Limitation of Liability Hearings

Deposition of EDWARD WILDING, contd.

BY MR. HOUSTON:

Q. Can you give us any other matters that were discussed at these conferences?
- Mainly such things as sanitary arrangements, ventilation, upholstering, decoration, fittings, the arrangement of stewards' accommodations and officers' accommodations, arrangements for working the ship, and things of that sort. It was not generally construction. Construction matters never were mentioned, as a rule.

Q. Were the plans showing the arrangement of watertight bulkheads present at those meetings?
- No details; that flooding plan by any two compartments, that I showed early this morning, was shown to them; it was made, and Mr. Ismay was at the meeting at which that was shown; it was made really for the purpose of showing him, satisfying him. (Witness refers to Exhibit 5).

Q. Does that diagram show the height of the bulkheads?
- Yes. He did not ask about the height of bulkheads; all he asked was "'Will she float with any two compartments flooded without the water coming over the top of the bulkheads?".

Q. However, the diagram which was exhibited there showed the height of the bulkheads?
- Yes; and Mr. Ismay looked at it and talked it over, and said he was satisfied.

Q. Was there any difference of opinion at these meetings, on any subject, that you recall?
- Difference of opinion as to what? As to whether a Georgian or a Louis Quatorze room was a proper way to decorate a first class room, yes.

Q. Whenever any difference of opinion developed, of any, kind, did Mr. Ismay have the deciding voice?
- When they were on such matters, generally, yes. He had a deciding voice, in the sense that the decision had to come from him eventually; but he always listened to what you had to say, and if he found you were right he agreed.

Q. But in all matters he was the last authority?
- We were building the ship, and he was the Chairman of the Company for whom we were building.

CROSS EXAMINED BY MR. FOSTER:

Q. Where were those lifeboats placed? In what part of the boat?
- On the boat deck.

Q. Any of them on the poop?
- No.

Q. How were they hung?
- They were not hung.

Q. How were they fastened?
- By gripes on chocks.

Q. How many did you say there were in all?
- There were 16 lifeboats and 4 collapsible.

Q. Was there room for any more?
- Yes.

Q. Arrangements had been made, had they not, so that more could be placed upon that vessel?
- No.

Q. None whatever?
- No arrangements made.

Q. No arrangements made?
- No.

Q. Never had been contemplated?
- Never had been contemplated.

Q. No plan had been arranged?
- No plan had been arranged; not by the builders.

Q. You never saw any plan for that purpose?
- Yes.

Q. You have seen plans?
- I have seen plans.

Q. Plans had been exhibited to the builders, had they not?
- They had.

Q. Were there any lifeboats on the poop?
- No.

Q. Boats could have been placed on the poop?
- The Board of Trade would not have accepted them.

Mr. Foster:
I move to strike out the answer.

The Court:
I think that is a proper answer.

The Witness:
Physically, yes; practically, no.

Q. Your Company had built ships in which lifeboats were on the poop, had they not?
- Not for British owners.

Q. But they had for other owners?
- Yes.

Q. For what owners?
- German.

Q. Your Company had built boats for the P. & O., had they not?
- Yes.

Q. For the Royal Mail?
- Yes.

Q. For ocean-going steamers?
- Yes.

Q. Had they not provided in them sufficient lifeboats for all the passengers on board, in certain instances?
- In certain instances the boats that were provided were sufficient for all on board, yes.

Q. Did you not testify before Lord Mersey, page 534, that you had seen plans prepared among yourselves which shows two lifeboats under each pair of davits?
- I have admitted that I saw such plans.

Q. Did you not see one plan showing three lifeboats under one pair of davits?
- As far as I recollect, no.

Q. Wasn't it a plan drawn by a man called Welin that showed that?
- The plan did not show three boats; it showed two drawn boats and one dotted as in the swing outboard position. It looked like three at first glance, but it was not really so.

Q. Did you not testify before Lord Mersey as follows: I refer to question No. 20758:

"Q. Did you see any plans showing three boats?
- I think there was a plan submitted to us by Welin showing three boats."

I subsequently referred to the plan again, and found that it was not as I had testified; it was two drawn and one dotted, giving the impression of three boats.

Q. You were mistaken when you testified before that that plan showed three boats?
- I qualified it to the best of my then belief; I think you will find it.

Q. You were mistaken when you made that statement?
- I agree; I was mistaken.

Q. But there was room on the Titanic for a great number of boats more than were actually there?
- Undoubtedly, and we have put them now in the Olympic.

Q. And there was room for a sufficient number of boats to have carried all the passengers?
- Boats of certain types, yes.

Q. Were there any motor boats?
- No.

Q. In some cases your firm has supplied motor boats on ocean-going steamers?
- Yes.

CROSS EXAMINED BY MR. EVERETT':

Q. Were you acquainted from 1894 on with the discussions, if any, in regard to the sufficiency of the Board of Trade rules as to lifeboats?
- I have only become acquainted with such discussions subsequently; that is, in 1894, I think.

Q. When the larger boats began to be built discussion arose among builders, did there not?
- I was in the Admiralty at that time, and therefore not interested.

Q. You began to be interested when you went to Harland & Wolff?
- Yes.

Q. At that time the matter was under discussion, wasn't it?
- I would not like to say at that time; but at intervals during the eight years between my going to Harland & Wolff and the Titanic accident, the question of boats was under discussion, yes.

Q. And about 1909, 1910 and 1911 the discussion became more complicated, did it not?
- I don't know; I would hardly use that word; there was further revival of the discussion.

Q. And the Board of Trade began to make further investigations?
- They did.

Q. Do you know Mr. William David Archer?
- Very well.

Q. (Referring to page 681 of the testimony of William David Archer before Lord Mersey.) He was the principal ship surveyor to the Board of Trade, was he not?
- And is still.

Q. And it was one of his duties, I suppose, to report on the cubic capacity of ships' boats provided?
- It was his department.

Q. Were you present at the Mersey investigation when he was testifying?
- I was.

Q. Do you recall his testifying in respect to a report which he made February 28th, 1911 as to additional boat equipment?
- No; I believe that report was then internal to the Board of Trade, and was not published.

Q. You never knew about that?
- Not except by rumor; there was no report available, I mean.

Q. Was he at Belfast while he was preparing his report?
- I believe he was, but I am not quite sure.

Q. Did he consult with you personally as to your views?
- He did not.

Q. Did you have any reason to believe, before the Titanic left for her first voyage, that he had recommended boat equipment for all persons on board the ship?
- I have no reason to believe he made any such recommendations.

Q. That was not a subject of talk or gossip in the shipbuilding business, that he had such a plan under contemplation?
- No; in fact, whilst it was a subject of general information, if one may so say, that he was contemplating recommending an increase, it was also a subject of general knowledge or report that the contemplation was based on tonnage and that the amount of the increase was very moderate.

Q. When it turned out that it was a very radical increase that was a surprise to you, wasn't it?
- Well, of course, the report was never acted on; the regulations were never made.

Q. I know that; but I am talking about the report itself.
- Well, it would only be fair to say that I did not see the report till some time after the Titanic accident.

Mr. Burlingham:
Is there any evidence to show when it came out?

Mr. Everett:
No, that is what I wanted to know.

BY THE COURT:

Q. Mr. Acher's report, as I understand you, never came out; it was never acted upon?
- It was never acted on.

Q. When did it come out?
- It was called for about the end of Lord Mersey's Inquiry, and was printed hurriedly then, and there were some copies available and I got one.

Q. Before Lord Mersey's Inquiry had it become a public matter?
- No; and it was not until the extreme end of Lord Mersey's Inquiry public matter. In fact, I think it has never been a public matter, thought I got one, as a favor, being in court.

BY MR. EVERETT:

Q. Mr. William Chalmers was at the head of the Board of Trade?
- Alfred Chalmers.

Q. Until a year or two before the Titanic accident?
- He was the principal marine advisor; he is not the head of the Board of Trade.

Q. He had shortly before his retirement made long recommendations for an increase of boats?
- I believe so, but as to their character, I never heard.

Mr. Burlingham:
When was his retirement?

Mr. Everett:
I understood it was a year or two before the Titanic accident.

The Witness:
He had retired while the Titanic was building, yes.

Q. Were you ever called before the Board of Trade or any of its official advisers, to give your views on the extent of boat accommodation?
- No, I was never asked, and I can also say as a matter of knowledge that Mr. Andrews was never asked; that is, the designing department of Harland & Wolff were not asked.

Q. Coming to the question of Lloyds. Was there any communication at all with Lloyds during the building or before the launching of the Titanic, in reference to their survey requirements?
- Never, for any White Star ship; it was never mentioned.

Q. And you never applied for any insurance in which they were concerned?
- Not through Lloyds; Lloyds Register has nothing to do with insurance.

Q. Was there any insurance on the Titanic?

Mr. Burlingham:
Objected to as immaterial and irrelevant.

- Yes. We of course insured her whilst building, on builders' risk policies.

Q. When she was delivered to her owners, was that insurance terminated?
- That insurance terminated. It terminated on the completion of trial; it is for building and trial. On handing the vessel over to owners they begin to run their insurance policies.

Q. You don't know what insurance they got?

Objected to.

- I am not informed, only by report.

BY THE COURT:

Q. What, precisely, was the date when the vessel was turned over by Harland & Wolff to the owners?
- In the evening of Tuesday, April 2nd, 1912.

Q. Just prior to sailing?
- After completion of the trials prior to sailing; then the owners accepted her and Captain Smith took command.

CROSS EXAMINED BY MR. MURRAY:

Q. This contract letter that was put in evidence this morning, can you tell who was the writer of that letter?
- I know; Lord Pirrie personally wrote it, as our principal.

Q. And Lord Pirrie was a director of the Oceanic Steam Navigation Company?
- He was the principal of Harland & Wolff. He signed Harland & Wolff's name.

Q. But was he a director of that company?
- Oh, yes, and has been for many years.

Q. Did you ever see the agreement made by Harland & Wolff with J. P. Morgan & Company?
- No, I have never seen it.

Q. That was in reference to the terms on which these vessels were built?
- Yes; I only know of the general character of it; I have never seen the agreement and am not familiar with what it contains, in detail.

Q. This reference to a conversation between the writer and Mr. Ismay -- A. Between Lord Pirrie and Mr. Ismay, as the heads of the two firms.

Q. Was Mr. Ismay a director of Harland & Wolff?
- He hadn't any interest whatever in Harland & Wolff.

CROSS EXAMINED BY MR. BROUGHAM:

Q. You stated that the ship was turned over to the owners on the evening of April 2nd, 1912.
- That is my memory of it, yes.

Q. And these trials that you spoke of a while ago, were on the next day?
- No, they were on the forenoon and the afternoon of that day; and on completion of the trials the ship was turned over.

Q. You stated before that the trials were on April 2nd and 3rd.
- There were some further trials made on the 3rd, after the ship was turned over.

Q. Were any of these turning or stopping trials made on the 3rd?
- No.

Q. What trials were made on the 3rd?
- A still further electrical trial, trials involving the sanitary arrangements and various other matters of that sort; trials consist of trying everything in the ship, and there are a good many things to try.

Q. What was the speed of the Titanic, the highest speed?
- During April 3rd when running south, we obtained a speed of about 23-l/4 knots for several hours.

Q. That was with the waterline at 30 feet?
- The mean draft about 30 feet.

Q. What was the weather?
- Fine and bright; a pretty bright day; it wasn't a brilliant day, but it was quite presentable.

Q. As to wind and sea, what was the weather?
- For a big ship it was fine weather; if you had been out in a cockle sheel you would have called it rough.

Q. You testified that as to height and strength of bulkheads on the Titanic you constructed them according to the highest standard. What you meant by that really amounts to the highest practice, does it not?
- Well, I think in excess of the highest standard was what I said, was it not? I didn't say in accordance with the highest standard.

Q. Well, you stated after a while that the thickness was in excess.
- It should be that it was in excess of the highest recognized standards; that would describe it, I think, fairly.

Q. But that was so far as thickness was concerned?
- Both thickness and strength; but not as to height. There was no regulation known to me that would have required that they be carried higher.

Q. Then you are speaking of regulations, when you say standard?
- Such regulation as can be intended to apply to a ship of that character, yes.

Q. To a British vessel under the British Board of Trade rules?
- Yes; the only rules that apply are the freeboard board tables.

Q. But there was no prohibition against your exceeding those requirements?
- Oh, no; we were at liberty to exceed the requirements.

Q. In fact, all of these regulations were merely minimum requirements?
- That is inferentially the case.

Q. In other words, it was what the law insisted you must have?
- That is right; not less than so and so.

Q. To at least come within the pale of the law?
- We must come a little further than that; sometimes a good deal further.

Q. And as matter of feet these requirements are based upon the normal, what happens every day, rather than unusual events to be anticipated?
- Well, one can't anticipate unusual events.

Q. But you testified before Lord Mersey that you did not build ships to run into wrecks or icebergs, but just to float.
- Exactly; in substance, I think that is right.

Q. And so, so far as your practice is concerned, it was not within the anticipation of any particular catastrophe?
- No particular form of accident, no; let me say fairly that the form of accident that was regarded as a standard accident, as the most serious probable accident, is merely a direct collision coming on the watertight bulkhead which flooded the compartments on both sides of it.

Q. That would be such as another ship colliding into the side and cutting a hole in her?
- Yes, close to her watertight bulkhead, a large hole.

Q. And it was with that in view that you spoke of watertight decks being possibly dangerous?
- With certain character of accidents, it is possible, yes.

Q. In other words, if the watertight deck were just below the waterline and the hole in the hull of the ship were above the waterline, then it might let some water in on top of the watertight deck, and it might make the ship turn turtle, because of the air underneath the watertight deck?
- Yes.

Q. But that would be easily arranged for by having it so arranged that the water could be allowed to go below?
- Well, then it is not a watertight deck.

Q. I understood you to say that it might be used as a watertight deck but that the watertightness might be eliminated whenever that became larger.
- It would be a very unreliable arrangement, or risky.

Q. But it has been done?
- It may have been; I don't know that; but in warships it is not unusual in watertight decks to fit special apparatus of such a character that water can he allowed to run down through the watertight deck; that is, that the watertightness of the watertight deck can be temporarily destroyed.

Q. Watertight bulkheads are normally not watertight, because the bulkhead door opens?
- Very often; it is part of the regulations of most companies, and I think of the White Star, amongst others, that during the time when there are most risks of accident such doors shall be kept closed. That is a very general requirement.

Q. That is the requirement now, is it not?
- It is, and has been for many years.

Q. So far as you know?
- Yes. In several companies I know that it has been; I couldn't say definitely about all.

Q. But if the watertight deck is the lid of the decks higher up, then your objection that the ship would turn turtle does not obtain, does it?
- Yes. Suppose the ship is struck on the bulkhead and she sinks down, which she would with the two compartments flooded. That would let her down in the water. If there is an opening in the ship's side that will let water in, it then gets into parts of the deck which are not injured; it can't get down.

Q. I don't think I follow you there. You are not assuming the same sort of injury that I was.
- Yes; at least, I hope I am.

Witness draws and explains diagram.

Q. It appears from what you have just said off the record that we are working somewhat at cross purposes. I was assuming an injury below the waterline; but also below the watertight deck which acted as a lid upon the watertight compartment. Then your objection that the ship would turn turtle vanishes?
- Oh, certainly, then it vanishes absolutely.

Q. But with two compartments flooded it does not show that if the forepeak and No. 1 and No. 2 hold were flooded, she would not have completely filled those compartments up as high as the bulkheads themselves extended?
- Exactly; and therefore she would have remained afloat, because there is still freeboard.

Q. And so would she stay right side up, even if the wound extended above the so-called watertight deck?
- Certainly.

Q. Therefore I don't see how you can say that your objection remains, with the watertight deck at the top of the bulkheads.
- Of course, the higher you put the watertight deck, the less danger there is from that particular watertight deck.

Q. As to longitudinally watertight bulkheads: You stated that "In our opinion it is very dangerous to have it."

What do you mean by "our"? Harland & Wolff?
- Harland & Wolff. I was testifying at Lord Mersey's Inquiry as representing Harland & Wolff; not as representing my personal opinion.

Q. You testified here "In our judgment they were dangerous."
- That is the same thing; it is our united opinion. It is not just my personal opinion, though I have to express it.

Q. Was Mr. Carlisle connected with Harland & Wolff at the time the Titanic was planned?
- Yes, sir.

Q. As I remember your testimony before Lord Mersey, your idea as to the danger of longitudinal bulkheads resided in the fact that -- there were two objections as you stated them: One was that the ship would list to such an extent that it would be difficult to lower the lifeboats on the other side of the ship, and the other was that -
- The danger was of watertight doors in the bulkheads not working properly when coal was being trimmed through them.

Q. You agree with the testimony given by Mr. Peskett, the naval architect of the Cunard Company, which you heard at that investigation, to the effect that that difficulty of the listing of the ship could be corrected?
- In time. I admitted it in my evidence to the Commissioner.

Q. And the time depends upon the size of the bulkhead door, doesn't it?
- Not that, but the arrangement for flooding the other side of the ship.

Q. But you only have to open the bulkhead doors?
- Well, more than that; that is not all. It is a dangerous thing to do, to try and remedy such a defect by letting water into a much larger compartment than you already have it in.

Q. But with the longitudinal bulkhead the ship would stay afloat and you would not have to use the boats?
- As long as the damage is not extensive; until more water gets in. Temporarily the ship floats.

Q. By having longitudinal bulkheads you reduce the danger of sufficient water coming in to sink the ship?
- Coming in, undoubtedly.

Q. In not to sink the ship?
- But in time, and in a comparatively short time, it may get in.

Q. You mean if the bulkhead doors leak or if the bulkhead does not hold?
- If the bulkhead does not hold, or if for any other reason, owing to the list, the water might find some other way in besides the wound.

Q. But if the Titanic had been equipped with longitudinal bulkheads like the Mauretania, and had the same wound that she had at this particular time, she wouldn't have gone down, would she?
- I am afraid it would not have made any difference, because I believe -- as far as the calculations I was able to make, she would have turned turtle within a quarter of an hour.

Q. That is, so far as you were able to make any calculations?
- So far as I was able to make any calculations, I made the estimate.

Q. You testified before Lord Mersey, I think, that if an inner skin like the Olympic has now been fitted with had been in the Titanic she would not have sunk.
- I agree; but that is another point.

Q. So you think that an inner skin is preferable to longitudinal bulkheads?
- I do.

Q. And the only thing necessary to have put an inner skin into the Titanic you have found by practical experience with the Olympic, was merely an extension of the plan upon which she was originally built?
- Yes.

Q. Which includes merely putting in plates and the strengthening of the structural parts?
- It was not strengthening them, but modifying them.

Q. Modifying them to the extent of giving support to the inner skin?
- Yes, and taking out the web frames; the whole thing had to be renewed.

Q. You used the same web frames?
- No, there are no web frames on the Olympic now, but it was in the same line of the web frames. It was kept to the line of the web frames, but the web frames themselves were taken out.

Q. So that it was merely the structural chain necessary to hold the inner skin in place, that was necessary to be made?
- That is right.

Q. You didn't have to change the outside in any way?
- No.

Q. Or the height of the decks or the position of the decks or any of the bulkheads for the purpose of putting in the inner skin?
- No.

Q. It was a mere matter of addition and more adjustment, so to speak?
- A rearrangement.

Q. And with such an inner skin and such an injury it is still your opinion that the Titanic would be afloat today?
- I think so; I do not feel any doubt about it.

BY MR. BETTS:

Q. I don't know whether I made it clear in asking you the question whether the Olympic would now float if the six adjoining compartments were flooded, under her new arrangement -- whether that also included the forepeak tank, in speaking of those forawrd compartments?
- Yes, you mentioned that.

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