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A. During the inspection, however, it was found that the
causes of the loss were improper and negligent stowage
of the cargo;
C. I don't see how it can be proved. We did our best
to fulfil contract obligations and to deliver the cargo
in undamaged condition.
A. I have looked through both your Sea Protest and the
inspection report and I'd like to ask you a few
questions.
C. I'm at your service, Mr Adams.
A. The cargo you had loaded for delivery at our port was
a delicate one and required special caution in stowing.
How was it actually stowed?
C. As you know the cargo consisted of 390 cases of sheet
glass and had a total gross weight in excess of 200 tons
A. What cargo compartment were they placed in?
C. We stowed them in the forward portion of the lower
tween deck that is forward of the hatch, of hold No 5.
A. Why was the particular space chosen for the subject
cargo?
C. The reasons for this decision were because the said
portion was closer to the "tipping centre" of the vessel,
and, because it was a lower deck, the arc of the roll of
the vessel would be lessened.
A. It sounds quite convincing - but you could have found a
safer portion of the hold to stow the glass, No 5
lower hold, for example. It's common knowledge, that
the lower the cargo is situated, the lower the swinging
arc would be.
C. That's right, but there was already some other fragile
cargo stowed there.