machinery and boiler spaces is for the purpose of protection against shell fire; is not that the case, Admiral?
- Partly. It adds to the protection against shell fire.

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