Deposition of EDWARD WILDING, contd.
Q. Do so.
- As to full sized lifeboats they could only handle two; if the lifeboats were of a collapsible character they could handle three or even four.
Q. Is this a true photograph of one of the davits of the Titanic? (Showing photograph to witness.) A. It is a correct photograph of the after end of the boat deck of one of those vessels; whether the Olympic or Titanic, there is not enough on it to identify.
Q. Is that a Welin davit?
- Yes; Welin is a man's name.
Q. And the Titanic was equipped with davits of that character?
- Exactly, of that character.
The photograph is offered in evidence.
It is marked Petitioner's Exhibit 9.
Q. The seventy-ninth interrogatory is as follows:
"State whether at the foremost part of the Titanic's bridge on the uncovered portion on either wing, there was a platform raised from the level of the rest of the bridge and behind a railing or bulwark. If yes, state how high said platform was raised from the floor of the bridge, what was the width thereof and what was the heights of the bulwark or railing above said platform."
Can you answer that interrogatory?
- The first part, there was a platform raised from the level of the rest of the deck behind a railing; or bulwark. The other figures I must give you from memory; they may or may not be right. Broadly speaking the platform was 12 inches from the deck and 15 inches wide. The height of the bulwark above the said platform was, I think, 42 inches. I am speaking from memory. I have not looked at the plan for a good many months.
Q. Does it affect the vision of the man on the bridge?
- No; it was so arranged that -- we took the shortest officer we had there at the time and considered what it was likely to be, and without getting on the platform he could see the stem head.
Q. What is the distance of the bridge from the stem?
- It is about 185 feet.
Q. What is the height of the crow's-nest from the water?
- Again speaking from recollection, 95 feet.
Q. Is that when she is drawing 34 feet 7 inches?
- Well, within a few feet, I mean. She was not far off that.
Q. How long has the Olympic been running?
- Since June, 1911.
Q. She, of course, has not run since October last year.
- No.
Q. That is practically three years?
- Over three years.
Q. You say she was built exactly like the Titanic? A.
- Exactly.
Q. From your experience with the Olympic are you able to say anything as to the result of your making these additional strengthenings for a ship of this enormous size, compared with any previous ship?
- Yes. We have had less repairs to the Olympic than to any large ship we have ever built, due to external causes, of course.
Q. Was any limit put on the builders by the owners in the matter of construction, fitting or equipment of the ship so far as regards her seaworthiness and staunchness?
Mr. Brougham:
Objected to as calling for a conclusion.
The Court:
I will take it.
- No.
Q. You said this morning that you were familiar with shipbuilding the world over. Did that include German and French construction as well as British?
- Yes, generally.
Q. Let me ask you, in the construction of the Titanic, whether anything was omitted by the builders, so far as the construction and strength and safety and seaworthiness is concerned, that was known to the shipbuilding art in 1909 to 1912, as related to great passenger steamers? If so, what?
Mr. Betts:
Objected to as to form, as leading and improper.
The Court:
He may answer.
- Nothing that we judged desirable to put in; it was left to our judgment, and we did our best.
Q. Did you make the trip over from Belfast to Southampton ton in the Titanic?
- I did.
Q. Then did you continue on to Queenstown, or did you remain at Southampton?
- I remained at Southampton, and was on board up to the night before she sailed.
Q. Did Harland & Wolff provide charts for the voyage?
- No; the owner always supplies charts.
Q. Did you see them before she sailed?
- They were brought on board; they were shown to me by the captain, on board, the reason being that before the ship is taken over the owner's representatives have no responsibility for navigation, and the responsibility for what navigation is required for trials is in the hands of myself and the pilot; consequently, I had to have the charts.
Q. Captain Smith was not in command?
- Not until the owners took over the vessel.
Q. There did they take her over?
- After leaving Belfast Lough.
Q. Did you see on board the Titanic a north Atlantic route chart which had on it the region of the ice?
- I did.
Q. When did you see that?
- On the way around from Belfast to Southampton.
Q. Did you attend the Ryan trial in London at the King's Bench?
- I did.
Q. What chart did the Titanic have? Have you a copy of it here, the chart that you saw on board?
- This is the British Admiralty north Atlantic chart? (indicating)
Q. Was there one like this on the Titanic?
- As far as I can judge, this is the same chart.
Q. And it is a chart entitled "North Atlantic Route Chart, showing variation curves for 1907," and it is brought up to what date?
- It is brought up to October -- I think October, 1911, X-11. That is the tenth month of the year; and as far as I recollect, that was the date to which the chart was brought.
Q. This indicates the limit of ice to the southward. "Field ice between March and July." A.
- That is right.
Q. In the neighborhood of 50 degrees west longitude?
- Quite right.
Q. You have brought with you another chart of the Admiralty North Atlantic Route Chart, dated 1912, variation curves for 1912?
- Yes,
Q. To what date is that carried down?
- That is corrected up to November, 1912, XI-12,
And that also has a statement of the plotting of the field ice as follows: "Field ice has been seen within this limit between March and July," This is distinctly lower than the other.
- Between 30 and 40 miles further south.
Q. It also contains a dotted line with the inscription "Icebergs have been seen within this line in April, May June"?
- Yes, sir.
Q. Is that the same on both?
- No, that comes further south in the second chart.
Q. How much further south is it on the 1912?
- About 90 miles further south for icebergs.
Q. In other words, on the later route chart the icebergs are indicated to have been seen about 90 miles further south than on the earlier one?
- Quite right.
Q. Is this the same chart?
- The second chart shows automatically that its corrections have been brought up to a later date. Both charts are on the same scale, and are made from the same plate, re-engraved with the corrections.
The chart is marked Exhibit, 10 of this date.
Q. You came over to testify in this case?
- Yes.
Q. And expected the trial would be the 17th of May?
- That was what I was advised, when I left.
Q. And you expect to return before the 2nd of June?
- I am obliged to do so. My country is at war, and we are doing a lot of Government work.
Q. Have you brought with you certain plans or copies of plans which have been called for in this case, and can you identify them?
- Some which have been made in the drawing office in response to the Judge's order, which was transmitted to us through Burlingham, Montgomery & Beecher.
Mr. Burlingham:
I have produced in response to the request of counsel for claimants, and the direction of his Honor, Judge Learned Hand, certain plans, and have given them to Messrs Hunt Hill. & Betts. If any of the counsel wish to ask this witness any questions about those plans, he is prepared to answer them. That is all.
CROSS EXAMINATION BY MR. BETTS:
Q. Have you examined the set of plans which Mr. Burlingham has given to us, of the Titanic?
- Yes, those were made up; I checked then over in my office and they were sent to our solicitors for transmission to Burlingham, Montgomery & Beecher.
Q. So that you can say those are correct plans?
- I can say those are correct plans, to my knowledge and belief; copies of the plans from which the ship was built.
Q. And the scale is shown?
- The scale is shown on each individual plan.
Q. Will you explain to us what the shell plate plan of the vessel is, how it is made?
- It is partly as expanded; it is not a complete expansion.
Q. Is that a shell plate expansion at all?
- We simply call it shell plating plan.
Q. What is a shell plating plan of the vessel? Describe it?
- It is a plan showing the level of the different strakes, i.e. - the different fore and aft lines of the shell plating with the thickness, and also the butts; it shows any portholes or doors which may be required to be cut, and it shows the thickness of the plating and the way it tapers down, and shows generally all the information that the workmen require to enable them to pick their plates out, and to put them together properly on the ship.
Q. Both of the British Admiralty charts that you have just identified show that icebergs are seen south of latitude 40, north, longitude 50 west?
- Yes, undoubtedly.
Q. So that there is nothing new in icebergs being seen in that latitude and longitude?
- Oh, no.
Q. Only after 1912, you say that the chart shows that they were seen further south?
- Yes; but I an not responsible for what the charts say; I don't draw the charts.
Q. I see that on this plan -- and do you know who made the various red and blue Pencil marks on this plan which is shown as the shell plating plant?
- Yes.
The plan is marked claimants' Exhibit A of this date.
Q. I take it that that shows the location of the various watertight bulkheads in the space covered by the plan?
- It does.
Q. And the key to the red and blue marks is on the plan?
- Yes.
Q. Showing what are the watertight bulkheads?
- Yes; most of the various particulars would not have been embodied on the shell plan, but were put on to try and reduce the number of plans to be furnished.
Q. And the heavy blue lines represent the watertight bulkheads, do they not?
- That is right.
Q. Do the bulkheads also correctly appear on the smaller plan, the lithographed plan?
- I haven't checked the lithographed plan, but assume the lithographer to be correct; it was made from a correct l/32" scale plan.
Q. I wanted to call your attention to the first bulkhead in the ship, the plan marked Exhibit 4; that is A?
- Yes.
Q. Does that terminate at the E deck?
- No (indicating in red pencil on Exhibit 4 a spot which is watertight horizontally and up as far as the shelter deck).
Q. Taking the next bulkhead, B, on this same exhibit, will you state to what height the plan shows that that bulkhead goes, watertight?
- That bulkhead was carried watertight up to D deck, being stepped aft at this length and carried up to that (indicating); that reminds me, I think I said both those went to C deck, this morning; the second one (meaning B bulkhead) only went to D deck.
Q. Does this plan correctly show that bulkhead C goes up as high as E deck?
- Yes, and that the bulkheads D, E, F, G and H go up to E deck.
Q. And no higher? We understand when we say to a certain deck that it means no higher?
- It means no higher; they go up to the under side and are fastened to that deck.
Q. We have gotten back to H. H goes to what deck?
- H goes to E deck.
Q. And J?
- To D deck, and all bulkheads abaft that go t o D deck.
Q. When you speak of these bulkhead doors, watertight doors, being the only ones in certain bulkheads, do you mean the only ones on the tank top?
- On the tank top level; on the higher decks there are other doors. There are about 30 doors, altogether.
Q. Some of those doors are in the alleyways, are they not?
- Yes, there are three or four at the after end in the alleyway.
Q. Point to those.
- There are five (indicating); they are all marked.
Q. Suppose you mark those with a blue pencil.
Witness does as requested, on Petitioner's Exhibit 4-a.
- These are not, of course, of the electrically operated type. These are the hand type, and there were no watertight doors forward of that on E deck.
Q. This broad alleyway on E deck was what is known as Scotland Road?
- The men called it Scotland Road; that is the name of a broad, wide road in Liverpool.
Q. Then there were from that alleyway various doors that went into the boiler rooms, were there not?
- Yes; onto the gratings that lead down into the boiler rooms.
Q. Would that be the fidley?
- Yes.
Q. How were those doors constructed?
- Spilled gratings, bars; a plate frame crossed by bars.
Q. Were they watertight doors?
- No; there were opening: in them.
BY THE COURT
Q. Was the Titanic in its arrangement of the various parts such as dining salon, restaurant, accommodations generally, including staterooms and berths and public rooms, and what not, about the same as the Olympic?
- Broadly, the same, yes, the chief difference being that the number of cabins on B deck and the size of the restaurant were increased in the Titanic.
BY MR. BETTS:
Q. Now taking Exhibit 4-a again, and looking at the plan of the tank top, I see a passageway marked "Firemen's passageway and pipe tunnel," underneath apparently No. 2 and No. 3 hatch; is that correct?
- Quite correct.
Q. How high was that passageway; through one deck?
- Oh, no; it was about 10 feet, 6 inches from the tank top, and as shown on Exhibit No. 4 did not extend more than halfway to the lowest deck. It is a mere pipe, comparatively a small pipe.
Q. Is that a watertight passageway?
- Absolutely watertight, as far as we could make it.
Q. And that connects at its forward end with two spiral stairways there?
- Yes.
Q. Which are, in turn, in the watertight trunk?
- In the watertight trunk.
Q. To what deck does that watertight trunk extend?
- The plan shows; I think it is G deck.
Q. If G deck is flooded in that compartment No. 1, does that then flood the pipe tunnel?
- Yes; and in the flooding calculations which I submitted to you this morning that was allowed for.
Q. If that passage is flooded, does that affect any other hold or compartment?
- No, being watertight..
Q. Provided the watertight door is shut at the end of the passage?
- Assuming that it is shut.
Q. Were there firemen's accommodations on G deck or above?
- On G deck and above, G, F and D.
Q. I notice in D bulkhead, just aft of D bulkhead, apparently, two watertight doors. What is that compartment which is between the two?
- We have a very strong prejudice at Harland & Wolff's to having a watertight door actually adjacent to coal, which has to be worked during the voyage. No. 3 hold was used as a. reserve bunker. In order to maintain the intactness of this D bulkhead, which is at the after end and yet enable coal to be got out of it at sea a watertight box was built over the after end of the pipe tunnel, having ordinary non-watertight doors opening into the reserve bunkers and having "a watertight door on the after side opening into the stoke hole. So that, if necessary, reserve coal, when being worked out with the reserve bunker nearly full, did not come in contact directly with the watertight door.
Q. Then the door in D was not watertight?
- It was; there was a special little box.
Q. Suppose that you put around the watertight box a blue line on this plan, Exhibit 4-A?
- Witness does as requested.
Q. Back of that watertight box are the boilers in No. 6 room?
- Yes.
Q. How do the firemen get between the boilers in No. 6? Are these open spaces that we see that we will mark with a red pencil -- are those spaces through which the firemen can walk?
- Yes; two of them only are kept clear; the third one is usually used as a storeroom.
Q. You don't know which one is kept clear?
- In this case -- I think I could tell you in each case, but I am not absolutely sure; but I believe that it was the one between the two outside boilers on both port and starboard, so that there were two passages.
Q. The watertight door between 6 and 5 boiler room is stepped out, is it not, from the bulkhead?
- Yes, on the end of a short pipe.
Q. And at the port and starboard of that pipe, back of that bulkhead, is where the coal bunkers were?
- Quite right.
Q. Where were the doors that came from the coal bunkers in No. 5 boiler room?
Witness indicates with red pencil.
- There was one there and another there (indicating with red crosses); on the starboard side there were two and one on the center line and two more on the port side.
Q. Are those doors that lead into the bunkers such as in No. 5, are they watertight doors?
- Not in any shape or form; only made of quite light, thin plating, stiffened on the edge to prevent the coal from a full bunker spilling out to the stoke hole plate.
Q. Does that also apply to the bulkheads which form the bunkers?
- Comparatively; they are much lighter than any watertight bulkhead.
Q. They wouldn't stand the pressure of water against them?
- They would stand a little, of course, being strongly built; however, not so strongly as a watertight bulkhead; they would leak, in other words, without being strictly watertight.
A larger scale plan of the arrangement of coal bunkers produced and put in, and is marked Claimants' Exhibit B.
Q. And the doors do appear correctly?
- Yes.
Q. Will you tell us how far from the stem of the ship this bulkhead between 4 and 5 boiler rooms is?
- Within a few, feet (measures); between 305 and 310 feet.
Q. Can you give us the height above the waterline of the ship of these various watertight bulkheads?
- Yes; it can be scaled from the plan.
Q. I would like, starting from A bulkhead, to have you give the height from the keel.
A structural elevation plan is produced and marked Claimants' Exhibit C of this date.
- 75 feet from keel; we can deduct any waterline we like.
Q. You deduct a waterline of 34 feet, 7 inches, from the height above the keel; that will give you the height of that bulkhead above the waterline?
- Yes, it mould be about forty something feet; that is A bulkhead.
Q. B bulkhead?
- That was of similar construction and extended one deck higher than was necessary for flotation. It was done just because there was a steel bulkhead there. This one B is 66 feet; C is 51 feet; D is 50 feet, E is 49; F is 47; G is 46; and H is 46; J is 45, - no, 44-1/2, all above keel.
Q. This plan is known as the structural elevation plan, is it not?
- It is.
Q. Was this made for the purpose of sending in in answer to the Court's order?
- It is a photograph of a tracing made from the original, in accordance with the Court's order.
Q. Now, take the waterline. When you speak of a 34 foot, 7 inch waterline, you mean the greatest draft of the ship at that point?
- The greatest draft; that is, the draft under the Board of Trade regulations, to which she was allowed to load.
Q. Are you speaking of the draft at the Plimsoll mark?
- The draft at the Plimsoll mark is the same thing.
Q. When you have mentioned the bulkheads as being watertight to a certain depth, I think you have already said that that meant that they were not watertight any higher than that?
- They were not watertight any higher than that; watertight and fastened watertight to the under side of the deck.
Q. The bulkhead might extend higher than that without being watertight, might it?
- It might extend higher than that without being watertight, for fire purposes.
Q. And the heights that I have mentioned were the watertight heights of the bulkhead?
- The watertight heights is of the bulkhead; that was what you asked me and that was what I answered.
Q. When you have mentioned the construction of the Olympic, have you referred to the original construction of the Olympic or the construction as she is today?
- The construction is generally the same, as structurally we have made very little change.
Q. It has been changed, has it?
Mr. Burlingham:
I object to anything that occurred after the disaster, as inadmissible, immaterial and irrelevant.
Decision reserved.
- Yes.
Q. What changes have been made in the Olympic since she was constructed, with reference to the bulkheads and with reference to the inner skin of the ship, if any?
- After the accident to the Titanic, certain alterations were decided on, with a view to increasing the margin of safety. We had arranged prior to that, as I told the Court this morning, for any two compartments flooded. The owners desired, in view of the character of the accident, to see that she would float with a large number of compartments flooded; and to do that we carried up certain of the bulkheads to a greater height.
Q. Which ones were those?
- I am not sure that I can tell you offhand, but there were three or four of them.
Q. In what part of the ship were they?
- The whole length; there was no reason for carrying them up in one part rather than another; but we picked certain bulkheads and extended them; and on those bulkheads, the stresses possible being greater, the stiffening on them had to be correspondingly increased.
Q. Did you extend some of the bulkheads up as high as B deck?
- We did; I think four of them; either four or five.
Mr. Burlingham:
This is all taken subject to objection.
Q. Did you add one watertight bulkhead to the ship?
- My recollection is that we did put one in -- in order to be able to say that she would float with any group of six of the original compartments flooded, I believe we put in an additional bulkhead abaft the engine room, between the two sets of the electric light engines.
Q. Did you after you had raised these watertight bulkheads this additional height take them up as high as the top plated deck of the vessel?
- The top plated deck, no; as high as the top strong plated deck, yes.
Q. That would be at which deck?
- The B deck; but both A deck and the boat deck were plated.
Q. These numbers and names of the decks are the same in the Olympic and the Titanic?
- Absolutely.
Q. Did you build any watertight decks in the Olympic at that time?
- Yes, a watertight deck was put in No. 1 hold, speaking from memory, I believe it was the orlop deck in No. 1 hold that was made watertight; the question of putting in more watertight decks was proposed at that time and discussed, and I objected to do it, for the reason I gave this morning; for loss of stability (or danger of turning turtle) if struck.
Q. In only one hold did you put it?
- In only this one hold; I believe it was the orlop deck, in No. 1 hold. I will mark it in blue on Exhibit 4, a blue dotted ring will indicate the extent to which it was done.
Witness indicates on Exhibit 4.
Q. Did you put any other watertight decks except that one in the ship?
- Nothing additional; there was some original watertight deck, of course, but none except what was there originally.
Q. Did you also build an inner skin throughout part of the vessel?
- We did.
Q. Through what parts did you build them?
- Through the engine and boiler spaces.
Q. How far was that from the outside plating?
- 30 inches; the depth of the original web frame.
Q. How did that inner skin compare with the construction of the Mauretania and Lusitania?
- Totally different.
Q. Do you know how it compared with any of the German ships?
- It was not, as far as I know, like any of the German ships. It was more like a warship; it was of the same character.
Q. Do you know what was the difference between that inner skin of the German ship Imperator, for instance?
Mr. Burlingham:
I object.
- She was built afterwards; I couldn't quote offhand the Imperator. It is a long time since I have seen her plan.
Q. I show you a picture of the space between the inner and outer skins of the Imperator in the Scientific American of April 19, 1915, and ask you if that refreshes your recollection?
- I have seen that photograph - or rather a similar photograph - before; and judging by that, of course, I would say that the space in the Imperator was about halfway between what we did in the Olympic and the watertight side bunkers of the Mauretania. That is, it looks about 5 or 6 feet wide.
Q. Do you recollect whether the Imperator was building when the Titanic was building?
- She was; that is, she only started to build when the Titanic was well advanced; but they overlapped. They started to build her, I believe, about the time that we launched the Titanic.
Q. Do you recollect whether the construction in the Vaterland is the same as the Imperator, with reference to the inner skin?
- I am again subject to correction, but as far as memory goes, it is substantially the same.