Arconic Evidence - Monday 22nd February 2021 (1/2)

22 February 2021 · Mr Schmidt (Arconic), Mr Millett QC (Counsel to the Inquiry) · 3:03:25
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Examination of Arconic witness Mr Schmidt regarding knowledge of PE panel flammability, marketing practices, and failure to update fire classifications

Key moments

Full transcript

00:00:11 good morning everyone welcome to today's hearing as always i'm here

00:00:16 here with my fellow panel members uh mysterio estefan and mr ali akbar good morning good morning everyone

00:00:27 good morning good morning everyone now today we're going to continue hearing evidence from mr schmidt of iconic so the first task is to make sure that our interpreters are with us and can see and

00:00:39 interpreters are with us and can see and hear

00:00:40 hear what they need to so interpreters are you there we're both here and we can both see and hear you thank you very much good good morning good morning and uh next of course i have to make

00:00:51 and uh next of course i have to make sure that mr schmidt is there and he can hear us and see us

00:00:57 hello good morning mr schmidt

00:01:00 good morning good morning

00:01:05 i can hear and see you good thank you very much

00:01:08 very much now um essentially we shall carry on in the way that we were taking your evidence last week but um i think probably the first thing i ought to do is just run through the usual

00:01:21 to do is just run through the usual housekeeping matters with you so would you mind confirming please that you're alone in the room from which you're giving evidence

00:01:38 uh yes i confirm thank you can you confirm that you have no documents or other materials with you confirmed

00:01:52 yes i confirm thank you very much and can you also confirm that your mobile phone is in another room and that you don't have any uh other electronic device with you which is capable of receiving messages

00:02:18 thank you very much well as i said the procedure will be the same as it was last week

00:02:23 last week uh we shall have a break during the morning at around about 11 15 and in the afternoon um is there anything you'd like to raise with me or ask before we carry

00:02:48 i think no no good thank you very much well in that case i'll invite mr millet to continue putting some questions to you when you're ready mr millet

00:02:59 when you're ready mr millet merci beaucoup

00:03:06 good morning mr chairman good morning good morning members of the panel and good morning mr schmidt

00:03:15 on thursday i asked you about a meeting between claude verlais and frank ritter 3a luca bond in freiburg in june 2011.

00:03:30 uh

00:04:09 53158 underscore p04 page 27 in the english this is claude verlais exhibit part 4 page 27. in the english

00:04:20 exhibit part 4 page 27. in the english and in the french please uh met 3053158 underscore p04 page 24.

00:04:34 you follow in the french while i read the english this is an email of the 30th of june 2011 at 9

00:04:43 2011 at 9 20 from claude verlet to gee shydecker

00:04:54 another he says we should be able to meet as soon as possible for a half-hour meeting about the fire tests carried out on the reino bong pe

00:05:05 bong pe in cassettes in 2008 at a meeting i stated that pe was in danger of becoming

00:05:11 becoming or for architecture in western europe in 2011 we're not there yet but almost there the classification obtained for the renault bomb pe cassettes is the

00:05:23 for the renault bomb pe cassettes is the same as that of the competitors i.e f and therefore not suitable for use on building facades m4 in france for example a meeting before tuesday if possible

00:05:35 before tuesday if possible would be good because that's the day i see f ritter in fribolo to talk about it now my question having shown you that document mr schmidt is if guy shy decker was

00:05:47 schmidt is if guy shy decker was in gishai decker was informed that claude verlet was meeting with 3a do you agree that it is likely that you would have known about that meeting as well

00:06:04 so

00:06:20 no not necessarily can we go to

00:06:26 fet3053158 underscore p04 page 34 please this is claude verle's exhibit but there is no uh

00:06:35 is no uh french version of this the original is in german

00:06:38 in german and that for those who want to see it is at page 31 but i don't want to go to it um english please and i'll ask madame translator please to translate this is an email from claude

00:06:49 translate this is an email from claude valet to peter frelich as you can see on the 8th of july 2011 subject visits ce marking freiburg

00:07:00 subject visits ce marking freiburg and he says uh peter i need to show that to gsc cs and rq on thursday can you please send me your comments

00:07:10 comments thanks claude and at the next page if we just go down to page 35

00:07:18 page 35 i'm sorry i'll stop there and get it translated

00:07:28 into

00:07:55 and if you look at the attachments you can see that there's a visit report and please go to the next page page 35 where we can see what's attached and there it is that's the visit report we looked at last week

00:08:10 visited

00:08:19 can we go back to the previous page of the email please where claude verle says i need to show that to gsc stroke cs and

00:08:31 i need to show that to gsc stroke cs and rq on tuesday can i ask you is gsc gee shy decker

00:08:53 lq is that laura kikivez there's written r.q

00:09:06 it's robert quatrocky my mistake and thank you does this email tell us that the visit report of the meeting in fryeburg was shown to you

00:09:20 know

00:09:27 [Music]

00:09:35 anyway i don't remember it

00:09:39 now you told us on thursday that you believe that products with the french classification m1 could be used on a facade

00:10:02 page 82 lines 23-24 for our purposes uh we saw in the email just now and we can go back to it if you like uh perhaps we should um in the french

00:10:15 uh perhaps we should um in the french met

00:10:17 met 158 page 24. this is the same sorry this is the same email run

00:10:25 email run as we were in this one here we have all the screen coming up

00:10:44 uh looking at the paragraph uh that starts in the middle of the classification obtained

00:10:52 obtained or in french la clasma can you see that la france look says the classification obtained for the reynobond pe cassettes

00:11:03 obtained for the reynobond pe cassettes is the same as that of the competitors ief and therefore not suitable for use on building facades m4 in france for example

00:11:12 example how

00:11:26 um

00:11:44 [Music]

00:11:51 p55 was classified m1 throughout its existence at least to my knowledge would you agree that you were wrong when you said or if you said that a club or f product uh

00:12:04 that a club or f product uh could be used on building facades

00:12:22 i don't believe that i said that would you agree with me that's to be to be clear then that a class e or f product could not be used on a building facade

00:12:36 class

00:12:50 do you agree that the 2011 european classification test for reyno bond pe cassette

00:12:58 cassette demonstrated that reynobon 55pe in cassette form was unsuitable for use on facades of high-rise buildings

00:13:17 from cassettes

00:13:32 you

00:13:44 [Music]

00:13:48 no i didn't confirm that either i think it depended on the regulations and as i don't know all the regulations i can't confirm that how could how could reynabon pe in cassette form

00:13:59 cassette form which obtained an f classification in the european tests be safe for use on any facade

00:14:10 okay

00:14:14 european

00:14:35 [Music]

00:14:54 [Music]

00:15:10 well the risk control can be carried out in different ways on a facade i already mentioned that last week depending on the product used in the system different countries in europe address the risk in different in

00:15:21 address the risk in different in different ways

00:15:25 do you agree with me that reynaud pe in cassette form should never be used or should never have been promoted by arconic for use on facades of high-rise buildings

00:15:36 facades of high-rise buildings whether or not the european standards 13501 applied in a particular country

00:15:52 for a

00:16:06 foreign

00:16:16 could i hear the question once again do you agree with me that reynabon pe in cassette form should never have been used or promoted for use by arconic on facades of high rise build whether or

00:16:29 on facades of high rise build whether or not

00:16:30 not the european standards 13501 applied in a particular country

00:17:16 foreign

00:17:26 i'm sorry i still don't understand the question a different way much more simply is

00:17:34 55 pe in cassette form gets a european f how would it be safe to use at height anywhere

00:17:42 anywhere sea by san francisco

00:17:59 specialist

00:18:05 [Music]

00:18:20 [Music]

00:18:26 specialist of facades all for sale systems but once again i think controlling risks and choosing the right materials

00:18:32 materials uh even this kind of product could be used can we go back to the email please in the french

00:18:56 that the classification f for reynabon pe except form is and i quote therefore not suitable for use on building facades

00:19:32 i don't have an answer well do you agree or do you disagree

00:19:45 i don't agree don't agree why don't you

00:19:50 agree

00:19:55 because i'm not sure what claude vlad is writing in his email here well if claude verle is correct that because reynold pe cassette

00:20:09 european f

00:20:12 it could not be suitable for youth on building facades if he's right about that then why was arconic

00:20:20 arconic continuing to sell reynabon 55 pe in cassette form for use in building facades

00:20:27 facades uh we'll see 2011.

00:21:00 okay

00:21:08 was right and saying that but if he was messily

00:21:21 but if he was messily which is the premise of my question why was arconic continuing to sell reynabond 55pe in cassette form for use in building facades from june 2011

00:21:56 a

00:22:08 because for example the product in france was m1 and the french legislation accepted to use m1 products for facades and he says it's m4

00:22:20 sorry i didn't hear you he says in his email but it's m4 maybe this

00:22:35 but he's the one that establishes that link

00:22:39 link was there any discussion within our conic

00:22:42 conic at this time june 2011 about whether or not

00:22:47 not reynabon 55 with the pe corps having obtained a european class f should any longer be sold for

00:23:19 no i don't remember

00:23:34 foreign

00:23:43 [Music]

00:24:11 [Music]

00:24:23 so i'm thinking in particular of a document that was a 2017 in documents so we're talking about an environment which is competitive we're looking to see also what the competition does

00:24:34 see also what the competition does and later on if you look at french technical opinions you can see that some competitors were saying that uh pfra2 could have m1 or m0 classification

00:24:46 m1 or m0 classification um and they hadn't taken fires into consideration until 2017 looking back at the email as a reference

00:24:57 looking back at the email as a reference in 2008

00:24:59 in 2008 if you look in the second paragraph you see that

00:25:12 we yes you recall being present at such a meeting

00:25:19 a meeting present you

00:25:31 no i don't recall

00:25:35 i'm going to turn to a fire uh in dubai in november 2012. before i do i ought to give a trigger warning

00:25:45 warning in this next section again we're going to be showing pictures of a fire in a tall building so for those who are watching who don't want to see that they should look away from the images please

00:26:08 can we please go to your exhibit 10 page 32 met three zeros five three one five seven page thirty two and in the french

00:26:16 french uh it's uh page twenty eight of the same exhibit run let me tell you seven thirty 32 the english and 28 in the french

00:26:34 in the english it's the bottom of the page in the french it's the middle of the page

00:26:37 the page we see an email from robert

00:26:43 on the 27th of november 2012 to alain flackon

00:26:47 flackon claude verlais and others it's writers until i think that alan flacko had become sales and marketing director on the 1st of august 2012. yes

00:27:02 it is

00:27:18 sweet yes i'm going to show you these emails uh

00:27:24 uh and you'll see from the uh the french original that you are copied in on all of them

00:27:28 of them your name doesn't appear on as copy on the english it's important that people understand that you are copied in on these emails

00:27:59 sounds like something our customers make fyi

00:28:11 a critique on a

00:28:26 and the text says for your information and just if you follow in the french please i'll read the english information acm facade caught fire in ace in uae read the article there is a link to

00:28:38 uae read the article there is a link to bbc

00:28:39 bbc photos there is a protective film but there is no way to see the brand i think it is worth digging into and if you look at the very bottom of the page

00:28:50 you look at the very bottom of the page there's an article embedded and it says in english on both sides of the screen cladding blamed in skyscraper fire monday november 26 2012.

00:29:22 if you turn the page please onto page 33 in the english 29 in the french you can see there's an embedded video which we can't play because that's an image and i want to look at the english

00:29:34 image and i want to look at the english text below please under the caption and the translator could translate the english please fireballs under the header well i'll start actually at the top uh

00:29:46 actually at the top uh exterior clatting i think you need uh even on the french probably need the a little bit higher up yes

00:29:53 yes bottom of page 28 top of page 233 exterior cladding may be responsible for accelerating a fire that ravaged portions of a 34 storey residential building in dubai

00:30:04 storey residential building in dubai according to reports

00:30:34 it says the fire at tamweel tower started near the top of the building and moved down raining down flaming pieces of the building onto the ground

00:31:01 and if you look under the header fireballs fall ground it says there were no reports of injuries

00:31:09 injuries however as the flames which started the building scaled down the structure they sent huge chunks of the building and debris to the ground

00:31:30 um

00:31:45 building cladding as fuel while the cause of the blaze was under investigation initial reports indicated the building's exterior cladding may have been the culprit behind the

00:31:56 may have been the culprit behind the blaze spread hello

00:32:21 now we've seen that this article sent internally in our comic including to you although it's in english would you have read it at the time do you think

00:32:52 yes probably do you actually recall reading it at the time do you think it is

00:33:05 [Music]

00:33:17 [Music] i may not have read it in detail but i certainly read it over

00:33:28 but i certainly read it over quickly you would have understood the basic

00:33:31 basic event and the cause of the fire from this article wouldn't you don't

00:33:49 [Music]

00:33:53 the cause of the fine no but what happened

00:33:57 happened yes now can we go to page 32 of this exhibit

00:34:02 exhibit in the english 28 in the french we can see claude verlet's response

00:34:17 in the french you can see that claude verne responds to

00:34:31 robert quattrocchi and

00:34:48 but he says hello this has to do with good bond pe knowing that all pe composites react in the same way

00:35:00 goodbye

00:35:12 receive it robert quatrochi was the plant manager wasn't he

00:35:25 directed

00:35:28 yes so can we take it from this that at a senior level within our comic within aap sas

00:35:35 aap sas uh it was known that pe composites will burn

00:35:39 burn like the tamweel tower fire don't

00:36:02 yes now you say in your witness statement

00:36:06 statement at paragraph 30.3 and i'm not going to take you

00:36:10 take you to it that it may be possible that these emails were discussed at a meeting you cannot recall such a discussion nor seeing the emails before

00:36:21 seeing the emails before the positions

00:36:24 of

00:36:52 no i didn't remember but i can see that i'm copied in so at least i must have seen them can we take it that you don't remember arconic doing anything in response to

00:37:03 arconic doing anything in response to this fire

00:37:05 this fire escamp

00:37:20 foreign

00:37:25 [Music]

00:37:30 in response to this file specifically no probably no we have seen no evidence in the record that arconic did anything

00:37:41 did anything in response to this fire is that correct

00:38:03 certainly why did our comic not do anything

00:38:07 anything in response to this fire

00:38:16 report

00:38:30 um [Music]

00:38:44 the

00:39:00 [Music]

00:39:12 [Music]

00:39:26 [Music]

00:39:40 alexa um well i think that at the time um we may have had some questions regarding the pe panels uh it's difficult to explain

00:39:53 pe panels uh it's difficult to explain but we had a certain perceptions of the different legislation and it wasn't always very clear

00:40:01 clear and it's something that i've already mentioned we had competitors we carried on selling p and on the specific tyre on this tower even if uh

00:40:12 even if uh the product uh was a pe component i mean the fire remained limited to the outside of the building

00:40:30 did you conduct an internal investigation at arconic into whether reynabon 55 pe in either cassette or rivet might

00:40:41 pe in either cassette or rivet might perform in the same way as we saw the acm performed in the tamweel tower fire yes

00:41:18 no i don't think so why not

00:41:43 because the product was known as being flammable

00:41:50 was it known as being that flammable

00:42:00 inflammable

00:42:14 a

00:42:27 [Music] someone subject well in any case that's what the firearm the dubai tower seems to suggest

00:42:38 so why not do an internal investigation to see if reyna bond 55pe might perform in the same way

00:42:56 uh

00:43:00 [Music] but it's because i think that was in any

00:43:13 but it's because i think that was in any case

00:43:13 case uh written by claude valley in a previous email all pe um component behave in the same way

00:43:23 way yes and so if all pe components behave in the same way arconic therefore realized didn't it that

00:43:32 that reynabon 55 pe would perform in the same way as the tamweel tower fire me don't

00:43:52 me really yes so why did you continue to sell it after november 2012.

00:44:21 [Music]

00:44:33 because this product could still be sold for

00:44:36 for usage on buildings

00:44:41 why did you continue to sell this product after november 2012 having seen these images

00:45:02 to

00:45:18 because first the fire was confined on the outside of the building

00:45:25 [Music] the conception

00:45:35 continue the risk therefore you may think that the way the facade had been

00:45:43 had been designed was able to contain the risk

00:45:57 i see let's move to 2013 uh there was another cladding fire in the uae

00:46:06 the uae in april 2013 at the al hafiz tower in sharjah

00:46:26 now i want to go please to uh your exhibit

00:46:30 exhibit at page 48 met 30s 53157 page 48.

00:46:40 and this is a long email uh on the 9th of may 2013. it's all in english and you can see that richard gieta of 3a

00:46:54 that richard gieta of 3a composites wrote to barry wingrove on that date 9th of may hi barry and i'm going to

00:47:02 going to read in english parts of it and ask the translator to translate to you start hi barry you may or may not have seen the recent press coverage

00:47:13 the recent press coverage of a building fire in dubai clad in aca

00:47:19 richard guitar barry windgrove

00:47:48 having taken the time to investigate with my colleague

00:48:08 and then he says in the second paragraph in italics and i will read it to you and then i'll ask the translator to translate it to you

00:48:17 you he says the trouble is that the cladding system here in particular but all over in general using pe is like a chimney

00:48:25 a chimney which transports the fire from bottom to top or vice versa within shortest time however since most sprinkling units are never being tested they for sure do not work when they are needed if you buy a new car and only

00:48:37 needed if you buy a new car and only turn the key after five years you'll be surprised how little your vehicle will move

00:48:40 move here the same the problem is

00:49:24 and then the next paragraph he says the worst of all in our field of composite panels

00:49:29 panels capital letters you do not get what you see

00:49:32 see double exclamation mark the mulk holding people are responsible for the huge damage in this part of the world they since a very long time promote fire rated composite panels with a white core

00:49:45 rated composite panels with a white core which when being tested turns out to be a recycled pe core burning like paper half of the country is full of this rubbish due to price we have taken random samples and done a live test in bangkok in front of architects they

00:49:57 bangkok in front of architects they almost

00:49:57 almost fainted indeed this panel is a whole sheet and burns fiercely

00:51:07 and three paragraphs from the bottom richard gita adds this again the perils of using cheap acm alternatives have been exposed as you are aware our standard core

00:51:18 are aware our standard core is the plus fr mineral core achieving class b

00:51:21 class b s 1 d naught according to en13501 part 1 unlike other acm producers

00:51:32 alternative assembly

00:51:44 [Music]

00:52:01 now let's go up to page 47 please this and again i'm afraid there's no french translation for this mr schmidt

00:52:11 statement no here we can see in the third email down we can see that deborah french sends this email on do you see to you

00:52:22 this email on do you see to you to peter furniture verlay and anna flaccon

00:52:26 flaccon do you see that

00:52:29 the deborah french

00:52:40 and she says just to make you aware i sent this link over to claude w last week concerning a bbc report covering a fire in uae using acm richard guitar aluco

00:52:52 in uae using acm richard guitar aluco bond rep in the uk is emailing all fabricators explaining that the luca bond is now using a fire core

00:53:38 and then she embeds a bbc item and then continues

00:53:48 would welcome any comments straight statement we have left the fire at our standards so i can communicate this to our relevant customers

00:54:02 [Music]

00:54:09 mr schmidt i've shown you that in some detail so far my question is do you remember receiving this email

00:54:21 yes did you read the email she was forwarding yes

00:54:29 the one from richard guitar richard getter

00:54:35 yes now what what did you think what were your thoughts when you saw the email from richard guitar which deborah french was sending to you

00:54:47 reflection said email

00:54:59 [Music] my first reaction was i think to check what the person was saying

00:55:27 [Music]

00:55:32 um because i i through experience and also through comments emanating from the market i knew that aluco bond was still selling a lot of

00:55:45 was still selling a lot of pe on the market

00:55:50 [Music]

00:56:01 [Music]

00:56:11 i mean here for example luke bond uh what's written is that for a commercial with a commercial intention they put forward the fact that the standard product

00:56:22 the standard product is a fire retardant product

00:56:28 it continues

00:56:33 but as i said before they carried on saying selling pe

00:56:39 now deborah french told us don't need the reference but it's day 89 page 49 lines 22 page 50 line 3. we don't need to translate the reference uh debra french told us that she had had

00:56:51 uh debra french told us that she had had conversations with people at murkheim uh uh that uh arconic uh was going to continue to sell

00:57:00 to sell pe do you know can you remember whether deborah french did have conversations like that with anybody at merck's time but not deborah french nozadi uh

00:57:49 no i mean it's not a question of recalling it but i don't think she had a direct discussion of this with me and i don't think she talked to other people about it

00:58:04 i don't know whether she talked with others now you said before you just told us that luca bond carried on selling pe the question i have is this um

00:58:15 the question i have is this um it looks from the email that luca bond were now selling fr as standard my question is did our colleague discuss switching to selling

00:58:26 selling fr as standard

00:58:32 bond continue

00:58:42 [Music]

00:59:10 so first we're not sure on the basis of that email that aluco bond decided to sell

00:59:15 sell far as the standard product

00:59:26 [Music]

00:59:59 and i think that starting from the beginning of 2014 we informed all our sales people all the commercial people to communicate on the performances of pe

01:00:13 to communicate on the performances of pe and the five performances of b

01:00:17 why did arcolic not start offering renai bond 55 in fr as standard

01:00:28 in fr as standard from april 2013 onwards

01:00:51 [Music]

01:00:54 globally

01:00:58 [Music]

01:01:01 because it implied carrying out a more global

01:01:06 global reflection on the subject and understanding how the market was evolving

01:01:12 evolving why didn't you do that

01:01:23 because we needed time to think about it i imagine

01:01:30 deborah french told us that commercial reasons were at least part of the reason why arconic did not proceed after this fire to offer

01:01:42 after this fire to offer fr as standard do you agree deborah french

01:01:50 represents

01:02:04 no

01:02:08 how much time do you did you need to think about whether starting to offer fr

01:02:19 commercial

01:02:38 [Music]

01:02:50 [Music] well on one hand and i repeat we don't know if luca bond

01:03:02 know if luca bond offered it as standard and we always try to respond to the needs of the client

01:03:09 look at debbie french's 13th of may 2013 email

01:03:14 email cep40

01:03:28 so now i'm sorry to say there is no french translation of this email uh so i'm going to ask madam translator to read the text uh in french to you and i'll tell you

01:03:41 uh in french to you and i'll tell you what it is it's an email from debbie french deborah french 13th of may 2013 to cep neil wilson jeff blades and roy fuster

01:03:52 neil wilson jeff blades and roy fuster subject

01:03:53 subject bbc report uh acm in

01:04:24 and before i ask for the translation of the text i'll just tell you that other copies of exactly the same text went to other fabricators in the uk yeah

01:04:46 i should tell you just in case you didn't know the cep was a fabricator and in fact fabricated the

01:04:53 the acm for grenfell tower

01:04:58 fabricators

01:05:05 translator if you would please translate the text

01:06:59 uh my first question is did you read this email in draft form before it was sent by deborah french

01:07:12 french no no were you involved in any discussion about the principles reflected in this email participated

01:07:26 in

01:07:30 no no were you aware of this email at the time

01:07:40 it

01:07:46 do you know uh from whom deborah french well let me put it a different way do you know whether deborah french needed authorization to send this email

01:08:07 no no

01:08:21 says mr schmidt just focusing uh on the penultimate paragraph she says at this stage we will continue to offer both pe and fr core and

01:08:34 to offer both pe and fr core and continue the close working relationship we have with our approved fabricators to make sure the right technical support rayner bond specification of materials are being used and installed on rayna bond projects now if we could

01:08:46 on rayna bond projects now if we could leave that on the screen please uh mr schmidt can we please go to your uh witness statement at paragraph 92

01:08:56 92 in the uh um english and i'll read it in the english and then i'll show you the french because we can't have three documents on the screen at once a paragraph

01:09:08 the screen at once a paragraph paragraph 92 at page 29 your witness statement met 3053187 page 29

01:09:18 29 paragraph 92

01:09:22 would you like me to interpret just the previous section that's okay i want to show people paragraph two and i'm going to read it read the sentence i or passage i want to put to

01:09:33 sentence i or passage i want to put to him from paragraph 92

01:09:40 and i think we need over the page please page

01:09:43 page 19 at page 30.

01:09:49 in the last part of the last sentence it says

01:09:54 says aapsas is simply a supplier of one component product which may be used in the start of a building and if i could show him the french of that please the french original at page 13 paragraph 92

01:10:06 original at page 13 paragraph 92 last half of the last sentence in that paragraph

01:10:15 page 13 paragraph 92

01:10:28 french version met3048338 h13

01:10:37 there it is there it is not that's it uh and i want to ask him to look please at the french version and a lot it is actually a full sentence in this french version a-a-p-s-e-s

01:10:50 in this french version a-a-p-s-e-s if he could read that sentence please

01:11:06 [Music] the last sentence in other words the very last sentence right very old sentence

01:11:20 yes i can see it now i've shown you that and i've shown you the paragraph in the email

01:11:28 going back to the email please

01:11:39 is what deborah french says in the in the email

01:11:43 the email in the paragraph i read out to you which starts at this stage correct

01:12:19 no it was never our policy

01:12:24 [Music]

01:12:34 them in fact very simply we didn't have the compensate competency internally to be able to advise the clients on the types

01:12:43 types of cause

01:12:46 of cause personally technically

01:12:58 nobody in the technical team could have taken into consideration the whole of the

01:13:02 the facade system in order to be able to advise on the appropriate product

01:13:12 then if you're right why deborah french said what she said in that paragraph if it wasn't true

01:13:29 no i can't explain now we've seen from the record that deborah french sent this message in identical terms at least to two fabricators cep which is this one and simcoe

01:13:41 cep which is this one and simcoe now and we can also see that none of these

01:13:45 these well this this message uh does not communicate anything about the dangers of pe

01:13:51 of pe evidenced by the fire in the uae

01:14:19 my question is why why did her message not say anything here about the dangers of using p e corps hello

01:14:40 i don't know do you know why this message did not tell fabricators that in its cassette variant

01:14:51 variant reynabon 55 pe had achieved a euro class e

01:15:22 55 with a pe core in cassette variant for use at height even after this fire in april 2013.

01:15:34 continue

01:15:50 france

01:15:59 [Music] uh

01:16:12 [Music]

01:16:18 uh

01:16:24 [Music]

01:16:35 [Music]

01:16:44 well i don't believe the question was asked i think one can say that arconic wanted to carry on saying it's selling acmpe but one must remember that from a general point of view it's very in very few cases that uh we're aware

01:16:56 in very few cases that uh we're aware of the final destination with regard to the usage of the product why not simply attach a health warning when selling rainerborn 55 pe at least

01:17:09 when selling rainerborn 55 pe at least in cassette variant after this time

01:17:13 period

01:17:28 epoch

01:17:42 say

01:17:51 [Music] um

01:18:06 [Music]

01:18:12 well i don't believe that our um uh competitors did it uh ten years later it is a legitimate question to raise but at the time it wasn't so obvious

01:18:27 but at the time it wasn't so obvious why wasn't the fact that reynold von pe 55 with a cassette variant had achieved a class e in the european fire test sufficient to make it obvious

01:19:05 i don't have an answer another convenient moment mr chairman yes i think it is mr minute thank you well

01:19:12 well mr schmidt i think it's time we had a short break so we're going to take that now

01:19:17 now we'll resume please at 11 35 our time

01:19:36 thank you very much we'll see you merci beaucoup 11 35 over 12 hours thank you

01:35:22 welcome back everyone we are ready to continue with mr schmidt's evidence but first i better just check that the interpreters are with us are you their interpreters

01:35:33 are you their interpreters yes the interpreters are with you sir thank you i can hear you and see you thank you and uh mr schmidt are you there

01:35:40 there mr schmidt

01:35:45 i can see you and i can hear you thank you thank you very much and you're ready to go on i hope

01:35:53 yes thank you then mr millet when you're ready thank you

01:35:59 can we go please to met 3064988 at page one two two in the english same time

01:36:08 time please add to french page 119 same exhibit now if we go to the bottom of page one two two in the english topic page one one

01:36:20 two in the english topic page one one nine in the french we can see an email from isabel moises again

01:36:27 this time the 25th of april 2013. can you see that it is

01:36:38 can you see that it is can you confirm for me that under en13501

01:36:43 en13501 pe riveted system equals bs2d naught cassette f fr riveted system or cassettes bs one d naught thanks isabel

01:36:59 yes now um we can see the reply from claude verle at the bottom of page one two one in the english and one one eight in the french please my name is

01:37:10 and uh we can see claude valley uh comes back to her at the bottom of page one

01:37:17 page one twenty one

01:37:22 leave the french on the screen because you can see that there in the english please scroll to 122 at the top uh he says under en13501 reyna bond is really one pe is classified as e

01:37:33 classified as e rendezvous fr is classified as b s1 d naught

01:37:37 naught we do indeed have a historical report classifying the renault pe riveted system as bs2dnau but we no longer wish to use it on the market

01:37:46 market it should be noted that the class e for the pe composite has become the market standard for the national classification systems our competitors talk about pe as being m1

01:37:57 being m1 for example thanks claude and then if we go up to english page one two two one and a little bit further at the top top of the screen on page one one eight in the french

01:38:09 the french we see isabel moises goes back to claude verle on thursday the 25th of april 2013 and she asks in the question and in the french is mila casificacion and in english

01:38:21 mila casificacion and in english it's but is the b s 2 d naught classification for riveted valid or not that's her question and if we go above that still on page one two one in the english

01:38:32 one two one in the english uh still on page one one eight in the french ford valley tells her by response it's valid because it's contained in a in an official report however the tests

01:38:43 in an official report however the tests that we conducted are not really reflective of the riveted system in general

01:38:47 general so alcoa with the market in quotations market classification and does not use it anymore preferring a class e regardless of the system above that uh you could just see that

01:39:00 above that uh you could just see that isabelle moises comes back to claude verle same day 25th of april or the date is cut off on the french and she says is this official the official is this official as we are

01:39:12 the official is this official as we are still talking about bs2d naught and at the top of page one two one

01:39:19 one and in the french at the bottom of page 117 you can see that claude verlet responds

01:39:25 responds at 17 57

01:39:30 at 17 57 the top of page one two uh one two one bottom of page one one seven uh and you'll need to go to the top of page one one

01:39:41 page one one eight sorry no there it is sorry 1755. uh he says it's valid because it's contained in an official report

01:39:52 contained in an official report uh i'm so sorry i'm looking at the wrong part um yes that's right he sends her a response top of page one two one

01:40:00 two one top of page uh 117. he says no we have not communicated bs2d not from the beginning of the year at the request of cs

01:40:12 the request of cs and in the french just look at it together

01:40:15 together uh if you've made a translator if you could just read the french textbook

01:40:34 yes

01:40:38 did you request uh that b s to d naught should not be communicated uh from the beginning of 2013

01:41:13 [Music]

01:41:16 um

01:41:24 [Music]

01:41:41 we're in 2013 and i think it follows an exchange of mail that took place in 2012 and in

01:41:48 and in which claude valley was trying to meet me and well i know i don't know whether an exchange took place but i know that i didn't meet him

01:41:59 place but i know that i didn't meet him that i know there was no meeting are you saying that this request so far as you can recall it was the logical conclusion of the discussions uh in the middle

01:42:11 of the discussions uh in the middle and the failed meeting in may 2012.

01:42:38 i'm not certain but that might be a possibility can you help us why you asked that our comic not even communicate the fact that rivet uh had a class b rivet

01:42:49 rivet uh had a class b rivet maybe not cassette but rivet had a class b

01:42:54 escape

01:43:10 no no can we go back to the email run please and have uh back where we left off

01:43:19 off and if we bottom of page 120 in the english

01:43:23 english bottom of page 117 in the french we see um that at the bottom in the english isabelle moyeses says

01:43:34 in the english isabelle moyeses says to glorverle but that's not what miguel gets told is that right for question marks and you can see the french equivalent of it

01:43:47 and above that claude burleigh comes back 1801

01:43:50 back 1801 and he says yes it is even i even told him about that before everyone else when i was in spain the thing is that d i t still includes b s two d naught for p e so he makes use of that

01:44:15 and then above that in the english and just read along the french on the right as well moises comes back to the valley and says yet we still won't stop proposing the riveted product in p e question marks

01:44:38 that's the thing it's a gap in the certification that we continue to make use of

01:44:42 use of if you're reporting certification continue

01:44:49 exchange i think runs uh out at this point where she says you can just see the french on the right hand side i'm afraid it's been cut off a bit but we can move across to look at the full

01:45:00 we can move across to look at the full of the the full

01:45:04 she says thank you uh she says to him so i cannot say otherwise

01:45:13 no word missing actually uh right uh well my question is having shown you the entirety of the email run were you aware that at the start of 2013

01:45:24 were you aware that at the start of 2013 the tests being carried out did not reflect the riveted system in general well my

01:45:52 not at all it looks from the email run that uh uh that um

01:46:06 uh claude verlet was exploiting or continuing to make use of a gap in the certification and can you explain that

01:46:22 expertise

01:46:47 i don't understand the whole chain of email but i think we're talking about spain or portugal maybe here

01:47:01 [Music]

01:47:09 and what i understand is that the d.i.t which is probably some accreditation system in one of these countries

01:47:18 in public

01:47:24 [Music]

01:47:27 published something saying that p got the classification b in the rivet form

01:47:40 and i imagine that miguel is probably a client

01:47:43 client utilize

01:47:47 system miguel relies on that d.i.t for the riveted system do you know why arconic was permitting the sale of pe rivet

01:47:59 the sale of pe rivet uh as if it was a class b in light of your request we've seen that our conic not even communicate that rivet fixed pe

01:48:10 rivet fixed pe had a euro class b

01:48:16 permitted

01:48:47 but i don't think there's any communication taking place in that chain of emails

01:48:54 can you tell us the answer to my question

01:48:59 question sorry sir i couldn't hear your question there was a weird sound we were able to answer my question i'll ask it again from your own recollection do you know why our comic

01:49:10 recollection do you know why our comic was permitting the sale of p.e rivet as if it was class b in light of the request you had see we had seen earlier from you uh not to say that it had a

01:49:22 from you uh not to say that it had a class b

01:49:26 repetitive

01:49:54 uh

01:49:59 [Music]

01:50:23 hello hello interpreter can you did you hear that last answer yes i'll take over i think there might have been a technical issue um i would just like to say that we

01:50:34 um i would just like to say that we don't sell the product uh in a riveted form we sell it in a platform

01:50:46 you carry on mr schwartz continue mr schmidt

01:51:03 [Music]

01:51:13 and i don't believe once again that in that email the bs2d0 is promoted for reno bond pe

01:51:24 just at line seven there the witness said flat form not platform just to be clear

01:51:30 clear yes that's right moving on um mr vale says in his witness statement that paragraph 6 they need to go to it that by early 2013 he wanted to

01:51:43 go to it that by early 2013 he wanted to have a

01:51:44 have a low classification or rayna bond p e namely a class d for both rivet and cassettes

01:52:00 um

01:52:15 class d for the formative asset and he says that he wants to do that in order to differentiate more clearly between the fr product and the pe product

01:52:28 the fr product and the pe product to be

01:52:42 my question is were you aware of that testing strategy as described by claude

01:52:49 claude claude questions

01:52:56 strategies

01:53:09 [Music]

01:53:19 i believe that if it was discussed with management it would have been discussed with

01:53:23 with commercial management do you know why policy was not followed quite simply to tell customers the real

01:53:35 to tell customers the real classifications for rayno bond 55pe namely cassette was an e and rivet wasn't really a b

01:53:45 politics

01:53:49 [Music]

01:53:52 classification

01:54:06 b

01:54:25 the rivet test showed a classification a b

01:54:29 b classification over the years so why were you so reluctant to market it as having a v classification

01:55:01 [Music]

01:55:06 i think in 2013 certainly clear claude wanted to

01:55:10 wanted to um show a clearer differentiation between p e and f r e

01:55:16 and f r e final

01:55:19 [Music]

01:55:30 foreign

01:55:33 and in the end when exactly he didn't finish the sentence i don't know when he actually received the classification or obtained calculation with regard to ee

01:55:44 ee obviously and i wanted to add also officially

01:55:54 was the idea to stop referring to class d for reynabon pe

01:56:02 uh so that people would no longer uh so that people would no longer started to start asking difficult questions about whether the cassette

01:56:14 questions about whether the cassette variant

01:56:14 variant was truly a b d c

01:56:26 d

01:56:35 no i don't believe so why not just market fr

01:56:38 market fr on the basis that it was safer than pe

01:56:56 because there was a request for pete there was a demand for pe and a demand for fr

01:57:03 but they weren't the same they didn't have the same safety so why not just market fr as the safer option

01:57:22 for

01:57:33 [Music]

01:57:44 well i think that this development took place even beginning of 2014

01:57:50 we'll come to that uh i want to turn to another test on the pe cassette in 2013 mr schmidt can we please go to uh met3053158

01:58:06 can we please go to uh met3053158 underscore p02 page 38 and at page 36 in the french same exhibit run two separate pages

01:58:25 and if we look at the english version at the bottom of page 38 and the french version at the bottom of page 36 at the same time

01:58:42 we see here an email from benoit forest for rest of cstb on the 7th of november 2013 to feed bondholm

01:58:53 2013 to feed bondholm who i think is a technician isn't he at arconic

01:59:00 yesterday

01:59:12 uh and if you just follow in the french while i show you the ink show the english he says hello mr von trong don't translate it just

01:59:23 von trong don't translate it just follow through the french please hello mr von moore first sbi tests on the product renault on pe have been completed and then he sets them out in the box you can see on the right in the french

01:59:34 the right in the french if we turn the page page 39 into english we can see the equivalent in english and we can see the sbi test there and the table at the top there in the english bottom of the page in the

01:59:45 in the english bottom of the page in the french is the results of the rivet pe uh rivet fix pe uh and uh underneath the uh sbi test we see behavior

01:59:55 behavior can you see and you'll need to flip the page of the french to the compost mold at the top of the page behavior cs2d naught on a test and then underneath that uh we have um that's the and that's the

02:00:07 uh we have um that's the and that's the riveted system as you can see yes

02:00:21 under the single burning item test uh renault 55 pe with rivet fix has obtained a class c yes

02:00:34 system 50 afternoon c we yes were you aware that from november 2013

02:00:43 2013 rivet fix had tested as a c-class product not a b yes

02:01:13 i don't know whether we asked for class c or whether it was the result of the test that

02:01:18 test that made it see the

02:01:35 is

02:01:46 [Music]

02:02:02 play

02:02:16 specific well very simply at this time claude valde i think wanted to obtain a more well how can i say it a more negative um result but i don't know

02:02:27 negative um result but i don't know whether that's that demonstrates this specifically but did you have a discussion at the time with claude verlet about seeking a more negative result

02:02:44 negative and underneath uh the uh c2 behavior result we see another box a reynabon pe cassette system

02:02:58 a reynabon pe cassette system and uh it says in the long rectangular box on the right of that underneath the figure

02:03:04 figure thr and smuggler figures stopping the test at 800 seconds out of 1260 seconds for widespread ignition best possible classification e ignition test

02:03:16 test and then you see underneath that um uh benoit forest says following these results can you tell me what you want me to do

02:03:25 to do you can just read the text underneath the box there mr schmidt yourself in the french um he says you have the possibility to continue with the ignition test in order to envisage an e-classification

02:03:36 e-classification for both systems or to continue with sbi but only in order to obtain a for the riveted system since cassette does not pass lastly you can also decide to stop

02:03:46 to stop we remain at your disposal for any further information and await your decision

02:03:53 are you aware at this time that for the third time now uh we saw it in 2005 we saw it in 2011 for the third time now the cassette test was stopped for widespread ignition

02:04:05 was stopped for widespread ignition were you aware of that at the time

02:04:31 [Music]

02:04:36 um

02:04:40 i can't be affirmative i can't remember did you know that arconic in fact decided to proceed with that ignition test

02:04:49 test and obtained an

02:05:05 no now take it from from me that the c classification was not recorded in any final classification report at the time

02:05:16 final classification report at the time as opposed to the test report which we have

02:05:18 have the results of

02:05:39 what it looks to the inquiry to have happened on the records is that it is that at this point arconic decided to classify all p e chord rhino bond whether rivet

02:05:50 all p e chord rhino bond whether rivet or cassette as class e

02:05:54 b

02:06:12 my question to you is is that correct is it correct that our conic decided to classify

02:06:17 classify all pe called renault bond rivet or cassette

02:06:21 cassette as class questions

02:06:46 [Music]

02:06:51 once again it's a decision that was taken

02:06:55 taken at a commercial level but i think it is right

02:06:59 right you say you think you think i am correct in my

02:07:02 in my putting to you factually

02:07:10 factually yes i think so let's turn to january 2014 now and we go to claude vale's exhibit part four page one three five

02:07:21 four page one three five met three zero five three one five eight underscore p04 page one three five that's the english and if we could also have up at the same time please uh the french version at one forty same

02:07:32 uh the french version at one forty same exhibit number different page page one forty

02:07:44 yeah and we can see here english on the left french on the right that here is a certificate ra

02:07:52 zero three 13033 three uh to standard european standard en 13501 and

02:08:01 13501 and if you look down to the text you can see the commercial brand reynaborn55pe without identifying whether it's rivet or cassette can you see that

02:08:31 look at the date a date of issue january the 31st 2014 can you see that

02:08:43 yes go to the bottom of the page you'll have to scroll up a little bit on the french version because it's cut off on the screen at the moment you can just just

02:08:56 and i'll read the english if you follow along please in the french master schmidt

02:09:00 schmidt it says the document zero ra three three uh dated january 31 2014 cancels and replaces the document ra11

02:09:12 cancels and replaces the document ra11 0032 dated february the 9th 2011 and the document ra ra-050005a dated january 7th 2005.

02:09:25 dated january 7th 2005. and that last reference is of course the reference to test 5a from january 2005 on the riveted system

02:09:51 if we scroll down to the next page in the english page place 136 and in the french page 141 please we can see the product description

02:10:08 it says just follow along with me composite panel consisting of a low density

02:10:13 density polyethylene core covered on both sides of a thermally bonded pre-coated aluminium sheet systems riveted or cassette can you see that in description

02:10:33 and if you scroll down to the next page please page 137 in the english page 142 in the french we can see the classification under section 4.2

02:10:46 under section 4.2 and it says fire behavior e smoke production not applicable flaming droplets or debris not applicable and then the large box classification e and then underneath that

02:11:00 e and then underneath that it says the classification is valid for the following product parameters

02:11:21 following end use conditions sweetly conditioned utilization

02:11:29 underneath that first bullet point there says riveted or screwed system and cassette system on metal substructure discussion

02:11:45 now i've shown you this classification report my question is do you agree that the effect of this classification report is that from the 31st of january 2014

02:11:58 is that from the 31st of january 2014 arconic had a formal classification report

02:12:02 report stating that all renault bond p e whether rivet or cassette was classified as an e

02:12:09 as an e according to the european standard

02:12:14 classification

02:12:18 left

02:12:43 yes you see this classification report at the time

02:12:57 did anybody tell you at the time january 2014

02:13:01 2014 that reynaud bond 55 pe was now classed as an e according to the european standard yes

02:13:14 reynolds

02:13:28 no is that something that you would have expected at the time to have been told excuse me

02:13:38 excuse me [Music]

02:13:42 foreign

02:13:52 [Music]

02:14:04 [Music]

02:14:13 so my answer is not necessarily what i understand is that uh there was a desire from the commercial management to

02:14:24 commercial management to make it known that p had that e-class for both systems so i believe that is something that emanates from maximum from the maximum management

02:14:40 from maximum from the maximum management at this time uh end of january 2014 mr schmidt is right isn't it that the bba certificate zero eight slash four five one zero

02:14:51 zero eight slash four five one zero for reyna bond 55 was still in circulation yes

02:15:06 certified

02:15:14 yes

02:15:18 and it's right that that certificate still represented that all reynar bond pe

02:15:25 pe achieved class b in the european tests

02:15:58 i believe that the certificate was still reminding of the original test in 2005. yes and my question is why why was it

02:16:11 yes and my question is why why was it not updated to state now that rayner bond 55 in

02:16:34 [Music]

02:16:44 um

02:16:48 [Music]

02:16:54 i'd find it difficult to answer i don't believe that there was a desire to hide anything i think it's just something that was forgot forgotten and nobody thought or establishing a link with the bba

02:17:07 establishing a link with the bba certificate have you yourself conducted any kind of investigation within our comic

02:17:13 comic to seek to understand how it could have been the case that notwithstanding the classification e

02:17:20 e from january 2014 the bba certificate remained unamended

02:17:51 why is that

02:18:04 because we didn't establish we didn't express a link between the two things in my view

02:18:12 my view i don't understand how there could have been no link between the vba certificate stating that renault bond 55 pe had a class b

02:18:24 that renault bond 55 pe had a class b on the one hand and your knowledge on the other archonics knowledge on the other that it didn't but instead had a class e clearly there's a link between the two isn't it

02:18:36 a certificate

02:19:04 a

02:19:17 [Music] uh

02:19:32 uh

02:19:40 that question of ling is not exactly what i meant but i believe that on one side

02:19:45 side arconic and the commercial team uh wanted to inform about the p having a class e but on the other end no one thought of establishing the link

02:19:58 no one thought of establishing the link with the

02:19:58 with the bba certificate

02:20:03 [Music]

02:20:16 and besides i think it's something that would have been very easy to update during a bba audit on that sort of question

02:20:25 question mr schmidt was it not our colleague's responsibility to make sure that the bba certificate remained up-to-date and accurate mr schmidt responsibility

02:20:42 certificate

02:20:50 yes according to the cell's condition that we talked about last week so please explain to us how it was the bba certificate was

02:21:02 how it was the bba certificate was allowed

02:21:03 allowed to become inaccurate out of date and as a result i suggest to you

02:21:12 you fundamentally misleading in the sense that

02:21:15 that it would lead the reader into serious error

02:21:24 hello

02:21:39 oh

02:22:02 [Music]

02:22:14 [Music] the

02:22:22 the [Music]

02:22:42 well i mean there are two things i would like to say first i don't think that there was any desire to do what you're saying and secondly in the case of in the bba certificate

02:22:54 in the case of in the bba certificate there's a number of sentences that remind the reader that whatever fire certification the product

02:23:03 product has got people still have to carry out various

02:23:07 various checks and controls

02:23:12 let's move then on to 2014 a few days later february 2014. can we go please to claude verle's exhibit

02:23:22 exhibit part four page one three four at met three zeros five three one five eight underscore p zero four page one three four now there's no french equivalent to this i'm afraid so

02:23:33 this i'm afraid so we'll take this slowly

02:23:44 a lot more and you can see that this is a an email from claude verlet on the 3rd of february 2014.

02:23:58 hello

02:24:13 least commercial antenna commercial also to the iaf least commercial renault board

02:24:21 board commercial renault born and the subject is new fire european fire class for reynabong

02:24:36 and the email says dear colleagues and in bold it says please finding close the new fire reaction test report for renault bond architecture pe

02:24:47 renault bond architecture pe in accordance with en13501 norm but fire achieved classification is equal

02:25:00 [Music]

02:25:14 and then he continues the previous b class report done for reynabon pe in riveted system can no more be used from now

02:25:57 and one is the test in english and one is the test in french

02:26:03 and to be clear the test is the uh certificate uh dated 31st of january 2014 which we've just seen and which says that all reynold 55 pe is classified as an e

02:26:17 55 pe is classified as an e don't test

02:26:29 my question for you is would you have expected

02:26:32 expected deborah french as our conic's uk sales representative at the time to have known that that certificate was relevant to her market

02:26:44 relevant to her market my question is

02:27:14 is

02:27:28 commercial

02:27:32 [Music]

02:27:57 uh i think that uh from a general point of view i would have uh waited for all the commercial team to start discussing that with their customers because

02:28:08 customers because it was public and our desire was through the sales representative to inform the market

02:28:17 so does that tell us that you you expected deborah french at the time to communicate this message to her uk customers

02:28:38 certainly are you able to explain why she didn't yes

02:28:49 no i can't explain but

02:28:57 [Music]

02:29:20 foreign

02:29:34 elmo

02:29:39 i mean i did see i did see a document i believe it might be

02:29:46 be something that was joint document to an um something from cloud valley it was an email i think that was sent to taylormade

02:29:59 it was include valleys deposition called the

02:30:08 sorry the interpreter made a mistake it's a document you find in claude verley's

02:30:12 verley's uh witness statement and i believe it's an email that was sent to taylor maxwell explaining the new class and i think therefore

02:30:23 therefore there was some information that was passed on to the market even if only partially

02:30:37 [Music]

02:30:45 uh the attachment uh to that email what that fire test you've just shown previously

02:30:54 now deborah french told us in her evidence that she did not appreciate the relevance of this information to her market uh and carried on using the

02:31:05 on using the bba certificate because that was what she had understood the message from merck signed to be that's what she told us at day 88 page 140

02:31:15 140 line 22 to page 141 at 9 16.

02:31:43 my question is to the best of your recollection was deborah french told by merkstein to continue

02:31:53 continue to use the bba certificate in and after february 2014.

02:32:39 [Music]

02:32:55 i wouldn't be informed in detail about all of this but i find it really difficult to understand how on the one side the commercial management

02:33:06 the commercial management would uh inform that the product has got a classification e and in the same time the same commercial management would ask one of the sales people to carry on

02:33:19 one of the sales people to carry on using a document that pretends

02:33:32 certified

02:33:41 to knowingly carry on using a bba certificate that gives a classification be so can you account for why it was that deborah french was not

02:33:52 deborah french was not told expressly not to put forward the bba certificate anymore

02:34:11 no no now we know from many documents seen in the inquiry and from this french's evidence that on the 23rd of april 2014 deborah french sent the rhino bond bba

02:34:24 deborah french sent the rhino bond bba certificate to the cladding subcontractors harley working on the grenfell tower project

02:34:59 my question is would you have expected that at that point deborah french would have noticed the claim that reynaborn 55 pe had a class b

02:35:24 be

02:35:28 yes it's probable would you have expected deborah french to her told her her customers that although the certificate said class b in

02:36:03 that all sales representatives knew and understood that the euro european classification for this product had been significantly downgraded from a b

02:36:14 b system

02:36:19 on the event so

02:36:39 [Music]

02:36:48 uh

02:36:58 well we have the claude vale males that sends a message to the whole sales team saying that it had a class e and that he was available for further

02:37:10 and that he was available for further [Music]

02:37:16 information and i believe the management the management of the sales team was also available in order to be able to answer any questions what system was in place for making sure

02:37:29 what system was in place for making sure keep

02:37:29 keep catching up and keeping up with sales representatives so as to make sure that they understood that the european classification for this product had been downgraded

02:37:44 to

02:38:15 [Music]

02:38:22 i don't think there was a system but i think that claude's mill saying that we had

02:38:25 had a b and then it was downgraded to uh e was sufficiently explicit you see it wasn't enough simply to tell deborah french

02:38:36 deborah french the results of this test why not also tell her

02:38:40 tell her not any longer to use the bba certificate

02:38:54 a certificate

02:39:08 october 2014 uh because we can see that uh the designation for all reynold bonders pe did not last for the whole of that year which was

02:39:20 for the whole of that year which was translated in october

02:39:31 can i show you what claude vella says in his statement please met 30 531 one nine zero page 21 paragraph 70.

02:39:43 and the french version of this statement

02:39:47 we'll see 26 in the french paragraph 70 in both cases please

02:40:04 and he says here at the beginning of the paragraph

02:40:16 three zero is five three one nine zero page twenty

02:40:32 let's just look at the very start of that paragraph together you and the french i'll read the english paragraph

02:40:41 it says the next en 13501 testing that i organized on reynobon55pe was later in 2014

02:40:50 2014 it had become clear from discussions within aap sas and the wider market that there was a desire to again have separate classification reports for the pe rivet and cassette variants to more accurately

02:41:02 and cassette variants to more accurately reflect

02:41:03 reflect the classifications that each had in practice obtained i just want to ask you about that sentence

02:41:11 sentence two sentences first question who in the wider market had a desire for a separation of rivet and cassette pe respectively

02:41:28 generally

02:41:43 have the same desire to separate out again the classifications as between cassette and rivets do you know exclusives

02:41:56 classifications

02:42:00 no isn't tipper no i don't know you involved in this decision at all

02:42:08 no i'm sorry discussions so rephrase the question

02:42:20 i don't believe so absolutely

02:42:24 do you know whether the classification of

02:42:28 of uh rivet pe as class e was affecting sales

02:42:33 sales exclusive classification

02:42:38 class uh

02:42:49 i have no idea i never saw the link let's look at the classification report

02:43:00 let's look at the classification report please uh the english is at arc50397 and french is an arc underscore

02:43:16 and we could see on the first page we've got we've got the test on the left uh the french version uh

02:43:27 uh the french version uh is uh

02:43:30 not the right reference um so i think it's one three in fact my fault i'm sorry arc underscore uh

02:43:42 arc underscore uh t4013 yes thank you very much uh and we can see on the first page that its classification ra 14 0 339 to the european standard

02:43:55 0 339 to the european standard and if you look at the bottom of that page uh it has the date of issue december the 4th 2014. can you see that

02:44:16 the basis of this classification report is

02:44:19 is at met 30158 305 page 155 and 146 respectively means french go to those

02:44:30 respectively means french go to those for our reference purposes if you look at page four in this document please in both languages

02:44:41 i should have pointed out commercial brand it says renamon 55 pe riveted system

02:44:46 system can you see that okay

02:44:55 and now if you go to page four you'll see

02:44:59 see the classification

02:45:04 paragraph 4.2 classification there's the box fire behavior c smoke production s2 flaming droplets or debris d naught and then underneath that

02:45:16 naught and then underneath that classification cs2d naught and then underneath that 4.3 field of application this classification is valid for the following product parameters and if you look at the last

02:45:28 parameters and if you look at the last bullet point do you see there it says various colors

02:45:36 and again cooler in the french so it could be various colors some colors do you see that

02:45:44 decolon yes the second sub header end use conditions it says this classification is valid for the following end use conditions riveted or screwed system on metal

02:45:55 riveted or screwed system on metal substructure

02:46:08 again did you see this uh classification report at the time do you think it's gonna review the classification epoch

02:46:16 no no i don't believe so uh would you accept that what this would mean for the uk market at the time is that neither cassette nor rivet would meet the european

02:46:27 rivet would meet the european classification requirement for surface spread of flame uh

02:46:34 uh the european classification requirement for surface spread of flame namely class b

02:47:04 b yes do you know why the classification result was not immediately disseminated to the uk

02:47:15 immediately disseminated to the uk market

02:47:18 classification

02:47:33 it's at met 30 53158 underscore p028119 in the english in the french page one one three of the same exhibit

02:47:44 same exhibit yeah you are not necessarily at all

02:47:59 we have the french version up as well please thank you very much and you can see that

02:48:04 see that this is a fire reaction test report but also dated the fourth of uh december and if you go to page

02:48:19 or you can see the very bottom of the page

02:48:38 this is modification of the document for elimination of the riveted system document ra13033 fourth december 2014 cancels and replaces document ra 13033

02:48:51 document ra 13033 31st of january 2014.

02:48:56 uh we go to page 121 please in the english and 115

02:49:03 and 115 in the french

02:49:09 and we can see there that

02:49:14 there's a reference to the november 2013 test on the cassette system you see that

02:49:24 alice said

02:49:29 it appears to be a a reissue of the 2013 class e

02:49:34 class e test report for cassette but this time to state that it only applies to

02:49:52 uh

02:49:59 classification report now for completeness at met3053158 underscore p02 page 105. it's the same exhibit run page 105

02:50:10 page 105 in the english in page 109 in the french

02:50:23 in the english in page 109 in the french that's it and on the left hand side english right hand side french just follow along in the french please

02:50:30 we could see here's the report number ra130333

02:50:34 ra130333 the date if you if you look at the bottom or towards the bottom of the screen there again is the 4th of december 2014 and if you go to page 107 sorry pause that

02:50:45 that cassette system it says in the middle of the page commercial brand renault born 55

02:51:02 111 in the french we can see the classification again the paragraph 4.2 classification in the upper box

02:51:09 upper box fire behavior e smoke production not applicable claiming droplets or debris not applicable classification e you see that

02:51:31 to show that this classification test all the test data was provided to deborah french uh but she left in december 2014 and wasn't effectively replaced until

02:51:42 and wasn't effectively replaced until 2015

02:51:43 2015 peter friele i think operated in her role in the middle of that during that period do you know from your own knowledge whether this classification report was sent to the uk

02:51:54 classification report was sent to the uk marketing team

02:51:58 hello

02:52:26 is

02:52:36 no i don't know you know

02:52:47 [Music]

02:52:54 but i'm not sure if it would have been sent if the previous uh test uh had already given rise to class e

02:53:03 well can you help me what was the point of

02:53:06 of do you know and if you don't know you don't know what was the point of separating out the two classifications for rivet and cassette respectively and they're not sending the new classification reports for each product

02:53:18 classification reports for each product out to your sales teams

02:53:22 elementary

02:53:42 no i don't know now i want to look with you at the documents in circulation uh in the grenfell supply chain

02:53:50 chain in the early part of 2015 now 2015. can we go please to cep three zeroes five three three

02:54:01 document

02:54:04 univo the grenfell debut

02:54:10 this is provision sorry can we have the reference again please mr miller

02:54:17 mr miller is five three three seven four

02:54:29 yes thank you this is an email from neil wilson of cep who was the fabricator of the cassette panels for application on the

02:54:40 cassette panels for application on the facade at grenfell tower

02:54:43 neil wilson fabricated

02:54:52 she sends this email to mark stackley of holly

02:54:55 holly subcontractors on the 7th of january 2015.

02:55:06 and you can see that there are some attachments everywhere here the ps4 and do you see that as the third attachment

02:55:18 do you see that as the third attachment it says reynabon bba do you see that

02:55:23 you know

02:55:27 yes and the text of the email says please find attached details of the kh-35 cassette system we use and all the other info we have for rain able

02:55:53 and the attachments that he sends we've we can see this from a document reference i shall give you but we

02:56:03 but we we can see that it's still the same 2008 original bba certificate take that from me

02:56:10 me and that's cep cep3053377 so no need to go to it

02:56:15 go to it my question is can you explain why the original bba certificate which says that reynabon 55pe had european class

02:56:28 reynabon 55pe had european class b was still circulating in the market as late as january 2015.

02:56:38 certificate

02:56:53 no no

02:57:00 can we look at another of the attachments which he sends which is the uh renault bond brochure this is at cep3053376 please

02:57:14 brochure this is at cep3053376 please examine

02:57:18 your bond uh this is uh the discover new perspectives brochure uh which doesn't have a french

02:57:29 brochure uh which doesn't have a french translation we've already seen a copy of this mr schmidt

02:57:49 if you could just go down to page 16 to confirm that

02:57:59 it's written vertically on the right hand side

02:58:11 and if we go back to page 13 now please page document and look at the right hand side of the page and blow that up so that everybody can see that we can see that at the top

02:58:22 can see that we can see that at the top under certification and again mr schmidt this is the document we saw last week it says that reynabond p e obtains a b s 2 d naught classification

02:58:35 obtains a b s 2 d naught classification pursuant to certificate r a 0 5 0 0 0 5 a which is the 2005 5 a rivet test

02:59:16 do you agree with me here's my question do you agree with me that claims made in this document for european

02:59:23 european classification for pe as a class b were by january 2015 substantially out of date

02:59:40 success

02:59:58 yes there's a document dates from 2008

03:00:02 can you explain why your customers are still

03:00:06 still being still using this ancient piece of marketing literature that is not only substantially out of date as you've agreed but now materially wrong

03:00:22 continuous

03:00:38 [Music]

03:00:43 no i didn't think that document was still available

03:00:50 somewhere do you mean by that answer that you didn't know that substantially and materially wrong marketing literature was still in circulation in the uk market

03:01:03 circulation in the uk market excuse me

03:01:25 [Music]

03:01:32 a [Music]

03:01:40 i don't know at what time that literature was given to cep in that specific case

03:01:56 [Music]

03:02:13 i can't believe that it was given at that time

03:02:17 that time to cep when cep send it to its uh client or to harley ollie facades well mr chairman uh it's now just gone one o'clock

03:02:28 one o'clock and there's a few more questions on this topic to pursue with this witness but i'm not going to finish that in a reasonable time before the necessary break should we stop there then mr millet

03:02:39 then mr millet um mr schmidt we're going to have a break now so that we can all have some lunch

03:02:44 lunch we'll come back at 2 o'clock please

03:02:54 please don't talk to anyone about your evidence over the

03:03:05 thank you

03:03:24 you

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