7 WHITEHALL GARDENS,

_London, S. W., April 16, 1912_.

SIR: With reference to your letter of the 4th July last respecting

certain questions raised in connection with the proposed revision of the

Life-Saving Appliances Rules, I am directed by the board of trade to

state, for the information of the advisory committee, that they have

given very careful consideration to the report of the life-saving

appliances subcommittee which was forwarded with your letter.

As regards the recommendations with reference to the proposed extension

of the table (appendix to the Life Saving Appliances Rules) showing the

minimum number of boats to be placed under davits, the board are glad to

observe that the committee agree that alterations and additions are now

necessary to meet the changed conditions due to recent developments in

the size of passenger steamships and in the number of persons which

these vessels can accommodate.

The board of trade note that the gradations of tonnage in the extension

of the scale suggested by the advisory committee are not the same as

those in the form of scale submitted to them by the board; while the

increase in the number of boats is not in the number to be placed under

davits, but in the number of additional boats required to be readily

available for attachments to davits. It is observed that the committee

hold the view that "it is questionable whether it is practicable to

increase the number of davits," and "that any increase in the number of

lifeboats to be carried can probably be best effected by providing for

the launching of further boats from the existing davits."

The board presume that, in arriving at these conclusions, the committee

have had regard to ships already built rather than to new ships, as they

see no reason why there would be any difficulty in having more than

eight pairs of davits on each side of the ship, provided that the

requirements of Life-Saving Appliances Rules were known before the plans

were prepared.

The board are of opinion that a very careful and thorough revision of

the table should now be made, and I am to transmit herewith a copy of a

memorandum and tables prepared by the professional advisor to the marine

department, containing a full and considered opinion on the subject of

the extension of the boat scale and cognate questions.

As regards the proposed amendment of the rules, so as to admit of decked

lifeboats of an approved type being stowed one above another, or under

an open lifeboat, I am to state that this question is now under

consideration, and a communication will be addressed to you shortly on

the subject.

With reference to the advisory committee's recommendation regarding the

amendment of rule 12 of the general rules, the board desire me to state

that the questions raised in the recommendation are of wide application

and of such importance that the board do not think that they can be

adequately considered except by a committee of equal standing to the

committee which reported in 1891 on the spacing and construction of

water-tight bulkheads in the mercantile marine. The board have the

question of the appointment of a committee under consideration.

In connection with the advisory committee's recommendation that the

depth of lifeboats shall not exceed 44 per cent. of their breadth, I am

to transmit herewith, for their consideration, a draft amendment of

rules Nos. 1, 2, and 3 of the general rules with reference to the

construction of ships' boats.

The board have made full inquiry into the question of the construction

of ships' boats, and obtained some useful information as to the average

depth of boat which is deemed desirable for safety and utility, and the

ratio of that depth to the breadth, and they attach so much importance

to this element of boat construction that they think it should receive

the careful attention of the committee. The board think that the

committee, in the light of this additional information, may reconsider

the opinions expressed on this point in their letter of July 4.

I am therefore to transmit herewith copies of memoranda by the

professional adviser to the marine department and the acting principal

ship surveyor.

The board desire me to state that they would be glad to be furnished

with the advisory committee's views as to the application of the

proposed new rules and boat scale, e. g., whether they should apply to

ships already built, and if so, to what extent. They regard it as of

great importance, on the one hand, that all British vessels should be

provided with a proper and sufficient equipment of life-saving

appliances, and, on the other, that regulations should not be enforced

without notice which would necessitate important structural alterations

and consequent heavy expense in vessels already built.

I am to add that in order to make the constitution of the committee,

when considering this question, agree with that of the statutory

life-saving appliances committee indicated in the seventeenth schedule

to the merchant shipping act, 1894, the board have followed the course

adopted on previous occasions, and have invited Lloyd's Register of

British and Foreign Shipping and the Institute of London Underwriters to

select a representative who will be available to sit on the advisory

committee when the question is under consideration.

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