Limitation of Liability Hearings

Deposition of EDWARD WILDING, contd.

Q. Do you recollect whether the Kronprinzessin Cecilie had similar construction?
- I believe not. I believe she was more like the Mauretania.

Q. She was more of the longitudinal bulkhead type?
- I believe so.

Q. Do you remember whether she was built before the Titanic was built?
- She was; about the same time as the Lusitania, roughly.

The article referred to by Mr. Betts is marked Claimants' Exhibit D for identification.

Q. Taking the Olympic as she is today, how many compartments can be flooded forward before she would sink?
- Six.

Q. That is three hatches, two boiler rooms and the forepeak?
- Yes; it was taken in successive sixes. If you take the next group of six she will also float, and the next group, and so on.

Q. So that with any successive six compartments -
- It is not quite that; but she is divided into groups of six and she would float with any one of those groups flooded. There are five groups of six, I think, and any one of these groups of six could be flooded. Each high bulkhead is so arranged as to carry a group of six.

Q. You mean, any one of certain groups or six adjoining compartments?
- Any one of certain groups of six adjoining compartments. On looking at the plan, to the best of my recollection, the bulkheads which were extended to B deck were as follows: F bulkhead, which provided for the flotation of the ship with the six foremost compartments flooded; D and J, which provided for flotation with the six compartments containing the boilers, all flooded; bulkhead L to the bridge deck, which with bulkhead F provided for flotation with the four after boiler rooms, and two engine rooms, making six compartments, flooded; P bulkhead, which with J bulkhead and the new bulkhead extending to D deck provided for flotation with the two engine rooms and four compartments abaft it flooded.

Q. Has there been, so far as you know, any practical difficulty in the operation of the vessel with these changes?
- Not practical difficulty, because when we arranged that we obtained certain concessions from the Board of Trade in their requirements that they otherwise make, for doing it. The Board of Trade originally made a certain requirement for all watertight bulkheads. They don't compel you to do certain things; they ask for them and say they would like them. When we did this some of those things which they would usually ask for an ordinary watertight bulkhead would have made the working of the ship impossible, if insisted on. As we were doing more than anything they had in contemplation, they didn't let us off anything that they would have originally asked, but they let us off certain conditions which they imposed on watertight bulkheads but which were not imposed for bulkheads of this height, such not having been contemplated.

Q. Then did these changes seriously interfere with the convenience of the passengers?
- They interfered a little. We tried in carrying then out to minimize the interference. For example, they interfered in this way: They made a number of very awkward steps in the deck in going through bulkheads. There were some difficulties in passengers getting about. They weren't so comfortable.

Q. Do you know anything of any change made to the front bulwark of the bridge, as to the platforms which you have mentioned?

Objected to as before.

Same ruling.

A. It was made on the Olympic, but not until a later date, after the other alterations; it was a separate alteration, made later.

Q. What was that alteration?
- The alteration that was made was the raised platform that I spoke of this morning was taken away and the forward end of the bulwark on the bridge was lowered; 9 inches, I believe.

Q. Was the purpose of that so that an officer standing anywhere on the bridge could see?
- I really don't know; it was a fad, I believe, of the Marine Superintendent.

Mr. Burlingham:
I move to strike out the testimony relative to the changes in the Olympic.

Decision reserved.

Q. Referring to the photograph of the Welin davit, which had been marked petitioner's Exhibit No. 9, will you describe how those davits operate; in other words, how they move from outboard inboard?
- Yes. The photograph shows a long screw working in a concealed nut behind a pivot. If you turn by this handle (indicating) this screw, it drags the nut along and turns the davit around in that way (illustrating).

Q. So that the davit swings from inboard out, or vice versa, without changing the plane of the supporting nut of the davit?
- That is right; it swings in a transverse plane.

Q. Do you know where the boats are carried with reference to these davits, today, on the Olympic; where are they carried? Is that a correct photograph of the boats that were on the Titanic, or is this a photograph of the Olympic (referring to Exhibit 9)?
- There was no difference when the boats were finished, and I cannot identify it as either ship.

Q. Do you know whether this was taken before the accident to the Titanic, or afterwards?
- I believe it was taken before the accident; before the Titanic left Belfast; but I am not sure. I could ascertain that by reference to the photographer and his marks, if it is of any importance. I feel fairly sure that it was taken before the accident.

Q. Are the boats on the Olympic today carried in that position?

Same objection and ruling.

- Exactly; there are additional boats, but the boats are carried in the same position, and other boats as well.

Q. Where are the other boats carried? Can you point out on this photograph?
- (Witness made a diagram and described) Originally the boats were carried as shown in blue; the original boats in blue. That original boat is lifted on a stand (indicating), as indicated in red, and a collapsible boat of the Engelhardt type has been fitted underneath, and is drawn in red dotted lines. In addition, other Engelhardts are carried inboard, in the inboard position alongside.

Q. Are there any additional lifeboats carried besides the Engelhardt boats inboard?
- There were some additional lifeboats also fitted between the forward and after groups; but I believe no additional ones were carried inboard.

Q. The additional lifeboats were fitted on the boat deck?
- On the boat deck, on the side.

Q. Do you know how many were put on each side?
- Five on each side.

The drawing referred to by the witness is marked Claimants' Exhibit E.

Q. Do you know how many lifeboats are carried now on the Olympic?
- I couldn't answer offhand; but there are lifeboats of capacity such as to provide for the full number of passengers shown on the Board of Trade or passenger certificate.

Q. What is her stability with those additional boats?
- Less; she has to be more carefully handled and the Marine Superintendent states difficulty in her docking in a high wind.

Q. Have they added any ballast since then?
- Not permanent; they have to make more extensive use of water ballast, which leads to more trouble in up-keep.

Q. Are you familiar with what the German and the United States requirements were with reference to lifeboat accommodations in April, 1912?
- Generally.

Q. Do you know whether they made a larger requirement for a boat of this tonnage than the English law did?
- They did.

Q. Was it quite a considerable difference?

Objected to as immaterial and irrelevant.

Decision reserved.

- A moderate amount in both.

Q. Well, give me about what the percentage difference would be?
- I think the German percentage was about 30 percent more and the American about 50 percent more than the British.

Q. My associates have asked me whether I made it clear that it was based on the tonnage of the ship?
- In both cases; it wasn't based on people on board, hut the tonnage in all cases, except in Spain.

Q. As you understand it, the British rule at that time with reference to lifeboats made no different provision for a boat of 50,000 tons than it did for a boat of 10,000 tons?
- Quite right.

Q. When this rule was passed for lifeboat accommodations by the Board of Trade how many boats were there, as far as you know, British steamers, of over 10,000 tons gross?
- Offhand I couldn't say; but some 15 or 20, I think.

Q. How large were they, about?
- Some were about 20,000 tons.

Q. Do you remember the name of any one?
- I think the largest at that time was the Campania or Lucania; I think so; the largest that were then built.

Q. Weren't they less than 20,000 tons?
- They were less than 20,000 tons.

Q. Do you remember what the tonnage was of the two Cunarders that you mentioned?
- It was between ten and twenty; I think it was eighteen thousand and something; it can be found by turning up the Lloyd's Register of that date.

Q. Wouldn't it be a good deal less than that?
- I can be verified, as I say; I am subject to correction. The Campania was 12,884 tons gross and the Lucania was 12,952 tons gross.

Q. At that time would German regulations for lifeboats have a sliding scale so that the regulation differed according to the size of the vessel?

Objected to as immaterial.

Decision reserved.

- It did.

Q. And did the United States follow the same rule?

Same objection.

Decision reserved.

- Yes.

Q. With the vessels that you were building at your yard in the last ten years, say, do you recollect in what proportion of them you put on lifeboats that exceeded the Board of Trade rule?
- We always put on a little more than the Board of Trade rule in any case.

Q. As a matter of fact, almost all the British passenger steamers exceed the Board of Trade rules for lifeboat accommodation?
- By a small amount, yes.

Q. Didn't some of the British vessels, such as the Royal Mail Steam Packet Company and the P. & O. greatly exceed that requirement?
- No; very little.

Q. Didn't they carry lifeboats sufficient for all of the passengers and crew that were on board?
- They did.

Q. That resulted from the fact that they did not carry so many emigrants?
- Exactly, because the carriage of a large number of emigrants is a peculiarity of the North Atlantic trade; or was at that time, at any rate.

Q. You made some calculations as to the total area of the opening through which the water came into the Titanic, did you not?
- I did, for Lord Mersey.

Q. Will you tell us how you made that computation?
- Yes. It was known that certain spaces were filled up in a certain number of minutes, approximately. You couldn't say to a stop watch, but in about 40 minutes certain compartments forward were filled up to a certain level. The capacity of those compartments was known, and therefore the amount of water which got in in the 40 minutes was known. The approximate depth of the position of the damage was known and it was then possible to calculate the rate of inflow per square foot of opening. I have the total inflow and I can divide that by the number of minutes and get the total inflow per minute. I can get the inflow per square foot per minute, and by dividing the one by the other I can get the square feet.

Q. What was the area?
- My memory is 12 square feet; 4 feet by 3.

Q. That is the total area of all the openings in the ship's side?
- That is right.

Q. By this I mean that the total area of all the openings in the ship's side caused by the collision and added together would equal about 12 square feet?
- Quite correct. For your information, the accuracy of that is probably one quarter either way; that is, it is more than 9 and less than 15, and 12 is the most probable.

Q. When you speak of the extra strength of the bulkhead and the plating on this ship, do you mean extra for a ship of that size or do you mean extra for the ordinary sized ship?
- Extra for a ship of that size.

Q. What other ships had you built of that size?
- Well, we had built other large ships; that is, ships getting up to that size.

Q. Well, for instance, what tonnage?
- 25 or 30 thousand, the Rotterdam and the Adriatic.

Q. There is considerable difference between the size of those ships?
- Undoubtedly, in tonnage, yes; in depth, little.

Q. As a matter of fact, wasn't your additional strength commensurate with the increase of the size of the ship?
- More than commensurate; that was the way I should have put it.

Q. Wasn't the reason for that that these very large ships were more or less of an experiment and one didn't know just what stresses they would he under?
- One had a pretty good idea of what the stresses were; but we were proposing to deal with a very large ship, and we were not proposing to run any chances that spending a few hundred pounds would avoid.

Q. The Britannic, is that now in course of construction?
- Nearly complete.

Q. Does that construction, with reference to the watertight bulkheads and watertightness differ in any great respect from that of the present arrangement on the Olympic?

Same objection.

Decision reserved.

- It is almost identical; as identical as with the slight differences in the ships it can be.

Q. What difference, if any, is there in the size between the Titanic and the Britannic?
- So far, the owners have not published it. I think you had better ask the owners.

Q. You might tell us, about?
- The owners have made a deliberate point of refraining; I know, of course, perfectly well, but I don't think I had better tell.

The Court:
I don't see any reason why they should be asked to disclose their business.

The Witness:
She is a little larger, but not much.

Q. With reference to your flooding plan, which you introduced, what effect on the results would the question whether or not the forepeak was flooded have?
- Very little effect, the amount being shown by the yellow line; the difference from the yellow line and from the dotted black line.

CROSS EXAMINATION BY MR. ROBINSON:

Q. In making that calculation as to the flooding plan, what factor of permeability did you allow?
- A factor in the coal bunkers of 50 percent and in the cargo holds of 75 percent; in the mail and baggage rooms of 83-1/3 percent; in the engine and boiler spaces 80 percent; in the passenger accommodation 95 percent.

Q. Was due consideration given to the loss of water plane?
- Certainly; the calculations were made by what is known as the Bonjean Curve method, the direct method; he, Bonjean was a French mathematician of about 1790.

BY MR. BETTS:

Q. Did you make calculations yourself for this flooding plan?
- I made one of them myself, personally; the others were made by my assistants, in order to facilitate getting through in time.

Q. Which one did you make, yourself, personally?
- The one I made personally was the one for the blue, because it was the first difficult one; I started on that.

Q. I think the blue one was the one that wrote the epitaph of the vessel, as you say?
- The blue one was the first difficult one; I did that myself; I put my assistants on to the others.

CROSS EXAMINATION BY MR. HOUSTON:

Q. I want to ask for some more details as to that stopping and turning test that you conducted. As I understand it, you testified as to the stopping test, in the case of the Titanic the vessel was going forward at about 20 knots?
- That is from memory.

Q. On a straight course?
- Yes.

Q. When did you signal the captain to reverse?
- As soon the buoy which was our landmark -- we were out at sea -- was vertically below the bridge so that we could measure the distance that the ship had actually run from my giving the signal. The observers were on the bridge, and therefore would observe the distance from the bridge.

Q. And the buoy was directly under the bridge?
- The buoy was directly under the bridge; that was why I was standing at the side.

Q. Have you prepared any plotted diagram showing the course of the ship when the helm was put hard over at full speed?
- Yes.

Q. Is that here?
- It has not been put in. I am not sure whether I have it at the hotel or not. I will undertake to look for it and produce it.

Mr. Houston:
I would like to have that.

Q. Were any stopping tests made at any other speed than 20 knots?
- No, only at what was called full speed.

Q. Can you estimate that the stopping distance would be at say 10 or 12 knots?
- It would be very difficult; so much would depend on the head of steam available, and on a lot of minor circumstances that might or might not arise; you might make an estimate that was right or it might be a hundred percent out.

Q. At least, you could stop much quicker at 10 or 12 knots?
- Judging from experiments on other and smaller vessels, the difference is much less than would be supposed.

Q. But there is quite a substantial difference?
- In one case where we began to try the difference they reduced the speed to one-half; we had been going 19 and reduced it to 9-1/2, in another ship altogether.

Mr. Foster:
I object to this line of testimony on the ground that it cannot afford any assistance to the Court in determining in just how short a time the Titanic could have been stopped.

The Court:
It may be taken.

BY MR. FOSTER:

Q. Do you agree with me?
- I agree that it does not throw any direct light on the subject.

BY MR. HOUSTON:

Q. At least, the stopping distance is substantially less as the speed decreases.

Mr. Foster:
Objected to.

- We found in the case I was proposing to mention, not.

Q. Not substantially?
- Not substantially still, it was by a percentage.

Q. What was the percentage? What percentage of decrease in the stopping distance?

Same objection.

- About 15 percent.

Q. That is, by reducing the speed of the vessel one-half, you reduced the distance that the vessel runs, before she comes to a dead stop, 15 percent?
- Yes; from 100 to somewhere between 80 and 85.

BY MR. BURLINGHAM:

Q. Reduced it by 15 percent?
- Reduced it by 15 percent; that was the intention of my reply.

BY MR. HOUSTON:

Q. If you want to modify that answer I want the full explanation.
- Of course the energy that you have to destroy has apparently been reduced by 75 percent; so that you have not gained the 75 percent in your stopping distance.

Q. What is the effect on the radius of turning of a reduction in speed?
- It increases the radius of turning.

Q. Does it increase the distance that the vessel travels forward?
- Yes; and the distance that she travels sideways; but only by a very small amount.

Q. Have you a diagram of that?
- I have a diagram of that, but it is not in the States. I have it at home and I can send it out.

Q. Have you a diagram showing the line of turning at half speed?
- At three different speeds. I think the lowest was down to about 12 knots; that was the Titanic herself.

Q. Under what conditions were those tests made? At what draft was the vessel?
- About 30 feet; she was almost fully coaled.

Q. What was the condition of the sea at the time?
- Fairly smooth; light breeze and sheltered water.

Q. The Titanic did not comply in all respects with the specifications of the Lloyds Register, did it?
- Lloyds Register had no specifications for so large a ship; nothing within a mile of it, so to speak.

Q. What was the reason that the vessel was not rated at Lloyds?
- Because it has never been the White Star practice to do so, for over 40 years.

Q. Isn't that because of some regulation or custom at Lloyds, with which the White Star boats do not comply?
- No, it simply goes back; I couldn't really answer what it started in, because it was before I was born.

Q. Are you familiar in a general way with the rating practices of Lloyds Register?
- Oh, quite. We build quite a large number of vessels to their class.

Q. Would the Titanic have been passed at Lloyds?
- I think she would if we had offered her to them. I may say that other ships built by us on the same general principles, of smaller size than the Titanic, have been offered after they have been completed, and have been classed by them without any question being raised or conditions required.

Q. Isn't it a fact that some of the Lloyds Rating Bureau had objected to bunker arrangements similar to those of the Titanic?
- Not to my knowledge; they have always encouraged them in ships that we have built for them, in ships we have built to their survey.

Q. Do you mean to say that from your knowledge of the customs at Lloyds the Titanic would have been passed at Lloyds without any change whatever?
- I can't put it any higher than this: I believe if we were to offer the Olympic today to Lloyds they would class her without making any further requirement. I have no authority for it, though.

Q. That is, the Olympic in her present condition?
- Or as she was finished originally. We have made no change that would affect Lloyds classification; none of the changes made would have affected Lloyds' views as to classing her.

Q. In the beginning of your testimony you said that a part of your duty was to confer with the customers for whom you build ships?
- Yes.

Q. And discuss the plans with them?
- Yes.

Q. Was that part of your duty at the time the Titanic was built?
- It would have been Mr. Andrews' duty, as he was then in charge of the designing department.

Q. Did you have any conversation with the officers of the White Star Line with respect to the plan of the Titanic?
- I was present at some, but not in charge of the discussion.

Q. Who was present at those conferences?
- It is six years ago; I couldn't quote.

Q. Can you remember any of those present at any of them?
- I couldn't give a date for the conference and state that anyone was present then; it was usual for them to have some of their managers and some of their superintendents.

Q. About how many of those conferences did you attend?
- Those that were held in Belfast.

Q. About how many were there, roughly?
- Well, again you are asking me something that I cannot say.

Q. Was it five or a hundred?
- Something between six and twelve.

Q. Can you remember any of the people who were present?
- During that time, yes; there were practically all the White Star people present at one meeting or another; all the White Star people; but I can't say that at a certain conference a certain man was present; I have no doubt in the course of all the conferences practically all the White Star people were present.

Q. When you say White Star people, who do you mean?
- The White Star Liverpool managers and superintendents.

Q. Can you name those that you remember?
- Yes.

Q. Will you please name the representatives of the White Star Line whom you remember to have been present at one or more of these conferences?
- Mr. Ismay, Mr. Sanderson, Mr. Concannon, Mr. Cauty, Mr. Fletcher, Mr. Willett Bruce, the superintending engineer; the assistant superintending engineer, I have forgotten his name; Captain Murray, who was then marine superintendent, Captain Thornton, and Captain Bartlett, who was afterwards superintendent..

Q. On behalf of Harland & Wolff, was Mr. Andrews present?
- He would be present at all of them unless away on other business.

Q. Anyone else usually from Harland & Wolff?
- If Mr. Ismay or Mr. Sanderson, who were directors o f the White Star Line, were there, Lord Pirrie, our principal, would be there.

Q. About how many of these meetings did Mr. Ismay attend?
- I couldn't answer.

Q. Was he at several of them?
- Yes.

Q. More then half?
- I couldn't say.

By THE COURT:

Q. Do you remember what questions were discussed as to the constriction of the vessel?
- Practically none.

Q. Were there any, so far as your memory goes?
- Well, I can say no; no detail of our arrangement or construction.

Q. Was there any discussion as to the bullheads?
- As to the construction of the bulkheads, no; as to the arrangements of the bulkheads, yes, in the sense that they might want to move it a little for some purpose or other, and would ask if it could be done; as to position, but not as to construction.

Q. Is Lord Pirrie a practical shipbuilder?
- Yes. 40 years ago he was chief draftsman of Harland & Wolff.

BY MR BETTS:

Q. Was he one of the directors also of the Oceanic Steam Navigation Company?
- He was; that has been acknowledged.

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