Limitation of Liability Hearings

DEPOSITION OF ADMIRAL DAVID W. TAYLOR - Contd.

Q. As a matter of fact, deeper draft aft would, or should be, taken into account in determining the heights of bulkheads, should it not?
- Not at all. It has no material effect upon it. You might take the keel and cut off two feet from the bottom, and the top of the bulkhead would not know the difference. The question, or rather, the matter of the change of trim resulting from damage aft would not be materially affected by the draft aft. The change of trim would depend upon the size of the compartment flooded.

Q. But if the ship were on an even keel it would be possible to have the aft bulkheads the same height as the forward ones, would it not?
- I do not understand the question.

Q. Let me add to it: if the ship were on an even keel and the aft bulkheads were the same height as the forward ones, the tops of the aft bulkheads would be the same distance above the waterline as the tops of the forward bulkheads, speaking generally, not with respect to any particular bulkhead, would they not? I mean the ship floating on an even keel -- any ship -- the Titanic?
- I think that if the Titanic were on an even keel and the bulkheads built as they are, the tops of the bulkheads aft would be even higher than they are, above the waterline -- presumably she trims a little by the stern.

Q. And by reason of the fact that she did trim by the stern, it would be necessary to make the aft bulkheads rather higher, to have them a proper distance, a safe distance, above the waterline?
- No; higher above the keel perhaps, but not higher above the waterline. The question of safety depends upon the height above the waterline in the ordinary trim of the ship, not upon the height above the keel.

Q. But if the ship trims by the stern is it not naturally necessary to have the aft bulkheads rise higher than the forward ones?
- Not higher above the waterline.

Q. But to bring them to a safe distance above the waterline it is necessary to have them higher above the keel, if the ship trims by the stern?
- If the ship trims by the stern, in order to have them higher above the waterline, it would be necessary to have them higher above the keel, depending upon the amount of trim by the stern. As a matter of fact I have no reason to believe the trim by the stern of the Titanic was a material factor in the case, as it can not have been more than two or three feet.

Q. If the designer of the Titanic so testified, however, would you contradict his testimony on that point, that is, that by reason of her trimming deeper by the stern, the aft bulkheads were made higher from the keel, in order that there would be a proper margin of safety with any two adjacent compartments flooded?
- If the designer of the Titanic testified that the vessel trimmed two deck-heights by the stern -- which I take to be sixteen or eighteen feet -- I would say that he would be justified then in raising the bulkheads aft a deck higher; but from my knowledge of the sister ship I can testify that the vessel did not trim at anything like a deck-height by the stern.

Mr. Brougham:
Do you mean the Olympic?

The Witness:
Yes.

Q. Now Admiral, are you familiar generally with the requirements of Lloyd's rules for scantlings of vessels?
- I cannot say that I am now; I have gone into them more or less in the past.

Q. What would you say of a vessel that was built with scantlings equal or in excess of Lloyds' requirements, as to strength? Would you regard her as a properly strong, seaworthy vessel?

Mr. Brougham:
I object, on the ground that the question calls for a conclusion of the witness which would necessarily be based on a legal knowledge of the meaning of the word "seaworthy" in this case, which the witness is not shown to have.

Mr. Wells:
Admiral, we have no desire to lead you into any legal trap. My inquiry was directed solely to the question of her seaworthiness in respect to strength of construction and scantlings.

- As regards strength of construction and scantlings, I should regard a vessel built in accordance with the highest requirements of Lloyds' Register as adequate.

Q. Have you any special reason for saying "the highest requirements"?
- Lloyds' classes vessels under several classes.

Q. Are you of the opinion that Lloyds' accept a vessel for classification that is not adequately built?

Mr. Brougham:
I object, on the ground that the witness is not shown to be competent to express such an opinion.

- I am not sufficiently familiar with all of Lloyds' requirements to express an opinion. Lloyds' requirements are not all shown in their rules. The majority of important vessels classed by them, I believe, are classed after special investigation.

Q. Admiral, have you examined the plans of the Titanic sufficiently to express an opinion as to whether she was strongly built?
- I do not recall seeing any structural plans of the Titanic . The plans I have examined are plans of general arrangements; Claimants' Exhibit C gives no scantlings so far as I am aware.

Q. It has been testified that the Titanic 's bulkhead plating was ten to twenty percent heavier, and the stiffeners on the bulkheads seventy-five to one hundred percent in excess of Lloyds' rules. What would that indicate to you with respect to the strength of the vessel?

Mr. Brougham:
I object, as incompetent.

- It is impracticable to form any reliable opinion on that matter, in the absence of a careful examination of the detailed plans of construction, because the efficiency of the bulkheads depends very largely upon the distribution of the weight, as well as the weight itself.

Q. Then from your knowledge of the Titanic you do not assume to testify at all as to her strength of construction with respect to her strength of hull, in its various parts?
- Practically the only knowledge I have of the hull of the Titanic is what I have teen told here today as regards her scantlings, and that of course is inadequate to warrant my expressing any opinion as to her general structural strength. The question of her structural strength has to be considered in connection with the distribution of weights in the vessel, concerning which I have no information at all.

Q. Will you express an opinion as to why the Lusitania is not now afloat?
- I have not sufficient information as to the Lusitania to warrant my expressing an opinion as to why she sank. I do not even know whether she was struck by one, or two, torpedoes.

Q. At all events, her longitudinal bulkheads and watertight flats were not sufficient for the injury that she sustained?
- I think there is no doubt that she sank.

Q. Admiral, have you designed any ocean-going passenger vessels?
- No.

Q. You are more familiar with the designing and building of war ships, are you not?
- Yes.

Q. In fact, your experience, aside from the experience you gained while undergoing your course in naval architecture, is almost entirely with war vessels, is it not?
- Vessels of the Navy; those are not entirely war vessels.

Q. That includes auxiliary vessels, I suppose you mean?
- Yes.

Q. Such as colliers?
- Colliers, supply ships -- we are building a transport ship now, to carry two thousand souls, nearly.

Q. Are these colliers built with longitudinal bulkheads and watertight flats?
- Not as a rule.

Q. Was this transport designed subsequent to the sinking of the Titanic ?
- She was.

Q. Did you design her?
- No. I had some connection with the designing; I designed her lines, and was consulted as to other features of the design.

Mr. Brougham:
Will you ask him if she had longitudinal bulkheads?

Mr. Wells:
No; I brought out the fact that she was designed since the Titanic disaster.

Q. In the case of the grounding or stranding of vessels, do you know of any cases where the damage included the destruction of the continuity of transverse bulkheads?
- No; I do not recall; not in the case of any war vessels.

Q. And you have not examined any cases of merchant vessels that were damaged in that way, have you?
- No.

Q. You have stated, have you not, that it was practically certain that the captain of the Titanic did not think he was running any material risk of accident to his vessel, much less risk of destruction, on the occasion of her voyage when she met with the accident, have you not?

Mr. Brougham:
I object, on the ground that whatever complimentary remarks the witness may have made concerning the deceased Captain Smith, they are entirely immaterial to this case.

- I have expressed that opinion.

Q. You also expressed some opinion with regard to the usefulness of lifeboats, have you not?
- I have expressed a good many opinions in regard to lifeboats.

Q. Did you not say this: "The facts that under the circumstances more boats would have saved many more lives from the Titanic, and that she could have carried about three times as many boats as she had, should not blind our eyes to the fact that lifeboats are, after all, a very inefficient device for saving life from a sinking vessel." Did you make that statement?
- I believe I am correctly quoted.

Q. And further: "Lifeboats, no matter how much improved, will probably always be inefficient as life saving appliances for the mammoth steamers of today." Is that correct?
- That is correct. I have so stated, and it has since been confirmed by experience.

Q. In fact, later accidents confirm your views as to that?
- Yes.

Q. You were of the opinion that the Titanic had an enormous reserve buoyancy, were you not?
- As long as she was intact, undamaged.

Q. And it was further your opinion that the rudder area of the Titanic was greater than smaller vessels usually had, was it not?
- Somewhat greater than the ordinary merchant vessel.

REDIRECT EXAMINATION BY MR. KINNICUTT:

Q. Did you write an article which was published in "Popular Mechanics" in June, 1912, with reference to the Titanic disaster, from which Mr. Wells has quoted, and of which this is a copy, on pp. 797, 798, 799; 802, 803, 804, 806, 807, 808, omitting three pages which are merely illustrations? (Handing the witness an article, hereto attached and marked Claimants' Exhibit A.)
- Yes, I wrote the article and supplied most of the illustrations. The three omitted pages were illustrations not supplied by me. I supplied only the illustrations on pages 798, 804, 806, and 807.

Q. Did you at that time make a calculation as to the effect of flooding all the compartments in the Titanic up to but not including the first boiler room?
- I made an approximate calculation, based upon information available to me at that time.

Q. What was the result of your calculation, assuming the forepeak and the next three compartments were flooded, as to the effect on the flotation of the vessel?
- The result is indicated in the waterlines of the diagram on pp. 806, 807 ( pointing to the illustration in Exhibit A ). Assuming that the ship was originally at the waterline shown in Fig. 2 on page 804 -- 34 foot draft -- and that all buoyancy forward of the forward boiler compartment was lost, the new line of flotation which the ship would assume would be approximately A-B in Fig. 2. The waterline A-B in Fig. 2 passes just about the top of the bulkhead between the forward boiler room and the next boiler room aft. I would state that I have made clear in the article that these calculations were rough approximations, and I would not put them forward as comparing in accuracy with the calculations made by the designer, who presumably had exact information. I will say that they were pretty close, though; the principal difference, I believe, is that I assumed the draft to be 34 feet, uniformly, and that the designer's calculations were based upon 30 feet forward and 32 feet aft.

Q. Are the following words in your article, on p. 802, a correct quotation: "This is a minimum requirement and its obvious reason is that a colliding vessel may strike just at a bulkhead and throw open two compartments to the sea"?
- That is a correct quotation.

Q. And you still believe in the truth of that statement?
- I do.

Q. If the evidence in this case shows that the damage to the skin of the vessel, to the shell of the Titanic, extended no further aft than the coal bunker immediately aft of watertight bulkhead E, and did not extend as far forward as the forepeak, will you make a measurement on the plan marked No. 14, in the right hand corner, and state what was the maximum length in the hull of the vessel over which the damage extended? ( Offering plan for measurement )
- Measuring with a rough scale, the distance from bulkhead A to the aft bulkhead of the coal bunker immediately aft of bulkhead E, is a little over 210 feet.

Q. Can you tell me approximately what the half-way distance is between the foremast and the stem?
- The distance from the foremast to the stem is apparently between 105 and 110 feet, making half the distance some 53 to 55 feet.

Q. This point to which you refer would come where, with reference to bulkhead A at the height of the upper deck?
- That would come, roughly, 8 or 10 feet abaft of bulkhead A.

Q. Admiral, will you say that an injury to the hull of a vessel about 850 feet long, going at 22 knots an hour, which would extend over a distance of approximately 210 feet as the outermost limits, and consisting of a number of punctures in the hull the total area of which would aggregate 12 square feet, would be a kind of accident that would be reasonably to be anticipated, assuming that the course of the vessel lay in the North Atlantic, in the iceberg region, and at a time when icebergs were all about, taking into consideration, also, the other possible circumstances under which such damage could be incurred, such as derelicts, and collision with other ships?
- I should say that the injury described is such as could be reasonably anticipated to result from collision with an iceberg, floating ice or a large derelict. It would also be possible from a scraping collision with another vessel.

BY MR. WELLS:

Q. If this damage was on the bottom of the ship, it would hardly be collision with another vessel. Would a collision damage the bottom of a vessel?
- A collision with another vessel would primarily damage her above the turn of the bilge. If it were a derelict I can readily imagine how there could be a great deal of damage to the bottom; she would be liable to ride over the derelict.

BY MR. BROUGHAM.

Q. You were asked by Mr. Wells about the possibility of building an unsinkable vessel, and you stated it could be done, if we were willing to pay enough money. Now I ask --
- I think I stated, against any dangers we know of now.

Q. Now Admiral, eliminating the dangers of naval warfare, torpedoes and submarines, and coming down to ordinary dangers of navigation that are reasonably to be anticipated, what is your belief as to the practicability of building a commercial vessel unsinkable as against perils of navigation reasonably to be anticipated?
- If I understand your question I would say that such a vessel, particularly if of large size, could be built without excessive increase in cost.

Q. Have you any knowledge as to whether or not the German ships Imperator and Vaterland have already been constructed in such a manner as to be unsinkable, as against perils reasonably to be anticipated?
- I am not acquainted with the construction of these vessels.

Q. Would the increased expense of making the Titanic so that she would have been unsinkable, against perils reasonably to have been anticipated, have been very great, in your opinion?
- In my opinion an increase of ten percent over the expense of construction of the ship would have provided sufficient additional subdivisions warrant her being called in justice an unsinkable ship.

Q. Now when you say ten percent over the expense of construction of the vessel, you do not include the expense of the luxuries that were provided, in the nature of furnishings, in suites deluxe, etc., do you?
- That ten percent is obviously a very rough estimate, made on the spur of the moment. In naming it I had in mind the total cost of the vessel.

RECROSS EXAMINATION BY MR. WELLS:

Q. Considering the area which would be open to the sea to have been 12 square feet, and that the length of the damage was 210 feet, what would be the average width of the opening?
- About 5/7ths of an inch, assuming it to be continuous.

Q. In other words, a very narrow cut?
- If it were of that nature, yes.

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David W. Taylor (sig.)