deal with this last-named subject. Such safety depends first on the structure of the hull of the ship and on its machinery; second, on the depth to which the ship can be loaded with safety according to its voyage; third, the lifeboats and other life-saving equipment, for use in event of collision, fire, or other casualty, including of late years wireless apparatus; and fourth, the qualifications and numbers of the officers and crew required to navigate the ship. Under ordinary conditions the structure of a carefully and skillfully built ship does not change appreciably for several years, while some of the officers and more of the crew are likely to change with every voyage and the life-saving equipment must be replenished or renewed at somewhat frequent intervals.

Marine insurance antedates by centuries the active concern of Governments with the elements of safety in navigation just recited, and to merchant shipping and trade by sea compliance with its requirements is as essential as compliance with the requirements of Governments. To meet these requirements the great ship classification societies were established during the last century, of which the British Lloyds' Register is the oldest and most widely known, and the reorganized American Bureau of Shipping the recognized institution of the United States. These classification societies maintain corps of trained naval architects, marine engineers, and surveyors to establish technical rules of construction, to see that they are complied with during the building of the ship and by survey after a casualty to determine the necessary repairs to restore seaworthiness, or from time to time to make surveys in view of depreciation. Upon the classification of a ship by one of these societies the rate of insurance of the ship depends in large measure, and this is equally true of American and British ocean cargo steamers as well as of those under other flags.

The difference between the American and the British application of the principle that the State should concern itself with the safety of the ocean cargo steamer lies in the fact that, so far as the construction of the hull and machinery is concerned, the United Kingdom relies mainly on compliance with the rules of Lloyds' or the British Corporation or other recognized classification societies whose surveyors superintend the construction of the ships. On the other hand, the Government of the United States requires annual inspection by Federal inspectors, although the American shipowner, like the British or Norwegian, is in large measure dependent for his marine insurance upon the classification of his ship by the American Bureau of Shipping, Lloyds' Register, or the Norske Veritas, as the case may be. It is no disparagement to worthy men in the Steamboat-Inspection Service to state that they do not have, as a rule, the technical knowledge required to frame rules for construction of hulls, nor do they

have the time, in view of other work, to supervise the actual application of the rules during the building of ships, and the salaries paid. and appropriations voted are insufficient to secure the number and kind of men required. The owner of the American cargo steamer, accordingly, is subject to regulation by the classification society, corresponding to the British shipowner's regulation, and in addition to the annual inspections of the Steamboat-Inspection Service. The Federal Government, to be sure, makes no money charge for this inspection, but occurring at fixed dates every year the annual inspection (except on the Great Lakes where the close of navigation by ice changes conditions somewhat) can not fail frequently to withdraw a ship for a time from profitable occupation. It may be said in explanation of the dual system of hull inspection in the United States that until recently there was no American classification society recognized as competent to perform for American shipping the services performed for British shipping by Lloyds' Society, but it is hard to see how such a society could have been established and maintained while the Government was maintaining its own system of inspection. It would tend to create more even conditions of competition in foreign trade if these two systems of hull inspection should not continue to run parallel. My predecessor seems to have taken the same view in recommending that the Steamboat-Inspection Service be intrusted with the work of classification of ships, which would involve a large increase in the number of the personnel and considerably higher technical attainments, and would end the American classification society. Much might be said for this recommendation if the American merchant marine were to continue under Government ownership and operation. The aim, however, is to restore our merchant shipping to private ownership and operation as rapidly as possible, and every private instrumentality needed for the successful operation of such a merchant marine should be developed. The recasting of our inspection laws along these lines in order to secure. more even conditions of international competition is recommended.

LOAD LINE.

While we have a dual system for the inspection of the hulls of ocean cargo steamers, we have no statutory regulation whatever of the load which such steamers can carry with safety, though for obvious reason such regulation for many years has been in force on British, Norwegian, and other foreign ships and a law upon the subject was passed this year by the Japanese Parliament. In ports of these nations, accordingly, American ships must be marked with load lines according to the load-line law of the port, all of which, however, are based on British freeboard tables and agree substan

tially with British law. The structure and dimensions of the hull of the cargo steamer, of course, determine generally the amount of cargo it can carry safely, though this varies somewhat with the season of the year and the waters to be traversed. The marking of load lines, accordingy, is intrusted to the classification societies, subject to approval of Government authorities. To meet the embarrassments caused to American shipping by the lack of load-line legislation, an informal arrangement was made in 1919 with the authorities of the United Kingdom by which load lines marked by the American Bureau of Shipping according to British freeboard tables and rules are recognized temporarily. This arrangement, of course, can not be maintained indefinitely, and the enactment of a load-line law, which the growth of our fleet of ocean cargo steamers in foreign trade made necessary two years ago, is again recommended and, indeed, is essential to the modification of the inspection system just outlined. The enactment of the load-line bill will require the creation of a small technical staff in the Department.

OCEAN PASSENGER STEAMERS.

One of the most valuable results of the International Conference on Safety of Life at Sea, held in London in 1913-14, following the loss of the S. S. Titanic, was an agreement among maritime nations on the general rules which should govern the subdivision of hulls of ocean passenger steamers, carrying often several thousand passengers. The Senate of the United States ratified the international convention but with a reservation which has delayed the proclamation of the convention and its transmission. In the meantime Great Britain, France, and other Powers ratified it and have taken preliminary steps toward its execution. Some modifications of the proposed rules concerning subdivision of hulls of passenger ships have been found desirable in view of the experience gained from the terrible loss of life through the sinking of many passenger ships by submarine warfare, directed particularly against such ships and subjecting their hulls to every form of strain through the explosion of torpedoes. Informal conversations on desirable changes in the rules framed in 1913-14 have been held, and preparation should be made for participation by the United States in the final discussion of the rules and for their administration in this country, because the possession of a large merchant fleet by the United States entails responsibilities, for the discharge of which we are thus far provided with inadequate administrative personnel.

The faster ocean passenger steamers carry the mails and are adaptable to service as troop transports or auxiliary cruisers, and the war showed how indispensable they are to a maritime nation.

For these services to Government, actual or prospective, most of them under foreign flags operate under mail subsidy contracts with their respective Governments. The merchant marine act, 1920, in sections 7 and 24 authorized such contracts with American ocean passenger steamship lines, subject only to the amount of the appropriations which Congress may see fit to vote for these essentially national purposes.

RADIO COMMUNICATION.

The regulation of radio communication has become a matter of increasing intricacy and difficulty owing to the rapid development of the art during the war and since its close and to new purposes to which it is being applied. Our own legislation of 1910 and 1912 and the international radiotelegraph convention of 1912 were framed almost entirely for the purpose of securing radiotelegraphic communication with the least practicable interference between ships at sea and the coast, or between ships at sea with one another. The legislation and the international convention have been reasonably successful in accomplishing that purpose, but both, especially the convention, contain technical restraints, proper enough at the time, but now rendered obsolete by recent scientific developments and improvements in methods and apparatus. Of even greater present interest, however, is the development of radio communication across the ocean between continents by high-powered stations, and the increasing use of wireless communication between stations on the land, where it is supplementing the communication hitherto maintained by telegraph and telephone wires. The radio telephone must be recognized as an established fact, though yet in its infancy.

The only justification for Federal regulation of radio communication lies in the fact that no such communication at all would be possible unless some authority determined the power and wave lengths to be employed by different stations and classes of stations in order to prevent mutual interference with the transmission and reception of messages. Invention has already done much to reduce such interference and will doubtless do more, but interference is still the important factor to be considered from the point of view of the practical use to-day of this indispensable means of communication.

For obvious reasons the basic regulation of radio communication must be international, and for this and other reasons the Department has not urged consideration of a bill submitted to Congress early in the summer to bring the act of 1912 to regulate radio communication more into accord with present requirements. The preliminary conference at Washington on electrical communications, attended in the autumn of 1920 by representatives of the United States,

Great Britain, France, Italy, and Japan, prepared the draft of an international convention on electrical communication by telegraph, telephone, and radio, and the portions relative to radio communication have been under review during the summer by an international technical committee, the American membership of which included competent representatives of the Department. The preliminary work for the revision of the international regulation of radio communication is thus fairly well in hand. It may be best, therefore, to await the submission to the Senate of the revised international convention before considering the bill to change our own laws, although that bill was drawn so as to be readily adaptable in administration to the changes probable in the convention. If, however, a convention shall be submitted and ratified, bringing our telegraph and telephone systems, as well as radio communication, within international regulations, a change in the method of administration in this country will be necessary. The Department of Commerce, as the department administering shipping laws generally, was naturally charged with the administration of the radio legislation of 1910 and 1912 through the Bureau of Navigation. Its radio inspection service is confined to the seaboard and the Great Lakes for which the small annual appropriation, $80,000, scantily provides. As already pointed out, the present development of radio communication is over the land or between distant continents. A force of inland inspectors must soon be provided in any event, and if the United States is also to exercise any measure of supervision under international rules over telegraphs and telephones, all necessary regulation of electrical com. munications could properly be administered by the Post Office De partment which is already represented even in remote hamlets.

The act of June 24, 1910, requiring wireless apparatus and operators on all ships carrying 50 or more persons has been adopted in substance by all the principal maritime nations and the amendment in 1912 to that act, requiring a continuous wireless watch, was incorporated in the International Convention for Safety of Life at Sea of 1914.

The British law of 1912 requires all ships of 1,600 gross tons or over to be equipped with wireless apparatus and operators. Nearly all such American ships not already subject to the act of 1910 are owned by the Shipping Board, which voluntarily equips them with wireless apparatus and operators, so that there is no immediate need of considering an amendment in this respect of the act of 1910. The continuous watch under the American law is maintained by two licensed operators; under the British law by one licensed operator and two watchers, trained to receive elementary signals and messages but not skilled in sending them. Our own system is preferable.