I considered the matter very closely from time to time. I first of all considered the record of the trade—that is to say, the record of the casualties—and to see what immunity from loss there was. I found it was the safest mode of travel in the world, and I thought it was neither right nor the duty of a state department to impose regulations upon that mode of travel as long as the record was a clean one. Secondly, I found that as ships grew bigger there were such improvements made in their construction that they were stronger and better ships, both from the point of view of water-tight compartments and also absolute strength, and I considered that that was the road along which the shipowners were going to travel, and that they should not be interfered with. I then went to the maximum that is down in the table, 16 boats and upward, together with the supplementary boats, and I considered from my experience that that was the maximum number that could be rapidly dealt with at sea and that could be safely housed without incumbering the vessel's decks unduly. In the next place I considered that the traffic was very safe on account of the routes, the definite routes being agreed upon by the different companies, which tended to lessen the risk of collision and to avoid ice and fog. Then again, there was the question of wireless telegraphy, which had already come into force on board of these passenger ships. I was seized of the fact that in July, 1901, the Lucania had been fitted with wireless telegraphy, and the Cunard Line generally fitted it during that year to all their ships. The Allan Line fitted it in 1902, and I am not sure that in 1904 it had not become quite general on the trans-Atlantic ships. That, of course, entered into my consideration as well. Then another point was the manning. It was quite evident to me that if you went on crowding the ships with boats you would require a crew which were not required otherwise for the safe navigation of the ship, or for the proper upkeep of the ship, but you are providing a crew which would be carried uselessly across the ocean, that never would be required to man the boats. Then the last point, and not the least, was this, that the voluntary action of the owners was carrying them beyond the requirements of our scale, and when voluntary action on the part of shipowners is doing that, I think that any state department should hold its hand before it steps in to make a hard and fast scale for that particular type of shipping. I considered that that scale fitted all sizes of ships that were then afloat, and I did not consider it necessary to increase it, and that was my advice to Sir Walter Howell.

I appreciate this explanation, and I think there is much force in it. At the same time, it seems to me that it does not justify the delay. Even taking all these matters into consideration, it can not be that the provision for boat accommodation made in 1894 for vessels of 10,000 tons and upward remained sufficient to 1910, when vessels of 45,000 tons were being built. Two considerations demonstrate this. The first is that some shipowners recognized the insufficiency of the requirements of the board of trade, and voluntarily exceeded those requirements by providing larger boat accommodation than the old rules and table exacted. The second is that shortly before Sir Alfred Chalmers left the board of trade, the board had begun to direct attention to the amending of their rules in this connection.

It appears that in November, 1910, a question was asked in the House of Commons as to whether the attention of the president of the board of trade had been called to the fact that the Olympic, a sister ship of the Titanic, was provided with 14 lifeboats only. The answer given was that the Olympic (which was then in course of construction) would carry 14 lifeboats and two ordinary boats of an aggregate capacity of 9,752 cubic feet, which was in excess of the requirements of the statutory rules. On February 15, 1911, a further question was asked as to the date of the last regulations, and whether, having regard to the increased tonnage of modern ships, the desirability of revising the regulations would be considered by the board of trade. The answer by the president was:

Those regulations were last revised in 1894. The question of their further revision is engaging the serious attention of the board of trade, and I have decided to refer the matter to the merchant shipping advisory committee for consideration and advice.

Three days afterwards, namely, on February 18, 1911, a circular letter was sent out by the board of trade to the board's principal officers at Liverpool, London, and Glasgow asking each of those gentlemen to draft such an extension of the existing boat scale as he might think satisfactory and reasonable for the conditions of large passenger steamers. This circular letter was answered by the principal officer in Glasgow (Mr. Harris) on February 24, 1911, by the principal officer in London (Mr. Park) on February 27, 1911, and by the principal officer in Liverpool (Mr. Young) on March 3, 1911. It is sufficient to say of these answers that they all suggested a large extension of the statutory requirements.

Meanwhile, namely, on February 28, 1911, Mr. Archer, the board of trade's principal ship surveyor, had also drawn up a scale. This was a more exacting scale than that of any of the three principal officers. By his scale a vessel of the tonnage of the Titanic would have had to carry boat accommodation equivalent to at least 24,937 cubic feet, which would have been sufficient to hold all and more than all the persons who were on board at the time of the disaster (2,201). It would not, however, have been nearly sufficient to have held all that the vessel might lawfully have carried, viz, 3,547, and it is to be observed with reference to Mr. Archer's scale that in it he suggests an extension of rule 12, by which (if the vessel were divided into efficient water-tight compartments) the total boat accommodation might be reduced much more than rule 12 as it stands would permit. If this reduction be taken into account, the boat accommodation would fall so that it would be sufficient only for 1,750 persons. Mr. Archer's view was that shipowners should be encouraged to increase the floatability of the ships they built, and that the way to encourage them was to relax the legal requirements as to boats as their plans advanced in that direction. The great object was so to build the ship that in the event of a disaster she would be her own lifeboat.[4]

Having obtained these four reports, the board of trade, on April 4, 1911, submitted the matter to their advisory committee, and obtained the committee's report on July 4, 1911. The following are copies (with omissions of immaterial passages) of the board of trade's letter of April 4, 1911, and of the advisory committee's report of July 4, 1911:

Board of Trade, Marine Department,
7 Whitehall Gardens,
London, SW., April 4, 1911.

SIR: I am directed by the board of trade to inclose herewith, for the information of the merchant shipping advisory committee, a copy of a question asked in the House of Commons on February 15 and of the answer given by the president of the board of trade with reference to the life-saving appliances rules made under section 427 of the merchant shipping act, 1894.

The board are of opinion that the table in the appendix to the rules should be extended upward in the form indicated in the accompanying scale, so as to provide for vessels of tonnage up to 50,000 tons gross and upward.