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The SECRETARY,

_Merchant Shipping Advisory Committee_.

BOARD OF TRADE, MARINE DEPARTMENT,

7, WHITEHALL GARDENS,

_London, S. W., April 25, 1912_.

SIR: With reference to previous correspondence respecting the proposed revision of the statutory regulations as to boats and life-saving appliances on ships, I am directed by the board of trade to state, for the information of the merchant shipping advisory committee, that, apart from the questions which have been raised regarding the boat accommodation on vessels over 10,000 tons, it seems desirable to consider whether the provision of boats and other life-saving appliances required by the rules in the case of vessels under 10,000 tons is satisfactory, or whether the rules or the boat scale should be altered in respect of their application to such vessels; and the board would be glad to be favored with the observations of the committee on this point in addition to those that have already been referred to them.

I am, etc.,

WALTER J. HOWELL.

The SECRETARY,

_Merchant Shipping Advisory Committee_.

To these letters the advisory committee sent the following answer:

MERCHANT SHIPPING ADVISORY COMMITTEE,

7, WHITEHALL GARDENS,

_London, S. W., April 27, 1912_.

SIR: We are desired by the merchant shipping advisory committee to inform you that your letters of the 16th, 20th, 24th, and 25th instant were brought before the committee at a meeting held yesterday.

The committee fully recognize that the proved impossibility of keeping such a vessel as the _Titanic_ afloat after a collision with ice until the arrival of outside succor has created an entirely new situation which was neither in the contemplation of the board of trade nor of the committee in the consideration of the extension of the existing boat scale in regard to vessels of 10,000 tons and upward.

In advising on such extension in July last, the committee aimed at providing ample boat accommodation on large passenger vessels in accordance with the principles that were adopted by the original life-saving appliances committee, and which principles had apparently been fully justified by many years of experience. It is with satisfaction that the committee note that the board of trade, apart from the new possibilities demonstrated by the loss of the _Titanic_, agreed in the essentials with the recommendation of the committee.

In face of the new facts, the committee at their meeting yesterday reopened entirely the question of the revision of the boat scale for large passenger vessels with a view of providing the maximum of protection for the passengers and crew in the event of an overwhelming disaster, whilst at the same time maintaining the principles in regard to the stability and sea-going qualities of the ship itself, and to the prompt and efficient handling of the boats carried under the existing scale, which hitherto have proved not only essential to safety, but also adequate for all ordinary emergencies. The questions involved are not free from difficulty, but they will receive the immediate attention of the committee. Pending their consideration, the committee note that assurances have been received by the board of trade from representatives of most of the large passenger lines to the effect that every effort will be made to equip their vessels, at the earliest possible moment, with boats and rafts sufficient to accommodate all persons on board.

In regard to the recommendation forwarded with the committee's letter of July 4 last, that the board of trade should, having regard to the developments in ship building since the report of the committee of 1891 on spacing and construction of water-tight bulkheads, review the requirements designed to attain the standards at present enforced under rule 12, the advisory committee note that the board of trade have under consideration the appointment of a committee of equal standing to that of the committee of 1891. In view of the great importance of this question the advisory committee desire us respectfully to urge that such a committee be appointed at as early a date as possible.

The subject of the general revision of the statutory regulations as to boats and life-saving appliances on all ships, which, apart from the questions regarding the boat accommodation on vessels over 10,000 tons, is for the first time referred to the advisory committee by the letter of the 25th instant, together with the particular questions raised in the letters of the 16th, 20th, and 24th instant, are also receiving the immediate attention of the committee.

At yesterday's meeting subcommittees were appointed to give immediate consideration to the subjects requiring detailed examination. These subcommittees will pursue their inquiries concurrently, and we are desired by the advisory committee to inform you that their investigation into the revision of the life-saving appliances rules will be proceeded with as expeditiously as possible.

We are, etc.,

NORMAN HILL, _Chairman_.

R. W. MATTHEW, _Secretary_.

Sir WALTER J. HOWELL, K. C. B.,

_Assistant Secretary Marine Department,

Board of Trade_.

This letter was acknowledged by the board of trade on May 10, 1912, as follows:

BOARD OF TRADE, MARINE DEPARTMENT,

7, WHITEHALL GARDENS,

_London, S. W., May 10, 1912_.

SIR: I am directed by the board of trade to acknowledge the receipt of, and to thank you for, your letter of April 27, stating that their letters of April 16, 20, 24, and 25 have been considered by the merchant shipping advisory committee.

The board observes with satisfaction that, in view of the entirely new situation which has arisen, the advisory committee have decided to reopen the question of the revision of the table in the life-saving appliances rules in so far as it governs the boat accommodation in vessels over 10,000 tons gross. The board are further glad to observe that the question of a general revision of the life-saving appliances rules is also under consideration by the committee, and in this connection they presume that, in considering the question of a general revision of the rules including the table, the committee will consider the principles on which the requirements as to boat accommodation should be based, including, inter alia, whether the table should continue to be based on tonnage. Any conclusion reached by the committee on this question would naturally affect the revision of the present table as applying to vessels of more than 10,000 tons, upon which the committee has already been engaged.

The board agree with the view expressed by the advisory committee that the appointment of another committee on the spacing and construction of water-tight bulkheads is desirable. Steps have already been taken by the president to form such a committee, and he hopes to be able to announce the names within a few days. A further communication on this point will be addressed to the committee in the course of a few days.

The board are glad to note that subcommittees have been appointed to deal concurrently with the subjects requiring detailed consideration in connection with the revision of the life-saving appliances rules.

The board desire me to add that they assume that the committee, in considering the matters referred to them, will have regard to all important aspects of the question of life-saving appliances, whether expressly dealt with in the statutory rules or not, and in particular to the essential question of the adequacy of the provision for lowering and manning the boats and rafts carried by vessels.

I am, etc., WALTER J. HOWELL.

The SECRETARY,

_Merchant Shipping Advisory Committee,

7, Whitehall Gardens, S. W._

This finishes the history of the action of the board of trade in relation to the provision of boat accommodation on emigrant ships. The outstanding circumstance in it is the omission, during so many years, to revise the rules of 1894 and this, I think, was blameable, notwithstanding the excuse or explanation put forward by Sir Alfred Chalmers. I am, however, doubtful whether even if the rules had been revised the change would have been such as to have required boat accommodation which would have increased the number of lives saved.

Having regard to the recommendations of the advisory committee, the board of trade would probably not have felt justified in making rules which would have required more boat accommodation than that with which the _Titanic_ was actually provided; and it is not to be forgotten that the _Titanic_ boat accommodation was utilized to less than two-thirds of its capacity. These considerations, however, afford no excuse for the delay of the board of trade.

The gross tonnage of a vessel is not, in my opinion, a satisfactory basis on which to calculate the provision of boat accommodation.

Hitherto, I believe, it has been accepted as the best basis by all nations. But there seems much more to be said in favor of making the number of lives carried the basis and for providing boat or raft accommodation for all on board. Rule 12 of the life-saving appliances rules of 1902, which deals with water-tight compartments and boat accommodation, ought to be abolished. The provision of such compartments is of supreme importance, but it is clear that it should not be sought at the expense of a decrease in boat accommodation. When naval architects have devised practical means for rendering ships unsinkable, the question of boat accommodation may have to be reconsidered, but until that time arrives boat accommodation should, where practicable, be carried for all on board. This suggestion may be thought by some to be extravagant. It has never been enforced in the mercantile marine of Great Britain, nor as far as I know in that of any foreign nation. But it appears, nevertheless, to be admitted by all that it is possible without undue inconvenience or undue interference with commerce to increase considerably in many cases the accommodation hitherto carried, and it seems, therefore, reasonable that the law should require an increase to be made. As far as foreign-going passenger and emigrant steamships are concerned, I am of opinion that, unless justification be shown for deviating from this course, such ships should carry boats or rafts for all on board.

With reference to the second branch of the complaint against the board of trade, namely that their officials had failed to exercise due care in the supervision of the vessel's plans and in the inspection of the work done upon her, the charges broke down. Suggestions were made that the board's requirements fell short of those of Lloyd's Registry; but no evidence was forthcoming to support the suggestions. The investigation of the charges took much time, but it only served to show that the officials had discharged their duties carefully and well.

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