a two-thirds majority vote of the assembly and of the Maritime Safety Committee. There is a specific prohibition against making structural amendments retroactive. Generally speaking, article IX provides machinery for the amendment of the convention as may be desirable but surrounds such machinery with safeguards against hasty or ill-considered changes or amendments prejudicial to the interests of the chief maritime states. A provision in article XV permits a conference to be called for amending the convention if IMCO is not in force.

The convention is to come into force on January 1, 1951, if, by January 1, 1950, 15 governments, including at least seven governments having not less than one million gross tons of shipping, have accepted it. Otherwise it will come in force one year after such 15 governments have deposited their acceptances. Article XV provides that the United Kingdom shall act as the bureau power in all matters except those dealt with in article IX until IMCO comes into force.

Chapter I of the regulations (appendix 2) contains the provisions of general applicability of the technical regulations including application, general definitions, general exceptions, special exemptions, and the acceptance of equivalents. Regulation 3 excepts from the general application of the regulations, unless provided otherwise, certain categories of ships to which the 1929 Convention extended. These are troopships, ships not propelled by mechanical means, yachts, and fishing vessels. In few instances would the provisions of the regulations apply to such craft in any case, In addition specific exception is made to vessels whose navigation is confined to the Great Lakes.

Regulation 4 permits exemption from requirements of the regulation in the case of ships making a single voyage under exceptional conditions. Regulation 5 provides for the acceptance of equivalent arrangements or appliances other than those specified in the regulations. In either case the Administration concerned must submit a report to IMCo.

Regulations 6 to 19 inclusive provide for the inspection and survey of ships subject to the convention and for the issue and acceptance of certificates as evidence of compliance with the applicable portions of the regulations. These 14 regulations generally follow the pattern laid down in the 1929 Convention, but additional certificates have been provided to take care of new requirements; a new provision allowing a period of one month's grace after the expiration of a certificate has been inserted; and there is a requirement that certificates other than exemption certificates shall be posted in the ship.

Regulation 18 has to do with the control which a government may exercise over a foreign vessel in its ports. Article 54 of the 1929 Convention dealt with this subject but was so ambiguously worded that the United States Senate, when ratifying that convention, was obliged to attach a reservation (the third) to its ratification. Regulation 18 as it is now drawn covers the intent and includes much of the language of this third reservation. In securing the adoption of the present regulation 18 the Delegation hopes that it has made any further reservation unnecessary.

Regulation 20 has no counterpart in the 1929 Convention. It specifically requires each government to conduct an investigation of any major marine casualty and to supply IMCO with pertinent information concerning such casualties, particularly so far as such information bears upon the operation of the safety regulations. This provision should result in the accumulation in a central body of data to which IMCO could turn when considering the desirability of future amendments to the regulations.

Chapter II deals with the construction of ships from the safety standpoint with special regard to the prevention or mitigation of casualties. (The load-line convention, of course, deals with the strength and seaworthiness of ships under normal operating conditions.)

The 1929 Convention contained a formula for the compartmentation of ships with a view to their retaining reserve buoyancy if damaged. This reserve buoyancy, however, did not take into account the stability of the ship in a damaged condition. The proposed convention requires that a vessel shall have an adequate stability under an assumed extent of structural damage. This requirement, taken in conjunction with a proposal to increase the minimum permissible length of a compartment, may lead to a better spacing of bulkheads and thus to a degree of improved subdivision.

The proposed convention considerably exceeds that of 1929 in its requirements for protection against fire. It authorizes three alternative approaches to the problem. The first is the essentially incombustible ship; the second depends upon an automatic sprinkler installation; and the third requires the extensive use of fire-retardant bulkheads together with the installation of a fire-protection system. The adoption of regulations setting forth definite requirements for defense against fire is one of the outstanding accomplishments of the Conference.

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Basic regulations are included dealing with those electrical installations on passenger ships which are essential for safety. This subject was not dealt with in 1929, but the increased use of electricity since that time made its consideration imperative.

In the 1929 Convention it was provided that passenger ships should be inclined upon their completion and the elements of their stability be made known to their operating personnel. The new convention extends this requirement to cargo ships of 500 gross tons and upwards. The convention also makes provision for fire-extinguishing appliances on cargo ships of 1,000 gross tons and upwards. The previous convention dealt in this respect with passenger ships only.

Chapter III deals with lifesaving appliances and emergency musters and drills. A most important advance beyond the 1929 standards in this direction is the extension of many requirements to cargo ships of 500 tons and upwards.

The definition of "short international voyage" is rewritten to include both length of voyage and distance off shore and a measure of increased boatage is required for ships on such voyages.

The new convention permits the use of lifeboats of Class I only, that is to say, boats with fully rigid hulls and internal buoyancy. The requirements as to motor lifeboats for smaller passenger ships and for cargo ships of over 1,600 gross tons are extended with the alternative use of hand-operated gear permissible. Radial or ram's-horn davits are prohibited except in ships under 150 feet in length.

Lifeboat equipment requirements have been increased in the light of lessons learned in the war. subject of technical improvement by the Radio Committee, while the Lifeboat radio installations have been the use of portable radio transmitters in lifeboats is so extended that there should always be at least one set in the boats of any ships subject to the convention.

All ships are required to carry means for effectively making distress signals by day or night, and the line-throwing apparatus heretofore required must now be capable of attaining a minimum range of 250 yards. The requirements as to musters and drills on board ship are increased and in certain directions are made applicable to cargo ships.

Chapter IV covers radiotelegraphy and radiotelephony. In certain of its applications chapter IV does not go as far as United States statutory requirements. However, it is unlikely that any appreciable number of foreign vessels will be relieved of compulsory radio installation on this

account.

The chapter requires cargo vessels of under 1,600 gross tons and over 500 gross tons to be equipped with a radiotelephone installation if not fitted with a radiotelegraph installation. In the 1929 Convention the minimum limit on cargo vessels was 1,600 gross tons, and there was then and is now no radiotelephone alternative for these larger ships. Chapter IV further provides for a greater degree of flexibility in permitting exemptions from radio in that the exemption is not necessarily related to specific mileage, may be partial or conditional, and must take into account the various conditions surrounding the particular voyage.

The requirements of the chapter as to listening on distress frequencies (except for cargo ships of less than 1,600 gross tons) involve advances as to the hours of operator-listening and as to the installation and operation of auto alarms. The new provisions substantially increase the possibility of distress messages being promptly picked up by foreign ships. Statutory requirements for United States telegraph-equipped ships already are more stringent and need not be changed.

The technical requirements as to radiotelegraph installations both on board ship and for use in lifeboats represent substantial advance over those which were contained in the 1929 Convention. The technical requirements for new types of auto alarms represent a marked advance over even our present national standards. Because of this and in recognition of practical procurement problems appropriate delay clauses are included.

The necessary changes in the requirements as to surveys and as to certificates have been made to suit the new provisions. A certificate called a safety radiotelephony certificate is established to cover the small cargo craft and conditionally exempted ships equipped with radiotelephone only. Provisions have been made so that the distress frequencies to which reference is made in the new convention shall follow any future requirements adopted by the International Telecommunication Union.

Chapter V deals with safety of navigation, under which broad term a number of requirements chiefly of an operational nature are included. The chapter generally applies to all ships on all voyages, including those specifically excepted by chapter I, saving only men-of-war.

The provisions in regard to meteorological services have been rearranged and expanded to take into account the recommendations of the International Meteorological Organization. The requirements as to the International Ice Patrol have been generally continued with provision being made for a simpler and more flexible method of distributing the costs of this patrol. In this connection, regardless of the existence

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of IMCO or, alternatively, the use of the United Kingdom as a bureau power, the United States will deal directly with other interested governments in matters concerning the ice patrol.

The question of revising the regulations for the prevention of collisions at sea was exhaustively studied by the Conference and agreement was arrived at as to certain improvements. These proposed regulations are contained in the final act and will be brought into force by national legislation when a substantial degree of unanimity among maritime nations has been reached as to their adoption.

The procedures covered by article 45 of the 1929 Convention have been modified to take into account the increased range of marine radio installations and to extend rescue provisions to aircraft or survival craft. The proposed regulations adequately provide for the securing of assistance from other vessels but are designed to avoid interfering unduly with ships not needed for the rendering of assistance.

The requirement of direction finders on board ship has been extended to all ships of 5,000 gross tons and upwards, as compared to passenger ships only of 5,000 gross tons and upwards as the 1929 Convention required. Exemption may be allowed in the case of vessels operating in regions where there are few or no radio beacons, but the value of the direction finder from the rescue standpoint must be taken into account. In this connection a new regulation requires governments to set up such aids to navigation, including electronic aids, as the volume of traffic along their coasts and the degree of risk demand. Similarly, a new regulation requires each government to maintain adequate rescue equipment along its coasts.

Another new regulation provides for a simplified and efficient system of signals between a stranded vessel and a rescue party on shore. This system is easily understood and involves no elaborate equipment on the vessel. A regulation covering safe pilot ladders is included to make the boarding of ships in open waters less hazardous.

Chapter VI deals with the carriage of dangerous cargoes, that is to say cargoes which are dangerous either from their inherent nature or from their liability to shift at sea. It was generally agreed at the Conference that sufficient time was not available for an extensive study of this subject. Nevertheless certain basic principles were written into the regulations, and a recommendation was made that further study should be given to the matter by IMCO. Specifically, the subject of grain cargoes is dealt with in some detail and requirements for adequate shifting boards are