In order to investigate ship structural response in ocean waves, various wave loads (hydropressure, inertia force, vertical bending moment, etc.) should be taken into consideration, including effects of phase differences between themselves. The 1 st report1), one of approaches to the above-mentioned, deals with confirmation of accuracy of estimation method on wave load (focusing on phase differences between wave load components), development of “DIScrete Analysis Method (DISAM for short)” based on 3-D FEM and investigation on structural response of double bottom for midsh if) part in ocean waves. As the continuation of the 1 st report, this paper deals with investigation on structural response of double bottom in ocean waves from wider point of view, and the following results are obtained : 1) For fore and aft part, in spite of increase in inertia force, stress level is low in comparison with midship part. This phenomena is considered as the effects of the following : (a) Difference of section shape between fore/aft part and midship part. (b) Cancellation of various wave load components. 2) Correlation between stress in different directions has the following tendency. (a) For bottom plate and inner bottom plate, longitudinal and transverse stresses have almost the same phase ; therefore, the maximum values of them arise at almost the same time. (b) For girder, the large phase difference between longitudinal and shear stress is expected ; therefore, the above two components do not have the maximum value at the same time.