Grenfell Tower Inquiry - BRE & Simco contractor Evidence - Tuesday 2nd March 2021 (2/2)
00:00:07 good afternoon everyone welcome back we're going to hear evidence from a fresh witness this afternoon
00:00:14 afternoon mr patrick jones so my first task is to see whether he is there and can hear me and see me hello mr jones hello i can hear you and see you very good thank you very much can i just
00:00:26 very good thank you very much can i just ask you do you have a full screen picture i do yes i'm good because previous witness had a bit of trouble with that i just wanted to check that now you should have on the screen in
00:00:37 now you should have on the screen in front of you the words of the affirmation which we ask witnesses to make do you have it there i do could i probably then please read the affirmation out yeah i do solemnly sincerely and truly
00:00:48 yeah i do solemnly sincerely and truly declare that i affirm that the evidence i shall give shall be the truth the whole truth and nothing but the truth good thank you very much indeed now before you start giving evidence there are one or two things we need to cover
00:01:00 are one or two things we need to cover um just housekeeping matters really can you confirm for me that you're alone in the room from which you're giving evidence i am alone yep thank you can you confirm that you have no documents or other
00:01:12 that you have no documents or other written materials with you i have nothing no i have no documents no writing
00:01:17 writing very good and uh can you also confirm that your mobile phone is in another room and that you don't have any electronic device with you that's capable of receiving messages yeah i've got no i've got nothing in
00:01:29 yeah i've got no i've got nothing in here with me everything's elsewhere very good thank you very much indeed now just um
00:01:35 just um i i hope we're not going to have trouble with sound or vision we haven't had very much trouble so far but if there is a difficulty what i'll do is to call for a short break and we'll sort it out and then get back to you when we're
00:01:46 out and then get back to you when we're when we're ready um we'll have a short break during the afternoon somewhere around about 3 15 so you'll be ready for that if you need
00:01:58 so you'll be ready for that if you need but if you need an additional break at any time just indicate and we'll try and accommodate you all right okay is there anything you'd like to bring to my attention or any questions you'd like
00:02:10 my attention or any questions you'd like to ask before we start no i think um okay thank you ready to go right and i'm miss sullivan i understand you're going to examine this witness yes thank you mr chairman when you're ready off you go thank you
00:02:22 ready off you go thank you thank you good afternoon mr jones um before we start could you just confirm again that you can see me and hear me
00:02:30 hear me i can hear you and see you quite clearly excellent
00:02:34 excellent well can i start by thanking you for attending this public inquiry and to come and give your evidence it's very much appreciated if you have any difficulty understanding any of the questions i'm going to ask
00:02:47 any of the questions i'm going to ask please do just say that and i'll ask it again or put it a different way
00:02:54 and finally before i start um just a reminder
00:02:58 reminder that if you could keep your voice up so that the transcriber who is also on the hearing
00:03:03 hearing can take a note and you could not not nod or shake your head but say yes or no when you're answering that would be very helpful okay
00:03:14 that would be very helpful okay understood thank you um mr jones you've provided some written answers in response to questions sent to you by the inquiry could i please take you to those um
00:03:27 could i please take you to those um they'll appear on your screen and they are at sef zeros 75
00:03:43 and you can see in the top left hand corner
00:03:47 corner hopefully it says just under the inquiry header
00:03:52 header please find highlighted text as answers to the best of my knowledge and recollection patrick jones 10th november 2019. can you see that i can yes um so although that document's
00:04:04 i can yes um so although that document's not signed can you confirm uh that that represents your answers to the questions that the inquiry puts you in that letter i would i believe that one i mean i can't tell from that part that section
00:04:15 can't tell from that part that section of it but
00:04:16 of it but page two piece just seems james can see
00:04:20 yeah that's that's mine i was like it seems silly but i was having trouble with my pdf editor at the time that's why it's in such a state like that that's not a problem mr jones
00:04:31 that that's not a problem mr jones um have you read that document and your answers recently uh already a couple of months back a few weeks back yeah i have i have revisited it since i did it originally yes
00:04:42 did it originally yes and so could you confirm that the answers that you've given there are true and accurate yes i'll still stand by everything i answered yes have you discussed your answers to those
00:04:54 have you discussed your answers to those questions or your evidence generally with anyone before coming here today no okay i'm going to ask you then a few questions about your background um we're going to focus then on 2014
00:05:08 um we're going to focus then on 2014 and in particular the work you did for simcoe
00:05:12 simcoe in relation to two tests carried out by celetex at the bre in february in 2014 so starting with your background in 2014 you're a self-employed cladding
00:05:24 in 2014 you're a self-employed cladding installer yes that's correct yes uh and if we could go back to your your statement um at scf6075 on page two
00:05:40 and zoom in on question two and i think as much as we can on the yellow highlighted text
00:05:53 highlighted text we asked you there about your previous experience and you've answered uh that you have been working on numerous green screen cladding contracts nationwide since 1999
00:06:05 nationwide since 1999 um can i take it that in terms of your own work
00:06:09 own work on those contracts that would be installation of the cladding yeah that's correct yes and can you remember what kinds of rain screen cladding you had worked on uh very very numerous um a lot
00:06:22 uh very very numerous um a lot a lot a lot of um in the first few years i did a lot of just the substrate which was the lsf and the
00:06:29 the you know in the particle board but there's so many so many different products i did i did quite a lot of work on trespa
00:06:37 on trespa and reservoir you know i was in high pressure laminates and so so many various different products so many had you worked on any projects that
00:06:48 had you worked on any projects that involved buildings over 18 meters in height by 2014
00:06:55 can't recall i might well have done i've not done too many highways buildings so i don't i don't really think i did it was mainly hospitals and offices and schools you know in in the early years i
00:07:07 schools you know in in the early years i didn't do
00:07:08 didn't do any high-rise stuff
00:07:11 and i think that's now gone from your screen but um you also said in your answer to that question that you had installed
00:07:21 uh there we go it's right at the end of your highlighted text yeah you'd installed various products at testing centers for just different testing regimes
00:07:33 yeah to elaborate on that is that what you're asking me to i've been a i've been a fixer for a long long time it was only i started cladding in 1999 or thereabouts
00:07:44 thereabouts and but before then i was shock fitting and sealing install and internal installing and i i used to get the jobs of doing testing for acoustic tests and
00:07:57 doing testing for acoustic tests and fire tests for the different products really
00:08:00 really okay that's um partly what i wanted to ask you
00:08:04 ask you it can i just start which testing centers were you familiar with i've i've been to and cardington and
00:08:15 and cardington and uh
00:08:19 win win tech which is kind of why i'm not sure
00:08:23 not sure yeah we tick how do you buy 2014 before the celetex tests been to or been familiar with the bre
00:08:34 i have been to bla i can't recall that i have been to bo a couple of times whether it was that one or not and if it was before or after that test i can't i really couldn't answer that okay how many times do you think you
00:08:47 okay how many times do you think you have been
00:08:48 have been i think i've been to bla on on another test although i can't really recall what if it helps you at all the bre is based in watford um does that help you with how often you
00:09:01 um does that help you with how often you might have been there or when no no i i'll say no i would call the bla you know well you know from the from the time i was there i i think i might have been in a different building at the bre
00:09:13 building at the bre another time for another test i think was years years prior i think it was an acoustic test for a ceiling for ceiling panels that's what i think i've been to the only one time before but
00:09:25 time before but that was you know in in the fire test hall i think this is that was the only time i've been there for that purpose i see you mentioned that you uh as well as acoustic tests
00:09:36 as acoustic tests you had carried out fire tests um by this point can you remember what kind of fire tests those were it was it was a fire test for it was a
00:09:47 it was it was a fire test for it was a carding term and it was for cape marine was it a large-scale fire test a bs-8414 test or something else i really don't know i'll say i've got no
00:09:59 i really don't know i'll say i've got no no knowledge of the test i'll say on they just instruct me as to what to install meticulously and i install it well it's got no knowledge of the test that was
00:10:10 of the test that was you know there was that was there yes i was going to come to that um i think in your written answers you said uh and i don't think we need to go to it but we can if you want to um you said that you
00:10:22 to um you said that you were unaware of bs8414 in 2013. is that does that sound right yeah that's correct yes so just to be completely clear before
00:10:33 so just to be completely clear before february 2014 did you have any knowledge of what bs8414 was no and you were contracted by simcoe to carry out the installation work for
00:10:45 to carry out the installation work for the
00:10:46 the test for celatex in february 2014 is that right yes that's correct yeah and um if we could call up page two of your statement
00:10:58 it's seo oh it's coming uh in your answer to question one the second half sentence you say
00:11:10 the second half sentence you say uh that you would probably have been in contact with john simmons or graham is graham is that graeme smith of simcoe it would have been great smith yes
00:11:22 been great smith yes had you worked for simcoe before febria 2014
00:11:26 2014 yes do you know roughly how often
00:11:31 uh no i've been involved with with uh with those people for a number of years not in the guise of simcoe but in another cladding company called ecl limited and
00:11:43 limited and i've just known those people for a while so
00:11:46 so they you know they've known me and what what kind of jobs have you been working on them with as ecl
00:11:57 i started planning installing with in 1999
00:12:00 1999 right can you remember when simcoe first contacted you uh about installing the test rig for the february 2014 test no i can't remember that no it wouldn't have been
00:12:11 that no it wouldn't have been far i think i would be working for them at the time although i can't i can't remember where or which job i mean i've not looked into that i could suppose i could find out through pass records but you know i
00:12:24 through pass records but you know i would have been working for them normally the case will be laid down phone will say will you will you go here and i'll say yes or no
00:12:32 yes or no that would be that was it but it wouldn't have been long before i wouldn't i thought generally there's no leading time or anything like that usually can you remember uh did they call you up on this occasion
00:12:43 on this occasion i really i really can't remember i would have thought so very little was done email you know was back then so yeah they would have been they would have telephoned to me
00:12:54 have telephoned to me i appreciate you've said uh you can't recall but do you remember anything about what you were told um about what works they wanted you to do before you got there
00:13:05 no is it they'll say good good just go to the bra someone someone will meet you there and you know
00:13:12 you know that's it that that's basically that's all the information you know you would generally get so they could give me the address and then the time and the date and say turn up everything else will be there and
00:13:23 up everything else will be there and then somebody there from meet you somebody will meet there could we go back
00:13:28 back to uh question three of your statements
00:13:36 uh you see you say i recall it was mentioned that the test was for an over 18 meter in-store criteria
00:13:45 criteria but i had no more understanding or involvement in any testing particulars yeah i understand yeah i mean yeah that's correct sure can you remember
00:13:56 sure can you remember who who it was who mentioned that it was for over 18 meter installation yeah it was john roper okay so this isn't referring to a conversation you had with simcoe this is
00:14:07 conversation you had with simcoe this is a conversation with celetex is it this is a conversation with solotics
00:14:11 solotics for that particular job i had very little involvement at all with simcoe on on that you know on on that job they they phoned
00:14:22 you know on on that job they they phoned me and asked me to go there which was which was nothing unusual and i went there met with john roper and that was it and until i wanted to payment from simcoe for for
00:14:34 i wanted to payment from simcoe for for the work
00:14:34 the work i'd i'd hardly hardly any contact with them at all i think i asked for the i think i phoned them or emailed them asking for the drawings on the first day
00:14:45 asking for the drawings on the first day on the second day and other than that i don't think simcoe were particularly involved at all
00:14:52 so turning to uh john roper in the contact you had with him if we can go scroll down slightly in that document question five
00:15:07 uh thank you you say in the second sentence there um the process was what you've just told us i was asked by simcoe i don't recall who to attend gallery and
00:15:18 i don't recall who to attend gallery and meet someone uh who who transpired to be john roper yeah exactly yes
00:15:23 yes was that the first meeting you've had with john roper at the bre yeah no yeah never met him before that point had you had any contact with anyone from celitex before that point
00:15:35 anyone from celitex before that point no i don't think so possibly let's say it's a
00:15:46 can you remember did john roper explain that celetex were testing an insulation product do you yes and what did he tell you about the product if you can remember
00:15:59 uh nothing really i mean obviously i was aware of celetex because we install it i installed it all over the you know all over the place onto various different jobs but i'll
00:16:10 onto various different jobs but i'll just that that was a that was a new a new product now actually i didn't he didn't say it was a new product he just said that it was uh it was just it was a test to achieve over 18 meters which
00:16:23 over 18 meters which that's that's as far as you know that's just as much information as was told really did he explain anything about why they were testing
00:16:32 testing uh two over 18 metres to you or just the fact
00:16:36 fact that obviously i understood through just general knowledge that you know that it uh up to id maters was a specif you know a specific test
00:16:47 a specif you know a specific test to install over 18 meters other than that you know so that so if this product asked the criteria then they could sell it above 18 meters
00:16:58 then they could sell it above 18 meters obviously that's the reason for it that's as much as i understood and was that just general knowledge you'd picked up on the job that there was
00:17:06 was some testing criteria for above 18 meters
00:17:09 meters yes um but you told us you you knew there was a test but you didn't know anything about what test it was well it's just i mean that that is that is
00:17:20 is that is as much information as all would have on that i know some products
00:17:29 products you know they're only classified up to 18 meters and things above 18 meters is a different uh criteria classification so although other than that i've got you know what test
00:17:40 know what test was involved or you know i just don't know i can say bs8414 now and various others that i'm aware of now at the time
00:17:50 the time you know that's it we're going to turn now to to that test and i'm going to ask you some questions about what you can remember about the
00:18:01 about what you can remember about the installation
00:18:04 the test was carried out on the 14th of february 2014. do you remember how long it took you to put up the rig from start finish
00:18:15 put up the rig from start finish not exactly but i wouldn't have thought any more than two two days three days might be older thought
00:18:22 thought were you installing the materials for this the february test uh by yourself uh i believe so i think i had some
00:18:30 had some i had somebody with me at some point who i
00:18:33 i can't remember who they were just because of the weight of the panels but i've got commonwealth and we're going to look at the drawings that you were given to help you with installing that
00:18:45 to help you with installing that so if we could go to bre four zeros five four two two
00:19:01 this is an email from luke cresswell at simcoe it's an email to phil clark and i think we can see he's copied in i think it's your personal email address
00:19:13 i think it's your personal email address so it's been partially redacted um and he says that uh unfortunately our site guys have turned up without drawings could you print off the attached for them
00:19:24 the attached for them and there are two attachments and just to help your memory if we can just quickly look at those the drawings which were attached that's bre four zeros five four two three
00:19:40 so you had
00:19:43 these do you recognize that no not specifically because obviously you keep watching it i've seen thousands and thousands of drawings but yeah they look yeah i don't
00:19:57 yeah they look yeah i don't specifically recognise them from that time but yeah i would i would say that there
00:20:02 there yeah they're in yeah i would say that they are
00:20:06 they are probably the ones that were there yes the other drawing that was attached uh was at vre 40 5424 so we could just call that up to
00:20:19 and same question can you remember this specifically or i can't remember the specific drawing but it look it looks totally in keeping with that with that test we got i would call the layout of
00:20:31 test we got i would call the layout of it mean that that layout would fit that test week so yes i would say that that problem probably is the drawing for for that
00:20:39 that area and that test i mean looking back at the photographs that i had yes that is the layout that you know was near us well we've seen um
00:20:50 seen um from the email we were just looking at that luke cresswell asked phil clark at the bre to print these out
00:20:57 these out for you and i don't think we need to go to it
00:21:01 to it but mr clark has told us and for the record it's uh bre 40 5768 at page 36 um that he did print those out and as far as he knows
00:21:13 far as he knows those were the drawings that you used to construct the rig yeah i would agree with that there would have been no i must have had those drawings from phil clark because you know otherwise i
00:21:25 phil clark because you know otherwise i wouldn't have been able to build it because you know i'm not saying simcoe's involvement was very little so i must have had those drawings because no one else visited so yes can you remember were those the only two drawings you had yes
00:21:38 the only two drawings you had yes i don't yeah nobody would nobody give me any more no and were you giving any other documents um
00:21:46 um to help with the installation uh i really can't recall i may have had um product specific for the
00:21:57 product specific for the actual fire barrier i know that i know that a man did turn up and show us the correct application of the fight barrier i think it was so sideways but i can't i
00:22:09 i think it was so sideways but i can't i can't remember his name and i can't remember which company he was from don't just recall a man that john roper introduced one morning and he showed us the correct application in the you know the correct fitting procedure of that particular
00:22:20 fitting procedure of that particular product
00:22:22 product in terms of the product specification could you just um help me by explaining how is it that that would have been helpful for you or something
00:22:30 something to have if it's if it's um so not not the product technical details but the install details sometimes they they if there's a different product generally everything's
00:22:41 generally everything's you know it's very similar in store criteria but you know something might be you know it might have a particular washer or they might want to the fixings fixed at a particular height or centers sometimes i don't recall anything but
00:22:54 sometimes i don't recall anything but there may
00:22:54 there may have been something is that based on a sense of what normally happens yeah so it's not
00:23:02 it's not it's not a memory or it's just it's just what
00:23:06 what normally happens here if it's a different product or or something that needs to be installed in a particular way as in a test then usually generally they would cover all bases and say
00:23:17 all bases and say you know these centers need to be at 300 100 this way so you generally would get a specification an install specification sheet
00:23:26 sheet although i can't really recall having one
00:23:30 one um i just wanted to ask you a couple of questions about this this person possibly from sidewise who came along with john roper one day um
00:23:40 um was that before the february test i can't remember which test it would have been at it probably would have been at the first test because i imagine it was during or poor to the first test
00:23:53 um but that's on the basis that that makes sense rather than that you have a recollection that that's the case is that right yeah that's correct yeah and i'll say it it would have come in yeah there's no
00:24:04 it would have come in yeah there's no point in coming after the first test where you
00:24:06 where you you would have evolved the first test and i know you've said that you can't remember who it was or what company they were from
00:24:14 were from um but you have also said that it might have been sidewise could you just help with what's led you to think that i think
00:24:22 think i think the fire barrier that was installing what soyuz is a sidewise type i can't we call the the brand but it's a sideways style so but i'm not actually sure
00:24:35 style so but i'm not actually sure of the fire barrier type or manufacture but you know it is whoever was supplying it i really don't know the answer to that one
00:24:44 that one you said he came with john roper was john roper with you every day when you were doing the installation no most days but not every day now
00:24:53 day now and how long would he stay for a good few hours generally and um was he giving you any verbal instructions about how they wanted the rig to put
00:25:05 about how they wanted the rig to put together yes can you remember anything he said not specifically um
00:25:16 not specifically um was he effectively expecting you to just build and install the system according to the drawings that you've been given yes and i imagine
00:25:27 yes and i imagine it obviously if it if it's a test to try it there's a tester trying to achieve
00:25:33 achieve certification he studied it i mean it's not
00:25:37 not not the first time it's obviously the somebody from the companies got a massively invested interest to ensure that the test is as accurate and as you know it's installed as accurately as possible
00:25:49 installed as accurately as possible that's what i understand it was therefore so it's your understanding he was there to um oversee your work yeah obviously the quality control yes yeah and apart from john roper um
00:26:01 yeah and apart from john roper um and also you've mentioned this man possibly from sidewise did anyone else give you any instructions about how to install the rig um i think we might have had
00:26:12 might have had uh light uh guidance from the bra staff the self just to say you know
00:26:19 know just because obviously they know their they know their test rigs but i do remember people saying you know you
00:26:27 you fixed to this and you know fixed in this section and fixed to that section but other than that no so when you say like guidance
00:26:36 guidance and think doesn't say that they are fully familiar with their test rig in that they
00:26:40 that they just just outline the procedure of you know you fix to this and then you know fix fixed to these beams and fix to this columns etc
00:26:51 fix to this columns etc and then when you get to that stage well obviously they're they'll they're watching it's in it's inside their hall so i'll say when you get to that stage you know stop and then we'll come and install our you know sensors as such
00:27:03 install our you know sensors as such and then you know we continue um if you say they're watching were they was there someone from the bre their present
00:27:14 their present at all the time it's inside there it's inside there there wasn't somebody standing watching over us but obviously there are people around i mean there's several
00:27:25 several probably six or eight test weeks in that one hall
00:27:28 one hall in question so obviously they're working on other rigs and doing other things and you know there's people around all the time mostly
00:27:37 i i wanted to ask you about that actually um when you were installing the rig
00:27:41 rig were you the only person working on um as in was it just your rig which was having work done or were there work going on on the other rigs in the bernhard we were the only people actually
00:27:53 we were the only people actually installing on the rigs but there were people
00:27:55 people who were people coming in and looking and
00:27:58 and um setting up i think it was mainly the blv people but there were other visitors there were no tests going on and there was no other installers at the time i'm going to come on to some questions about
00:28:09 questions about the bre's processes and procedures but just before i do just one last question about the man maybe from sidewise um do you know if he might have been chris mort does that name mean anything
00:28:21 chris mort does that name mean anything to you
00:28:22 to you more i really can't recall but more could possibly be it but you can't remember
00:28:29 remember no i really already can't remember his name no
00:28:33 name no i remember what he looked like but other than that well are you able to give us this general description um but that time he would have been
00:28:44 but that time he would have been early 50s or i thought um caught a stocky rounded it meant slowly bolding wearing glasses other than that oh no i just remember because he was
00:28:55 oh no i just remember because he was he was showing me he was showing me and the thing how to how to install the you know how to bend the tabs on the foil barrier that could you know one one way or the other it was a different product that i didn't you know was not totally familiar with
00:29:07 you know was not totally familiar with it he says we'd like you to install it in this manner do this do this do this et cetera
00:29:13 et cetera and just before i move on was it just the fire barriers that you had it wasn't wasn't any other component where someone came into
00:29:22 came into like that no it was just it was just the fly barrier system um okay i'm going to move on to some questions uh about what you might have seen about how the bre worked
00:29:33 bre worked um in february 2014 so at that time when you're installing that that first test did anybody um tell you anything about what standard practices were for the bre
00:29:48 what standard practices were for the bre uh sorry could you rephrase that in what way
00:29:52 way did anyone say to you um look these are our standard operating procedures and this is how we're going to be doing things uh so you know what's going on
00:30:01 on yes yes that would have yeah yeah i'm sure we had an induction yes i'm sure we had a verbal induction to opt to work in that area
00:30:12 opt to work in that area was that administered by a member of bre staff
00:30:15 staff yes it would have been yes can you remember what that induction covered no i think it was it was mainly just a general induction as in uh you know the fire escape route
00:30:28 uh you know the fire escape route procedures and and we couldn't be in there i do remember that we couldn't be in there when there was a test going on um so they had other tests
00:30:39 um so they had other tests set up in there so you know there's a period of hours where we wouldn't be able to work so we you know finish our work point this time other than that no i don't think any more than that no
00:30:51 more than that no i think the bre have explained that they would have done a health and safety induction at least um is it that sort of thing that you're remembering yes do you remember anyone telling you uh
00:31:03 do you remember anyone telling you uh the bre had processes in place to check and record the installation and design of the flooding systems
00:31:13 some i don't recall it but they they must
00:31:16 must they must have done because i'm aware so somebody
00:31:19 somebody somebody must have told us yes um we've heard a bit from phil clark about that um so i'm going to go through that what he's told us but before i do that
00:31:30 what he's told us but before i do that could you just tell us anything you can remember
00:31:34 remember about um what you must have been told or what you know not now know yeah well in that particular test rig
00:31:42 test rig they you know i was told the location of the fire and you know where that would be and where the sensors would be because obviously we had to avoid fixing points as to where the sensors required and
00:31:56 required and that was it they also was told you know we had to reach a specific duration of which i can't you know i can't recall it you know sort of things
00:32:03 of things you know meant little to me at the time and
00:32:07 and then you know that was it and then i would
00:32:11 would we would complete it or we'd partially complete it they would install their sensors then we would complete it then they would test it and then test it during the test and after the test and record it and
00:32:25 and after the test and record it and record everything and obviously i must have been told that i didn't just guess it so yeah when you say we had to reach a specific duration are you talking about
00:32:37 duration are you talking about how long you had to put the rig together or were you talking about the test that was going to be carried out no the the test obviously i i was aware that you know you know you know it says we
00:32:48 you know you know you know it says we know what's it for it you know it has to reach a specific amount of time at a specific temperature and were you told
00:32:57 told uh who at the bre you should raise any um problems or quests or questions with uh i must i must have been but
00:33:08 uh i must i must have been but you know they were just said to come come and see us there was an office upstairs and they said come and see us up there you know if you need anything uh do you remember who that was no
00:33:20 uh do you remember who that was no if phil clark again if phil clark's got grey hair
00:33:24 grey hair i really can't remember his name terrible names but if phil clock's got grey hair
00:33:29 grey hair that would have been phil clark and did did you get the impression that it was the person whose office it was who was saying
00:33:38 saying just give us several people in the office but yes okay um could we go to bre four zero five seven six eight at page eight
00:33:50 five seven six eight at page eight please
00:33:58 uh this is from mr clark's witness statement which he's given to the
00:34:04 inquiry and you can see under question 2b which is in bold and underlined he's there's paragraph 38 uh and he says the client slash project
00:34:16 uh and he says the client slash project officer
00:34:17 officer works with sponsor to ensure the system is correctly installed all required information regarding materials fixing and names materials has been provided and then in paragraph 39 he goes on to
00:34:29 and then in paragraph 39 he goes on to explain
00:34:29 explain some of the checks that the bre carry out
00:34:33 out um so first of all did you understand that there was a person who was the bre project officer or generally in
00:34:44 the bre project officer or generally in charge
00:34:45 charge for this test well yeah after i was aware that there was somebody that was in charge and there was one particular man it was quite obviously the man in charge uh i'd guess from
00:34:59 man in charge uh i'd guess from from context that it was phil clark but and i was obviously aware that you know i would be testing and measuring examples of everything yeah but
00:35:08 yeah but he he did have a lot of obviously i was there installing and so details like that he would have been speaking to john roper they would have spoken to us briefly obviously he did speak to us but
00:35:20 obviously he did speak to us but you know things like this i'm sure he was he was he was talking to john roper well could we go to page 42 in this statement
00:35:33 um paragraph 177
00:35:40 and he's described here that he would have taken notes photographs and had email correspondence with client under contractor he also then goes on this would have involved day-to-day checking of the
00:35:52 involved day-to-day checking of the system
00:35:53 system and ensuring the safe working practice of the contractors working on site and that would obviously be you wouldn't it yeah
00:36:01 it yeah do you remember phil clark or indeed anyone from the bre um carrying out health and safety checks yeah
00:36:08 yeah yeah definitely those people like i said there was there were definitely people around watching and looking and recording
00:36:16 recording and photographing you know at various intervals during the install you know on on the rig that we were on and
00:36:23 and and other works also there were
00:36:29 what do you mean by that do you mean taking notes yeah yeah definitely taking notes yeah there's people walking around the the rig is has got a scaffold a raised
00:36:39 raised scaffold all the way around the back of your stairwell there were people on there
00:36:44 there while i was on the machine on the phone there's there's definitely people on the back there you know you don't say obviously i wasn't paying too much attention to what they were doing but for sure there were people walking around taking notes and measurements and
00:36:55 around taking notes and measurements and installing you know the sensors yeah there was definitely people who recorded what was
00:37:00 what was occurring for sure and were they you mentioned
00:37:03 mentioned that they were taking photos at intervals um do you remember phil clark or anyone else from the bre uh taking photos of the components before you started putting them
00:37:14 before you started putting them up i can't recall that no i can't actually understand anything like that i know
00:37:20 in terms of the photos that they were taking when you say at intervals how often would that be i don't know i really can't remember i just i do remember that you know you know
00:37:30 know there were people in there there were people photographing but not sales was just installing and when you got there where did you get the materials from were they
00:37:44 materials from were they in a store or a pile how did you find them just some were just inside the doorway there's a big roller shutter door on the front some with materials were inside and some materials were
00:37:55 materials were outside and some were delivered during the process we might come back to that for the may test but
00:38:04 test but uh did anyone check those materials at the bre
00:38:08 the bre i don't know that i should i just i'm only assuming yes i'm sure they would have done but i really i can't recall actually saying it how could that evidence not know
00:38:19 it how could that evidence not know and you don't recall seeing anyone checking them against the drawings or specification or anything like that i can't specifically recall that no uh if we could go back to mr clark's
00:38:31 if we could go back to mr clark's statement
00:38:33 statement at page nine
00:38:42 paragraph 40 mr clark gives a list of um what he says is the biari's general practice
00:38:54 practice he tells us that generally bre staff undertake a visual inspection of the constructed test rig so do you remember anyone visually inspecting it after you'd finished building
00:39:09 specifically what they were doing i couldn't say but yeah i do i do remember people you know like i said previously i do remember people measuring you know and ensuring that the
00:39:21 measuring you know and ensuring that the work that
00:39:21 work that we've done you know yeah again exactly so that the criteria is correct not the width of the opening and that the height of the the head of the half and the height of
00:39:33 the head of the half and the height of the so i
00:39:34 the so i do remember that the height of the head of the hearth section being critical i remember the height of the rig being critical so they must have measured it but i can't really recall
00:39:45 but i can't really recall anyone specifically doing it but they you know
00:39:48 you know vaguely remember they always stop measuring things so sorry you know you think they must have been measuring something can you remember what they
00:39:59 something can you remember what they were measuring no exactly what they were measuring i can't i can't recall now do you remember anyone measuring the width of the cladding panels
00:40:13 do you remember anyone taking a record of the system as it had been built up
00:40:20 not specifically but as i said previously there were people in there photographing at various points while i was installing so i would assume that i had a record i i
00:40:32 i would assume that i had a record i i just
00:40:32 just understood that they took a record of you know intervals all the way through the whole process were those did they seem to be regularly spaced intervals
00:40:43 spaced intervals i can't recall that no did anyone from the bre
00:40:48 the bre uh undertake any checks to ensure that the system was being correctly installed were you just left to it no they did as i said they did they were there they were checking yes
00:41:00 they were there they were checking yes they definitely were checking and do you recall anyone uh checking or comparing
00:41:07 comparing the rig against the drawings that had been provided and which you had copies of
00:41:12 of i can't specifically remember that no when you got to the end of your task of installing did you uh have to tell someone from the bre that you were finished
00:41:24 i think yeah i think we did i think we did tell more i can't remember whether it was specified or whether we just said it's you know more i'd occur to say that we're we're now leaving the building
00:41:36 we're we're now leaving the building do you sorry they they they were there and if i remember royally that their their office on the
00:41:47 office on the first or second floor of the hall overlooks the whole area so anyone in the office would be able to see what we were doing anyway so and as i said there were people around most of the time did i just
00:42:00 around most of the time did i just clarify something you just said there was an office on the first or second floor
00:42:05 floor yeah and you've obviously told us there was a
00:42:09 was a walkway running around um was it your impression that there were two floors then the office was on one of those uh yes it's quite a it's it's like um it's
00:42:22 yes it's quite a it's it's like um it's quite a high-rise hall obviously it must be at least six to ten meters maybe higher to the roof and i'm sure that the the office is on the on the second or something it could
00:42:33 on the second or something it could could be the first floor i can't recall but it's definitely higher up it overlooks the overlooks the hall the fire test hall well if i if i'm if
00:42:47 uh was there we were just talking about um
00:42:50 um whether you alerted anyone when you'd finished was there any sort of formal handover process or formal sign-off
00:42:57 sign-off i can't remember do you remember if anyone checked the rig before it was handed over back to the bre i can't remember that oh look said i i
00:43:09 i can't remember that oh look said i i was fully aware that they were they were recording and testing and watching everything that we did so you know i just took it as understood that
00:43:17 that they they knew and they knew when we was ready we did we did definitely tell people that we'd finish them when we left and you know and is everything correct you know we were talking to the staff
00:43:28 you know we were talking to the staff and various members you know so yeah i think you said earlier that there was definitely someone
00:43:35 someone whoever it was who you know was the guy in charge as was he somebody you alerted to the fact that you had finished whether out of courtesy or because you had to if he was
00:43:47 had to if he was if he was there yes it would have been the first port of call because obviously he was the man dealing and so just to be um clear it's your evidence that in addition to
00:43:59 evidence that in addition to john roper of celestex and the bre were also carrying out checks whilst you were installing the rigs in the rig in 2014 and and maybe after
00:44:11 in the rig in 2014 and and maybe after yes i understood that they were testing and checking yes measuring sorry yes did they make any the bre or celitex make any comments in
00:44:22 the bre or celitex make any comments in relation
00:44:22 relation to the installations you were going in
00:44:28 carl
00:44:31 can't really recall it they did i think they specified it accurately enough and the drawings must have been accurate enough for us to to build it how they wanted the first time
00:44:42 how they wanted the first time i can't it that they may well have done i can't i can't remember that i can't remember them i'm making any verbal amendments during it was it your understanding
00:44:54 during it was it your understanding that the bre and celetex were both aware of what was on the rig in february 2014 definitely yes would it have been possible given
00:45:05 possible given what you've described about people being around in and out of the time uh for you to have installed something without the be all real bellatex knowing was there
00:45:15 was there no no
00:45:19 no no and i think you've told us that that was the first time uh you you had been at the bre to install a fire test so as far you wouldn't have had anything to compare it against to know whether
00:45:31 to compare it against to know whether that was normal would you
00:45:34 sorry can you rephrase that sorry um you
00:45:40 um you since it was the first time you were there yeah you couldn't say whether the level of checking and the level of activity was normal for the bre or not could you no i couldn't i couldn't say that but
00:45:51 that but but having done similar tests on different
00:45:55 different things not specifically for fire it was you know that's generally sorry par for the course so they
00:46:04 so they obviously the client's got a vested interest in it it's it's done to its best capabilities so it's accurate so that it's got his best chance of passing then the people who record it obviously
00:46:16 then the people who record it obviously i have to ensure that it's done correctly otherwise the tests would be invalid wouldn't it so yeah so everyone's checking and i understand that just from common sense then but as for the bras
00:46:28 common sense then but as for the bras exact procedure no i've got nothing to gauge their own procedure
00:46:34 procedure how did it compare with your experience of other tests very similar very similar okay i want to now move on to the the second test which is in may 2014.
00:46:47 second test which is in may 2014. um i'm afraid some of these questions are going to be pretty similar um but it's important that we we understand for me what you can remember so i think i'm right you were employed
00:46:58 so i think i'm right you were employed by simcoe again to install the test sample in may 2014 right
00:47:04 right yes and who was it can you remember who contacted you on that occasion to tell you there was going to be a second test i can't i can't recall that sorry
00:47:16 sorry do you remember when roughly that might have been
00:47:19 have been no i i don't know other than looking back through the possible emails but no let's say generally that i don't give you much warning you know i never got much more in the
00:47:30 never got much more in the morning sorry it would have been a week at the very most and um is it right that this time there was
00:47:39 there was somebody somebody else was employed to go along and help you with the installation yes and we have that i think phil clark uh has told us in his witness statement
00:47:50 uh has told us in his witness statement that he thinks wayne jones wayne jones wayne jones probably was was with me that might have been the first time i believe
00:48:02 wayne jones is my brother who i generally worked with all of the time but one one one time he wasn't there with me
00:48:11 with me well can we look it might just help you if we look at mr clark's statement why he says this if um we could go to bre 40 5768 at 65
00:48:23 at 65 that's page 65
00:48:28 and then it is right at the top of that page it's the end of paragraph 266 so actually maybe if we could go back a page to the bottom of page 64.
00:48:46 this you can see um in context that mr clark's talking here about the may test uh because he says that the installation was undertaken by the installers of the first system
00:48:58 by the installers of the first system which has already happened um and then over on page 65 he says uh it appears from what's on the bre's files
00:49:09 bre's files um that the work was undertaken by by you and wayne jones um so can you remember whether it was the first test or the second test well i would think i think wayne was with me
00:49:20 i would think i think wayne was with me on the first test and then not on the second test because as i said there was somebody simcoe sent somebody else to to assist me with the lift and the puddles because they were heavy
00:49:31 they were heavy you know there were nine all right 12 12 mil panel and it was it was like 90 kilo i think so number that that man i can't remember who he was
00:49:43 who he was um so you think you had some views for the first test i believe thank you so you had someone with you um for the second test but not wayne james is that right i think so yes
00:49:56 is that right i think so yes and were they with you throughout when you were installing the second test or were they
00:50:00 were they like the first test just there to help you moving the panels
00:50:04 like on the second test over there when was with me it would have been with me throughout we worked together for for years um so yeah on the second test
00:50:15 for years um so yeah on the second test whoever they sent they they would have been there in place of wine i don't think why wanted to go i can't quite recall this long ago but um
00:50:26 long ago but um yeah they would have been there installing with me
00:50:31 and um were you given an induction or any explanation of standard procedures um when you arrived for that second installation in may
00:50:42 for that second installation in may i would have thought so it's normal for normal process to have a health and safety induction everywhere on every site before any work starts so
00:50:49 starts so i can't recall it vaguely but i'm sure i must have i must have been giving it
00:50:56 giving it something i've got some questions about the design of that second test i realized
00:51:02 realized so you weren't involved in the design process but just to help your memory with with what it was if we could look at cell cell3010052
00:51:17 cell cell3010052 at page 13.
00:51:29 uh this is is uh jonathan roper of celestex's witness statement and if we look at paragraph 5.32 in the middle of the page
00:51:43 he's explaining here the discussions that took place internally at celetex about prior to the second test about what um what design changes they might make
00:51:54 make and you can see after the small roman numerals 2 he talks about increasing the panel thickness and using a double panel system on the fire barrier
00:52:05 fire barrier using a magnesium oxide board and they decided on option two and then in the next paragraph 5.33 he says just at the bottom of the screen
00:52:16 he says just at the bottom of the screen there
00:52:17 there the only changes between the first test and second test that i was aware of was the thickening of the malia turnip panel from eight millimeters to twelve millimeters and the use of a six millimeter magnesium oxide board
00:52:28 magnesium oxide board at the fire barrier at level two and at the top of the test room um does that sound right to you in terms of the changes that were made between the first and second test
00:52:39 the first and second test yeah yeah a lot of said reading through the transcripts as as the as the inquiry has gone on i'd completely forgot about the the magnesium oxide board but i've been
00:52:51 the magnesium oxide board but i've been mentioning it again i do recall it now but yeah that that is exactly how i remember it yes so from your perspective the changes would have been um you had different cladding boards to install
00:53:03 cladding boards to install yes and there was also the layer of magnesium oxide which you say you now recall yeah um we know from celetex i don't think we
00:53:14 um we know from celetex i don't think we need to go to it but if you want to then let me know and we can um but we know that an eight millimeter board of the malia turnip was used over the magnesium oxide do you remember that
00:53:28 do you remember that no uh if if there was there was definitely a heavier board 12 mil i think that model i think it might have been a 12 mil board
00:53:39 mil board no i can't remember that exact configuration no if there was a heavier board and does it follow that you also had a lighter board then
00:53:49 then um if
00:53:53 no no it doesn't necessarily know i think the the rig may have been there's a heavy board lower and then the magnesium oxide board was higher with the second fire barrier so it might
00:54:04 with the second fire barrier so it might run about a thinner panel because of the addition of this six ml underneath it do you remember installing cladding at that level which was a different color to the planning that was lowered down
00:54:16 to the planning that was lowered down only vaguely but i do recall from having looked back through my own photographs that you you should have on foil there but yeah i do remember there was there was
00:54:27 yeah i do remember there was there was one more that was particularly heavy it was it was really heavy and do you recall that there were um you said that you can remember from seeing
00:54:38 seeing photos that there were different color boards do you remember those boards being
00:54:42 being uh thinner or lighter
00:54:46 yeah i think one of them's orange i think the orange one was the heavy board i think that was with the i believe yeah i think i think we have the records
00:54:57 yeah i think i think we have the records the other way around but i don't think um
00:54:59 um we need to go into that um could i ask about again where all of the materials were um when you arrived were they all already on site
00:55:10 i believe so
00:55:14 no actually no i think i think that we was waiting for a delivery of some board do you remember i can't remember accurately but i do remember having a
00:55:25 accurately but i do remember having a delivery
00:55:26 delivery accepting a delivery while we were there still
00:55:29 still do you know if that was the delivery of the magnesium oxide board
00:55:35 i can't i can't say you know accurately it could it could have been it could have been that or the other panel i don't recall you say you were waiting
00:55:46 i don't recall you say you were waiting to take delivery a bit when whatever that was arrived um did you personally take delivery of it well well we accepted liberal because we
00:55:57 well well we accepted liberal because we were waiting to install it but you know the blv obviously would have taken charge of it and because it was their forklift offloaded it
00:56:07 it so your your memory is you were waiting for something with the bre forklift say again sorry were you waiting with the bre forklift
00:56:18 were you waiting with the bre forklift well let's say there was stuff around most of the time so when when anything arrived somebody would come out and
00:56:26 and offload it i see so uh when it arrived is your memory that the forklift went off and uploaded it and you would have been accepted delivery by signing for it or whatever
00:56:39 delivery by signing for it or whatever i don't know if i would have signed for it no i probably would have accepted it no
00:56:44 no do you know who would have accepted it no i can't call home i'll say there was there was various members of staff for for i think there's probably about four four different
00:56:55 four four different men of bra around at any one point and by those all bre employees rather than celetex as far as you know yes and were you just
00:57:07 as far as you know yes and were you just waiting for this delivery are you just waiting in the burn hall for it to arrive yeah i think we would i think we were running reinstated and reinstalling the system i don't think we were standing
00:57:18 system i don't think we were standing around waiting but i do recall expecting a delivery to arrive so you had started you would have started installing um the system whilst you were waiting
00:57:31 um the system whilst you were waiting and then when the delivery turned up um sorry i think we would have i believe it would have been although i can't quite recall i think we would have been reinstating the substrate after the
00:57:43 reinstating the substrate after the first test i'm sure we would have been you know taking away the previous test and reinstalling new aluminium rails and buckets i thought that's what we would have been doing
00:57:54 doing do you remember how far you were into installing or setting up the installation when the new delivery arrived
00:58:02 arrived no
00:58:05 did you see any delivery notes for the materials that had already arrived no would you have expected to not not in such a place no
00:58:18 not not in such a place no could i just ask you what you mean when you say not in such a place because any deliveries were not specifically mine they were either seller texas or all the bit or property the boe
00:58:29 property the boe if i was on a standard cladding job and i was the supervisor or you know the installer
00:58:36 installer on the side the pro i would have been in charge of the property that had come it would have been simcoes or whoever so i would have taken the delivery of it in that case but not in this
00:58:48 that case but not in this particular case no was any explanation given to you about why that material was being delivered whilst you were on site no it was just i was aware that it
00:59:00 no it was just i was aware that it changed it and the way i understood it was that the first test had failed because the panel had failed before the seletech's product that could be tested to the duration so
00:59:12 that could be tested to the duration so it made perfect sense to me to put a thicker panel on it so that celatex being tested in question could be
00:59:19 be tested so it was just that just changed the panel
00:59:23 the panel was just waiting for the new panel to avoid that was all do you remember where you uh where you got that impression that it had failed because um the cellotex product could be tested yes
00:59:35 the cellotex product could be tested yes john roper yeah let's say that i i did speak to or i think now is phil clark that you know not the main manner thing but but not so much the
00:59:47 thing but but not so much the information that i got from the you know from it from the whole thing at all was john robert because he was he was there oversea and i spoke to him quite a bit when he was there i mean can you remember what else mr roper it
01:00:00 you remember what else mr roper it told you was there anything else no not really no i'll say i'd ask him a general question and he he'd answer it also say you know you know what i said
01:00:11 also say you know you know what i said how i mean obviously i wasn't intrigued as to why you know where about that you know what why did it fail or how how did it do and he says it failed
01:00:22 how how did it do and he says it failed and
01:00:23 and you know look as i said if well the the system burned away i'd say it for myself because i think i uninstalled it you know they had burned it burned before you know the panel had
01:00:34 it burned before you know the panel had failed before the product had been tested
01:00:37 tested did he explain to you what the changes were that they had made in so much as we were installing a thicker panel and to stop that happening again which
01:00:49 and to stop that happening again which make perfect sense to me i'm going to move on to ask you a couple of questions um about the installation process itself
01:01:00 about the installation process itself with that may test um we know that that was carried out on a friday this which was the second of may 2014 and mr clarks told us in his evidence
01:01:12 and mr clarks told us in his evidence that normally the rig would need to be handed back uh a clear day beforehand and for the record that's at the transcript of day 96 age 11 lines 9-18
01:01:24 age 11 lines 9-18 but i don't think we need to go to it you can just take it from me um do you remember if you were installing in the week running up to the 2nd of may
01:01:36 2nd of may i can't recall that no do you remember when
01:01:40 when you would have started
01:01:43 no i i don't know i'll say it's so long ago i haven't gone back over i might be able to find that information out but off the top of my head i really don't know that is it right that you would carry out the
01:01:55 is it right that you would carry out the installation in terms of putting the system up is that layer by layer
01:02:00 layer yes and how long does did that take can you remember no but i shouldn't imagine that it lasted any longer than two days three
01:02:11 it lasted any longer than two days three days
01:02:12 days maximum i would have thought
01:02:16 can you remember when in that window towards the beginning or towards the end when would you have been installing the layer of the magnesium oxide
01:02:27 towards the end for if it were called it was
01:02:32 was pot it was uh what two thirds three quarters of the way up so we would have started at the bottom obviously started at the bottom sequentially and worked just way up so it would have been towards the end of the process
01:02:44 been towards the end of the process and how long um would that so if you start at the bottom
01:02:49 would that then have been visible until you put the next layer until you got up to that level with the next layer all right yeah but uh yes but it oh i think
01:03:01 yeah but uh yes but it oh i think i can't quite recall but i think there was only one only one panel of magnesium oxide whether there was one band that went around both sides of the test rig or
01:03:12 around both sides of the test rig or whether it's just on on the large face i can't recall but it it could have been it could have been visible for half an hour it could have been visible for several hours i really can't recall how
01:03:24 several hours i really can't recall how how long it was open for before we installed we could have put the magnesium oxide panel on and then install the next panel straight over it you know so it could have been it could have been a matter of
01:03:35 have been a matter of you know a minute 10 15 20 minutes it could have been open for hours i really call that and were you given any any instructions to try and ensure that
01:03:46 any instructions to try and ensure that it it wasn't visible very long were you given any any suggestion or any instructions that it should be concealed from the bre staff
01:03:55 staff no no i will say there's i wouldn't have thought no there was definitely nothing that he would say underhanded that all i could understand that was that was going on in that respect and
01:04:09 that was going on in that respect and the oe staff could have seen it at any point in time and there were people everywhere all the time so no there was no there's never any to hide anything or cover anything not
01:04:20 to hide anything or cover anything not know
01:04:21 know how long i think you said do you think it was roughly two maybe three days is that um the clearest memory you have of how long the installation would have taken
01:04:32 would have taken yes well it's only 20 15 meters squared at the most so that's you know and doing it as
01:04:43 that's you know and doing it as meticulously you can you know so it's got its best chance of achieving what it needs to do and nobody would want to pay any more than two days for it so i shouldn't imagine it'd last any longer
01:04:54 imagine it'd last any longer than that do you remember seeing um mr clark or other bre employees as you were carrying out the installation not specifically
01:05:05 installation not specifically no i couldn't i couldn't say just to what point in time they were there watching but you know there were there were people around but i couldn't specifically say at what
01:05:17 but i couldn't specifically say at what point in time and you know and what stage of the install you know they were there recording no i couldn't say that do you know when you handed the rig back to the bre for testing
01:05:30 i i don't remember if your site was on a four in the option imagine it was half past two
01:05:38 uh and you told us earlier i'm just going to ask you about the drawings or any drawings you have for that test and we've talked already about the
01:05:49 talked already about the drawings you were provided with for the february test um could we go back to jonathan roper's witness statement that's cel301052
01:06:01 that's cel301052 page 13.
01:06:09 uh paragraph 3.5 so a bit further down possibly onto page 14 actually
01:06:21 yes there we go you can see 35.35 mr roper says the team at celestex had wanted
01:06:31 wanted patrick jones so you to construct the rig
01:06:35 rig because paul rob and i had decided we didn't want to pay for another set of drawings
01:06:39 drawings and patrick knew the system from the first test we thought that patrick could oversee the construction without the need for revised drawings
01:06:49 and mr roper has told us orally that celetex didn't get any new drawings commissioned before the test do you remember that you were not given
01:07:01 do you remember that you were not given any additional drawings
01:07:04 i can't i can't specifically recall but i would i would generally agree with that because as i said that
01:07:15 said that it was very it was very relaxing that way not said that nobody gave me the joints first nobody you know there's no there's no forethought or com you know or confirmation of anything
01:07:26 confirmation of anything before so i would guess that the first set of drawings i would agree with that that
01:07:31 that i did it exactly the same from the first one because i know you know i don't i really do not think there was a second set of drawings
01:07:43 drawings there's definitely not a set of drawings that showed two layers of panel if that's the question but no i would agree it was just the original set would have been all i would would have
01:07:54 would have been all i would would have worked for and given that we know there had been these changes to the design did you think it was strange that there weren't any new drawings
01:08:05 weren't any new drawings no how
01:08:08 no how did you know um to put up the uh the magnesium oxide layer without the drawings there john robert would have specifically told me
01:08:21 specifically told me what to do just to be clear you say he he would have told you did tell me yeah i wouldn't yes if i didn't have a joint if if i'd have had a drawing
01:08:32 had a drawing my mind does work like that if i'd have had a second drawing with the with the magnesium oxide i'm sure i would have remembered it but i didn't then so yeah
01:08:44 but i didn't then so yeah i was i was instructed i was instructed by john roper what boards to put on and how to put them on
01:08:51 them on did he tell you did he give you those instructions when you were on site at the bre
01:08:55 the bre yes so they were verbal instructions yes yes john robert was there a lot say it was he was there quite a lot to you know overseeing and instructing
01:09:06 instructing work so yes can you remember what he told you
01:09:10 told you in terms of um where those boards needed to be installed looking back from context at the back of the photographs and what i recall from it at the level of the second flight
01:09:21 it at the level of the second flight barrier
01:09:22 barrier but that's that's
01:09:26 a memory that's an answer you put together
01:09:29 together being as helpful as you can but it's not a memory is that right yes but also it goes logically that i wouldn't have guessed where to put them i would have specifically been told where to put them
01:09:41 specifically been told where to put them i wouldn't have i wouldn't have chosen where to put them myself i would have been told where to put them i would have built the rig specifically as requested and requested by in this case john roper
01:09:55 and requested by in this case john roper as far as you can remember did anyone accept john rother give you any instructions about how to uh
01:10:02 uh install the design that was to be installed
01:10:07 did he give you any explanation about why the changes were being made or just tell you what they were only generally as i said previously that the
01:10:18 generally as i said previously that the the first test had failed because the panel product in question in the first test had failed uh it had burned through before it
01:10:29 uh it had burned through before it reached its before the test could conclude so that where it failed they put a thicker border or two layers of board that's that's what i understood a lot said it made perfect sense to me that
01:10:41 said it made perfect sense to me that that would be you know understood that it wasn't the panel product that was being tested it was the celetex underneath ms solomon i'm sorry to interrupt you but
01:10:52 interrupt you but can i just try and clarify something with mr jones um mr jones i envisage you putting up this um test rig and uh when you get to the cladding
01:11:05 and uh when you get to the cladding panels
01:11:06 panels you start at the bottom i assume and work on up is that right yes that's correct yeah was mr roper present when you were putting up these panels
01:11:15 panels for the whole time as far as you recall i believe it probably was yes you see i i can understand that if you had a drawing which showed where you should put the
01:11:26 which showed where you should put the magnesium oxide boards you would know exactly where to work to and where they should go but without a drawing how did it work
01:11:37 there's i think there's there's obviously the original draw and showed that there was i think if you remember all you saw the four four five panels high yeah first panel covered the first
01:11:49 high yeah first panel covered the first four barrier second panel was intermediate i believe so the third panel would have been on the second floor barrier so that that would have been the level it was required but i'm sure i'm sure john ripper was there though i do recall him
01:12:00 ripper was there though i do recall him being there he must have been yes so your recollection is that he in a sense supervised the placing of that particular of the cladding at that particular level
01:12:11 of the cladding at that particular level yes i don't i don't recall i really do not believe there was another drawing i really don't know yeah i just but i'm just trying to understand how it worked because you would need some fairly
01:12:22 because you would need some fairly precise instructions either in the form of a drawing or in the form of oral instructions it would have been all i mean if there's four panels third one from the bottom the one that corresponds with the second
01:12:34 the one that corresponds with the second foil barrier will be the magnesium oxide but
01:12:36 but i'm sure he was there at the time right and can you remember uh whether having gotten the magnesium oxide board on you immediately put on the
01:12:51 on you immediately put on the the the the outer board the eternity board or whether you worked on up the rig
01:13:02 i i really can't remember we probably would have done worked on the rig but i really i can't remember that in that detail yeah all right thank you thank you very much that's very helpful
01:13:14 thank you very much that's very helpful sorry ms sullivan on you go thank you mr chairman um miss jones in relation to those instructions you were getting from mr ropa do you remember anyone from
01:13:27 from mr ropa do you remember anyone from the bre
01:13:28 the bre being present when he was giving you those instructions
01:13:34 not not any not anything specifically as i said previously there were there were definitely people from the brb
01:13:46 people from the brb around all the time and i mean some sometimes john would be standing there talking to several people of whom i assumed would be re people so yes he was definitely talking to you
01:13:57 so yes he was definitely talking to you know bra staff at intervals at what particular what particular time and what particular stage of the process i couldn't clarify but as far as you
01:14:08 i couldn't clarify but as far as you remember
01:14:09 remember any verbal instructions given to you by mr roper
01:14:14 mr roper was a conversation between the two of you rather than with anyone from the bre standing in as well i don't i don't ever recall anyone from the bre in putting on the specifics of how the
01:14:27 in putting on the specifics of how the test
01:14:28 test went no i you know how the install went sorry
01:14:33 everything that i was asked to do yeah it was it was from john roper i don't don't yeah no no one from the bre had any design input not directly to
01:14:47 bre had any design input not directly to myself anyway could anyone have overheard um the instructions he was giving to you if they had wanted to yeah i thought so yes and i think i
01:14:59 yeah i thought so yes and i think i think we've already um discussed this but just for the sake of clarity uh were you given any instructions to try and conceal the changes that were made to the design from the victory
01:15:11 from the victory no definitely no i was unaware of anything
01:15:15 anything people said underhanded or anything going on
01:15:19 going on there was no there was no question of anything
01:15:23 anything sinister occurring to me at the time and no no one suggested hold up we'll get that on or cover that up or don't i don't say that there's nothing
01:15:30 nothing there's nothing there's nothing on that mr sherman i'm making quite good time with miss jones but i um i've had a few pages to go so looking at the time might be a good
01:15:43 so looking at the time might be a good point for a break is that convenient to you yes i'm about to start new topic right well mr jones i said that we would have a break during the afternoon and we're going to have it now all right
01:15:54 and we're going to have it now all right we will resume at half past three please and i have to ask you
01:15:59 ask you while we're having a break please don't talk to anyone at all about your evidence or anything relating to it understood it yet all right see what happens three then thank you thank you very much
01:30:21 welcome back everyone we're now ready to continue hearing further evidence from mr jones mr jones are you there can you see me and hear me yes i can i can see you and hear you yes
01:30:33 you and hear you yes very good thank you very much and you're ready to carry on i hope yes good thank you in that case ms sullivan when you're ready
01:30:41 thank you mr jones um miss jones we were talking before the break about what if anything you could remember
01:30:50 remember about when uh the installation for the may test was carried out um and i think it's it's better you don't have a clear memory could i ask you to look um at cel
01:31:04 could i ask you to look um at cel 50873
01:31:08 and page two if we get that document
01:31:21 uh and about halfway down that page there's an email on the 11th of march from john
01:31:28 from john at celetex to graham smith at simcoe and it says have just come off the phone to theory
01:31:38 to theory who have confirmed that work can commence on site from 7th of april i'd envisage needing materials supplied by simcoe
01:31:46 by simcoe and labour three days week commencing 7th of april if you could just scroll up please to the email at the top of that page and we can see mr smith's reply
01:31:59 and we can see mr smith's reply uh john as discussed yesterday that should be available that week as the site is on and behind again does that
01:32:09 that prompt any memory from you about when you were there for the installation of the test carried out in may or can you not remember no really i can't remember no thank you
01:32:20 no really i can't remember no thank you um and you told us that sidewise of someone from sidewise attended before the february test you think um to tell you about their product
01:32:31 you about their product was anyone there um before at the may test as well was there only one
01:32:38 one one such session there's only one visit i really can't recall whether it was sideways
01:32:43 sideways i i i really can't recall you know i won't be
01:32:47 won't be sighting sideways incorrectly there but it's it was the it was whoever was supplying that particular fire barrier which is a sideways style that you know whoever it was but already
01:32:58 that you know whoever it was but already got the call um we're going to just look then at some questions about the bre's involvement um which we partially discussed but just to make sure
01:33:09 to make sure that we've covered everything um can you remember in relation to the may test who from the bre uh had oversight or whether there was a person who had
01:33:20 or whether there was a person who had oversight as you were carrying out that installation i i can't recall who that was and what said
01:33:29 said i'm only i'm only assuming from context that it was phil clark but i i've got a terrible memory for names and
01:33:37 names and but it would have been it was it was the same gentleman though i believe you smell like we don't say it's you know i i don't know it's sure but whoever it was he was overseeing it was the same person you remembered
01:33:49 it was the same person you remembered from february is that right yes um
01:33:54 yes um and do you remember that person viewing or inspecting the rig as you were assembling it not specifically no could we go to uh bre 40
01:34:08 go to uh bre 40 5773 at page three
01:34:13 just as it comes up i'll just explain what this is um we it's not a document that you have any input into uh it's a document that's been disclosed to us by
01:34:24 document that's been disclosed to us by um the bre
01:34:29 and it's a document that came in at least was in existence from may 2013 onwards
01:34:34 onwards did you see anyone from the bre uh with a document of this sort whilst you were assembling the rig in may 2014
01:34:44 not specifically in that document now as i've said numerous times they they were definitely people walking around measuring and checking and photographing
01:34:55 and photographing and walking around with clipboards and looking at what we were doing at intervals during the whole time we were there but i couldn't specifically say you know when and at
01:35:06 specifically say you know when and at what stage you know they were you know they were recording and reporting there were definitely people for that that particular form i can't ever remember seeing that one though
01:35:18 though do you remember anyone um checking off against any sort of list or checklist
01:35:26 i would be it would be conjecture definitely there was people there were people checking stuff and my maybe against lists might be that one but i would just be guessing
01:35:38 but i would just be guessing and you say there were people checking um
01:35:43 um yes well any of them were there more than one
01:35:46 than one person doing that
01:35:49 i couldn't i couldn't say again it i would just i'll just be assuming there were definitely ble staff different members of staff doing different things but who was
01:36:01 doing different things but who was who in into what exact detail who was doing what that that's their job you know i was i wasn't really paying that much attention at the time i
01:36:12 paying that much attention at the time i see
01:36:14 see did any of them ask you any questions at any point
01:36:18 possibly that you don't remember or they i did i did speak on several occasions to some some of the bra staff but i don't think
01:36:33 some of the bra staff but i don't think look looking down there possibly on the on the thermal couple positions no just just specifics nothing nothing particular no nothing nothing particular springs to mind but
01:36:45 particular springs to mind but i did have a i did have conversations with you know lightly with with bra staff while i was installing can you remember what sort of things you had been talking about
01:36:56 had been talking about it would mainly been about that their their particular rig as i said much earlier on that they obviously they have knowledge of their rig
01:37:05 rig and they they would specifically tell me we'll we'll need to put um you know we'll need to put the thermocoupler here and there and you know fixed to that
01:37:16 that you know fixed to this section you know if you use in this section you know exactly just just things like that just general information on the rig itself nothing
01:37:27 information on the rig itself nothing particular on the on the products that i was installing they would they had no design importance but just on the particulars of their rig and what was required on in on that
01:37:40 and what was required on in on that score
01:37:41 score did anyone ask any questions about why there were different coloured layers of board
01:37:48 board being installed
01:37:54 and do you ever i know you told us you don't have a great memory for names do you know if you ever met stephen howard whilst you're at the bre doesn't name doesn't ring a bell at all now
01:38:07 name doesn't ring a bell at all now ms sullivan could i i'm sorry to interrupt you yet again but can i just ask
01:38:11 ask about photographs mr jones we understand that various people took photographs of the rig in the course of construction yes um were there times when you
01:38:23 yes um were there times when you asked bre to come and take a photograph no so whatever photographs they took they took them as and when they wanted to is that how it worked yes yeah
01:38:36 wanted to is that how it worked yes yeah and did you take any photographs of the rig in the course of construction i did yes and what happened to them uh i think you have copies of some of those the ones that i took uh there's some i took just as a
01:38:51 took uh there's some i took just as a well this is the stage we're at at the moment and and emailed them to john roper other than that they just they just stayed on more google photos and that's where they've been ever since okay that's helpful but do you think
01:39:03 okay that's helpful but do you think we've got them anyway yeah so yeah anything that i've found the information i thought would be helpful i'm sure that sentiment thank you very much yes
01:39:12 much yes yes ms sullivan sorry to interrupt you thank you and just uh for clarity we do we do have photos from mr jones and we are coming to look at some of them uh a bit later
01:39:23 bit later um so just so mr jones knows that they haven't
01:39:27 haven't got lost in transmission anywhere um
01:39:32 do you remember we've spoken about photos do you remember whether anyone from the bre was taking any measurements at any point specifically no but
01:39:44 specifically no but yes they were definitely taking measurements of of what of what i couldn't specifically say as as i said me again sorry no
01:39:55 as as i said me again sorry no numerous times there were definitely people from bre who were recording and looking at things you know are enjoying the build yeah but specifically what they were measuring you know
01:40:07 measuring you know you know i couldn't i couldn't say they would they were doing their work and that's as much as it went just to check i've understood that is that you you remember measurements
01:40:18 is that you you remember measurements being taken but not specifically of what yeah they were they were they were measuring and recording several times several intervals they were looking at looking at things i didn't say they're
01:40:29 looking at things i didn't say they're measuring things in part holes i didn't say they're measuring um i didn't specifically see what they were measuring but they were they were for sure recording the build as it
01:40:41 for sure recording the build as it progressed uh were you asked at any point to identify
01:40:47 identify all of the component parts that were going into the system
01:40:52 um and were you aware of anyone from the bre recording that information not specifically no i just assumed that everything that was done was recorded because that that's their
01:41:04 was recorded because that that's their job
01:41:06 job and i think um the chairman asked you earlier
01:41:10 earlier um about the instructions that you were getting um from mr roper could you just help how how often during the installation being built up
01:41:21 during the installation being built up were you having conversations with mr roper
01:41:25 usually usually in the morning and he didn't really need to tell us any more than
01:41:32 more than what we needed to know he would instruct us
01:41:36 us you know it's not it's it's not that detailed a thing he would he would say put this bit there and put that bit there and then that would more or less be it and he would come again and check that we were
01:41:47 would come again and check that we were doing what he had asked and it's it's not it's not really that deep a thing if he if he told me once at nine o'clock then it'd be done you know he wouldn't
01:41:58 then it'd be done you know he wouldn't have to keep talking about it all the day long
01:42:00 day long was he there um all day every day he was there quite a lot but i can't remember i don't think he was there every day but he was there every other day most days i really can't
01:42:12 every other day most days i really can't remember but he he visited quite a bit yes he wasn't there every day though and i know you've um we've been talking about if you can remember how long it took but can you remember
01:42:25 took but can you remember if it was the case that mr roper was there every other day or not not each day
01:42:32 each day were you there um consecutive days or do you think
01:42:36 you think you did some days and then came back and did some more i think i think we did but i really can't recall it's that long ago i can't i'm only i'm only getting that from looking back over
01:42:48 from looking back over emails and look look similar to the one that you just said that want to revisit i really i really can't say for sure
01:42:56 sure i did think there was a break you know there was a break in the install but i can't remember why whether i was busy or whether it wasn't ready or
01:43:04 ready or whatever reason but i do seem to vaguely recall that we didn't install in one hit as it were do you have any memory of what stage you
01:43:16 do you have any memory of what stage you would have been at when there was that break no um do you remember how long that was for no sorry i can't i really couldn't say
01:43:30 in terms of conversations whilst you were at the re um were you present at or did you hear any conversations between celestex and the bre
01:43:41 the bre uh whilst you were installing the rig no no no i didn't because usually we're up in the air on a scaffold
01:43:51 scaffold no i'm aware that they were talking together but no i didn't overhear no i didn't particularly overhear anything specific no we've talked a bit about um the
01:44:03 we've talked a bit about um the processes that were followed and your memory of what checks were carried out was there any difference as far as you can remember between the process in february 2014
01:44:15 between the process in february 2014 and the process in may 2014 what from the from the aspect of bi yes in terms of the checks not that i'm aware of no i didn't i didn't notice anything
01:44:26 didn't i didn't notice anything particularly different no no real differences in the way that those checks were done
01:44:32 were done no i didn't notice anything particularly different now at all as with february do you remember if you uh told anyone from the bre when you had completed installing that
01:44:44 when you had completed installing that you had that you were done and it was ready
01:44:46 ready for handover
01:44:50 i do i do recall letting them know but long said it might maybe just had a courtesy or building security that would that we'd finished and we were leaving the building and
01:45:01 the building and you know we've cleaned everything up but as for a particular you know process and protocol i really can't remember you know i don't i don't think i was given any instruction to
01:45:13 given any instruction to to let them know at certain intervals or stages
01:45:16 stages but again i may have done i do remember going up to the office and saying we're you know we're leaving now or
01:45:24 or we're done but i can't remember any any set
01:45:28 set uh you know stage points i think to having to inform on that do you remember who was in the office when you went up to say that
01:45:38 that no but look there was some sometimes there was nobody sometimes there was who believed to be failed and sometimes there were several people in there or two or three people and as far as
01:45:50 or two or three people and as far as you're aware um were any checks carried out
01:45:53 out once you'd announced that you were finished but prior to testing yeah i think yes i think they come and test check checked it when we were done or did the work that
01:46:04 when we were done or did the work that they needed to do when we done on saturday after we'd installed to a certain stage they would they would come and install thermocouplers and sensors and readers whatever they
01:46:16 and sensors and readers whatever they needed to do so that that happened obviously as soon as i finished can you remember in terms of when the thermocouples were installed
01:46:25 installed um was that after you had installed the magnesium oxide layer or before i can't recall that now and i thought it was before because some of them
01:46:37 was before because some of them i like they would have needed to check the face and the penetration through the through the insulation of i wouldn't believe
01:46:45 believe i'm just guessing sorry and do you know who
01:46:49 who carried out those dad overall check um before you left no just by staff i don't know who
01:47:03 see and we've slightly covered this already but just um for
01:47:09 um for the sake of the record um was it your understanding that the bre and celetex were both aware of the components in the test rig in may 2014 yes and as far as you were concerned
01:47:22 yes and as far as you were concerned was there any reason that the bre uh could not have identified the changes in the design so the six millimeters magnesium oxide and the eight millimeters of mali
01:47:34 and the eight millimeters of mali eternity
01:47:36 eternity but it was it was clear for anybody to see at any stage if that answered your question
01:47:47 any stage if that answered your question anyone anyone with access into that fire hall
01:47:50 hall obviously bla staff or invited participants because sometimes the door was shut it was clear at any stage for anyone to record anything
01:48:02 record anything what what they actually did say i've got no idea but it was there's there's nothing there's nothing hidden or
01:48:11 hidden or you know it was clear for anyone to see at any point so i should imagine that bi would have seen it
01:48:19 seen it so could we put it this way that as far as you're concerned um there was no reason to think that they were unaware of those differences correct yeah doesn't yeah
01:48:31 um i'm going to ask you some questions now
01:48:34 now uh about um stripping down that test rig so after the fire test has been carried out
01:48:40 out uh if we could go to bre-405548 at page six
01:49:00 at page six and you can see the uh the second email down
01:49:04 down it's an email from mr roper uh to mr clark on the 15th of may so about two weeks after the test and with the subject line monday the
01:49:16 and with the subject line monday the 19th
01:49:17 19th he says phil i've spoken to simcoe who are struggling to carry out a stripped down of the rig thursday or friday next week
01:49:24 week if i instruct patch brackets installer to strip down on monday without me attending would this be okay and can we prevent as much as possible our competitors being in hall at that time and
01:49:37 patch that that's a reference to you isn't it yes yes yes and the monday um that he's saying uh if he instructed you to attend that would be monday the 19th of may
01:49:49 19th of may we know that you did attend on that date because you took some photos which we're going to have a look at but can i just ask first do you think that was the first time um that you were asked to go and
01:50:00 time um that you were asked to go and strip down the rig and the first date
01:50:06 i'm really i'll call i would i would guess so but i'm guessing i don't know i would guess so do you remember did you complete the strip down of the rig in one day
01:50:17 of the rig in one day i can't remember but i certainly would have thought so i mean this is hours worth of work if that yeah so definitely i would have thought so but i can't i can't remember but i wouldn't
01:50:30 i can't i can't remember but i wouldn't thought usually yes definitely in a day do you remember was it just you who went to do that or did you have someone helping you
01:50:43 i i can't remember 100 but i think it might have just been myself i really we're just looking again
01:50:54 i really we're just looking again at that email um you can see just after the
01:50:58 the sentences we've been looking at uh mr okay goes on to say also would it be possible for you to i think there's a word missing but probably take a couple of images once
01:51:09 probably take a couple of images once the guys have removed the facade so we have something on file which shows the installation below and above fire break
01:51:16 break and then mr clark's reply is just above that and says hi john this would be okay and i'll put up a camera and get some good photos for the system coming down um do you remember whether mr clark or
01:51:29 um do you remember whether mr clark or a person who you thought had been mr clark um
01:51:33 clark um was present on the 19th of may when you went to strip down
01:51:39 again i would be surmising oh i would i would think though really i would be guessing i couldn't say whether he was or not i would assume that he was but again it's just an assumption that's
01:51:52 but again it's just an assumption that's very clear thank you um i should say mr clark's evidence was that
01:51:58 that when he said in this email i'll put a camera up he meant that he would arrange it not that he would be there himself um do you remember when you went to strip down was anyone from the bre there
01:52:12 yeah there must have been somebody there now i can't say that they were recording i mean that that isn't it that is their job i mean that is they they are recording it and i do
01:52:22 do now not saying that i do remember cameras on on tripods but at what point in time i'm oh i didn't know when you say cameras on tripods where would those be
01:52:35 cameras on tripods where would those be i just no no i haven't seen that i do remember cameras a camera rig set up on a tripod but in what specific location i don't know but i do remember now that is how they set it or record it i think
01:52:47 is how they set it or record it i think i might be thinking of a a recording for the video evidence for the for the actual test so i might be getting mixed up with that were you present for the actual test no
01:52:59 were you present for the actual test no no that was one criteria you were not allowed to be in to witness tests i believe do you know when you say you remember cameras on tripods how high
01:53:10 tripods how high do you remember those being later 1200
01:53:16 um judging by that email it looks like mr roper
01:53:19 mr roper didn't go with you to the strip down did he give you any instructions before you went
01:53:26 you went to take it all down i i don't i don't remember
01:53:35 can you remember if he gave or referred to in any way um the magnesium oxide boards
01:53:44 no sorry no i don't recall any conversation from john well there's nothing specifically about anything no it didn't i had no instruction specifically about
01:53:57 instruction specifically about you know doing anything with anything in particular no i don't believe it i don't believe
01:54:02 believe i even spoke to him but i have
01:54:07 if you didn't speak to him do you think you might have been told to go by simto instead then yes well it's simcoe i was working for so i should imagine at the time this is why i
01:54:18 imagine at the time this is why i vaguely recall that there was a break in it i think i was busy on another job that was equally as critical so yeah it would have been some kind of requested more you know presence there
01:54:30 requested more you know presence there i'm just going to um look at you with some of the photos you sent to mr roper um
01:54:36 um if we could go you actually sent a number of emails but uh there's one i want to look at first we could go to cel 5 0 9 5 0.
01:54:55 oh sorry that's the photo not the email uh could we go to cel 50946 i think is the actual email
01:55:09 okay that's another photo
01:55:14 okay well this is not the one i wanted to look at but it is another email you sent out that on that evening cel50942 please
01:55:28 that should just be coming up there we go and
01:55:32 go and it's a blank message but you can see um which is the important point uh the date and the time that you sent it
01:55:39 it and it's got subject line bre um
01:55:44 and then attached to that email and then another two emails um there are some photographs which you took um
01:55:52 took um given the time that you sent that uh that one's just before 10 o'clock at night i
01:55:56 night i assume um you were sending those when you'd finished and got back oh i guess so yeah and i got around to it but yes do you do you remember why um you were
01:56:07 do you do you remember why um you were sending them immediately after being there had you been asked to send them no i think it's no i don't believe that i was ever asked to send photos i think i just did
01:56:19 asked to send photos i think i just did it because i'm kind i think because i think because john was there i think it was just well i can't remember but looking back through the emails when i was originally
01:56:30 through the emails when i was originally given the evidence it just i think i was just informing him as to the state of i think i'm looking at that previous emails
01:56:37 emails because he wasn't there it must have just been just for his own information i don't think i wasn't specifically asked by him to send photographs i just did it could we look
01:56:50 photographs i just did it could we look at um
01:56:52 at um ceo50947 which is the email i was initially trying to take you to a viral tour of various photographs
01:57:05 and this is the one which touches the photos we're now going to look at and again um this one's five past ten and it just says john regards patch so it's the same position you were just
01:57:16 it's the same position you were just sending them because you thought um it was for his information really yeah yeah for sure um could we look at uh go back to cell 50950
01:57:29 uh go back to cell 50950 which is one of the photographs which was attached to this email
01:57:40 you can see in that photograph um the white layer of magnesium oxide boards
01:57:48 boards around the level two thermocouples and the
01:57:52 the top of the rig are those the magnesium oxide boards yeah oh well i think so i don't recall the one at the top being magnesium oxide but looking
01:58:03 being magnesium oxide but looking looking at that it must have been but yeah i do remember the magnesium oxide board being that that second level there you know the
01:58:11 the the wider one so is it the case then that you're you have a clear memory of the magnesium oxide being put at the second level but you don't remember the top so well no i don't recall putting it
01:58:24 so well no i don't recall putting it there but obviously i did but yes did you take this photo yes i think so and was there any reason particularly
01:58:37 and was there any reason particularly that you had taken a photo of this at this level of uh on the board being stripped down well um do you know you can see there's a man
01:58:50 um do you know you can see there's a man in a blue hard hat in what looks like it might be a cherry picker or something um obviously it's not you if you were taking the photo do you know who that
01:59:01 taking the photo do you know who that is yeah that was nice now i've seen that that was uh an assistant with me
01:59:09 and then there's another it's not actually very easy to tell in this photo because uh their face has been redacted but on the very right hand side um coming down the steps you can see
01:59:20 um coming down the steps you can see somebody wearing a hi-vis jacket um and in the photo they've got a underneath redacted face they've got a red helmet on do you have any idea who that might be no
01:59:33 idea who that might be no did you only have the one assistant with you as you can yeah until i just said that i can't even remember yeah there's a friend of mine called richard i'll say he said well i didn't even i could ever ever do
01:59:45 well i didn't even i could ever ever do that okay
01:59:46 that okay usually help me out so again um so there were the two of you and then we've got a third person in this photograph we know it's not john roper because he wasn't there
01:59:58 roper because he wasn't there was there anyone from celitex there with you
02:00:01 you i don't no i don't think so no i don't even remember anyone from celetex other than john roper ever attended i would guess that would be b.i.e stuff but it would it'd have to be not saying
02:00:15 yeah there'd have to be there wouldn't have been three of us there for sure but definitely but they've never been me and one other i thought i'd shut that down on my own actually but yeah was there anyone i'm sorry to interrupt
02:00:27 was there anyone i'm sorry to interrupt you i seem to be doing it a lot i'm afraid but i'd just like to clarify something with mr jones while we've got this picture up on the screen mr jones we can see from that photograph
02:00:38 mr jones we can see from that photograph that all the cladding all the marley eternic cladding has been removed yep but none of the magnesium oxide when you dismantle a rig of this kind do
02:00:51 when you dismantle a rig of this kind do you start at the top or the bottom
02:00:56 i don't think it would it wouldn't it wouldn't matter for dismantle okay but but would you just work your way straight up or down the face of the rig as the case may be
02:01:07 rig as the case may be probably yes i can't remember why there's there's no specific reason why that's why that's left there well that's what i was wondering whether whether first of all whether you left
02:01:19 whether first of all whether you left those particular boards there for any reason no you can't remember if you did why did no i don't know there's no particular well i would
02:01:30 there's no particular well i would remember but there's no particular reason why those boards are still left there okay and does just the fact that the boards are left there when you're dismantling
02:01:41 are left there when you're dismantling the rig tell you anything about the order in which the boards were put up when you were erecting the rig
02:01:49 for install i would or definitely always start at the bottom for install because once you've put them once you put the first one on you've got something to rest the next one on i mean that's that's the simple simple mechanics of it
02:02:01 that's the simple simple mechanics of it but for
02:02:02 but for if if those boards were charred and birch bird which i i can't remember but if they were well might have taken the the most dangerous ones off first you know we might have taken the loosest ones off
02:02:12 ones off which could have been a lot more than it could have been any of them yeah i could have started at the bottom up or or the other way all right well thank you very much anyway sorry miss sullivan on your game
02:02:23 anyway sorry miss sullivan on your game thank you sir um
02:02:26 mr james i just want to look at a couple of the other photos you took with you just to see um if that helps you at all with what you were taking photos of them and why in particular could we have a
02:02:39 and why in particular could we have a look at
02:02:40 look at cell 50946
02:02:52 you can see this is pretty similar to the
02:02:55 the photograph we've just been looking at it's another one that you know mr roper but it's it's uh i don't know why i've taken i know why i've taken that because it clearly shows that
02:03:08 taken that because it clearly shows that the fire damage up to the fire barrier and then
02:03:12 and then just smoke damage above it i can see that's why i've taken it but i don't know why i've just stripped the other board off unless we was chucking it in two different
02:03:23 we was chucking it in two different skips
02:03:24 skips i can't think there's no there's no specific reason but i can't think why i've done it like that could we look as well at cel
02:03:40 50945
02:03:44 and that's a close-up but again it's showing that whiteboard and i think there's an area of charring or soot damage at the bottom can you see that
02:03:55 that i can say that yes yeah again could you help us with why you're taking photos of this it's not specifically the whiteboard as i said there was nothing
02:04:07 i said there was nothing there was never any uh inference of anything suspicious or no handy going on it's not
02:04:15 it's not that's not particularly a photograph of the white board it's just the of the state of it the whiteboard and the other as well and the fiber behind it i'll say it's not that
02:04:26 behind it i'll say it's not that although it is a particular it is a picture of the magnesium oxide board it's not specifically the magnesium oxide board i mean this photo the other two photos
02:04:38 i mean this photo the other two photos obviously were um photographs of the system from a bit more resistance this seems to have been taken uh quite close enough would it have been taken out at that level
02:04:49 taken out at that level yes it would have yeah that's i would have only taken it on to tell it on my uh telephone but that clearly shows the smoke damage below and above the fire barrier
02:05:01 below and above the fire barrier which i believe to be sidewards yeah but that's that's why i've taken that because it you know it's clean one side and
02:05:10 and so effective in my opinion could we go back to um the email we were looking at from mr roper to mr clark which was a four zero five five four eight pages
02:05:23 four zero five five four eight pages sorry are they these photographs are these
02:05:26 these but these are not photographs that i would have sent to john roper or or are they i'll say i don't i don't think i would have sent that particular i think that's just from my own file
02:05:35 own file yes these are attached to uh is it attached to if you'd like to see the email this one's attached to you it's a
02:05:43 it's a cel 50944 please um i think the emails are just blank so i'm afraid you'll have to take it on trust from me but they are all uh the emails and the photos belong
02:05:55 uh the emails and the photos belong together
02:05:56 together yeah okay you can see so that's the one that attached that and the other two belong to the ema we looked at that said um john regards patch okay um if we go back to the email
02:06:08 patch okay um if we go back to the email exchange from mr rip with mr roger mr clark
02:06:11 clark at bre 40s 5548
02:06:18 uh you can see there at the bottom of mr roper's email and he says he's asking mr clark about getting some images which shows the installation above and
02:06:29 which shows the installation above and below the fire break do you recall if mr roper made a similar request to you at any stage look at those photos maybe but i don't recall
02:06:39 recall it i don't call him well i don't i don't know the answer is i don't i don't recall him ever requesting me to take photographs and i just wanted i was just trying to
02:06:51 and i just wanted i was just trying to see if i was copying on that i was wondering why but no i just think i just did it as a because there's you know just stage does it follow given the we've looked at
02:07:02 does it follow given the we've looked at a photo which um was taken by you of the full
02:07:04 full tested rig system showing those white boards yeah also a close-up at the same level that you must have um got down from dismantling it taking a photo
02:07:15 photo and then gone back up or the other way around but you you buried in level as those photos were taken is that right yeah
02:07:23 yeah yeah i was stood on the floor for the other ones i must have been so yeah i must have been the second one where you've got the the fire barrier and the white board removed i would have guessed that that
02:07:35 removed i would have guessed that that was
02:07:36 was during the awning store do you know how long
02:07:40 long you spent taking these photographs
02:07:44 second minutes um we've got a copy of the photograph i showed you which had your friend richard and somebody else but rejected but we have apparently a
02:07:56 but rejected but we have apparently a copy which has their helmet not redacted and so if we could go to that that is at cel 3010626
02:08:18 and you can just see on the right hand there on the stairs you may need your glasses it's not terribly good quality i'm afraid um there's a man in a red helmet oh
02:08:30 um there's a man in a red helmet oh you can see his helmet it is it is blue but i do recall him as being one of the they are well i believe i believe it was one of the bra technicians that
02:08:42 one of the bra technicians that installed the you know that was that worked there
02:08:48 what did you understand his role to be sorry at one of the bay uh staff you know the one who one of the ones that was about you know
02:08:59 one of the ones that was about you know installing the thermo couplers and you know i don't actually know what his what his world was
02:09:04 was but i believe that that man yeah quite a big man
02:09:08 big man talk tormund dark hair i think i think that's him do you recall you remember him do you remember anyone else from the bre being there or
02:09:19 there or uh do you not have that clear memory
02:09:23 that no i was saying those people and several others there was a younger there's a younger man as well that was around quite a bit and i can't i can't recall i just was
02:09:35 and i can't i can't recall i just was the younger girl there's a gold glasses as well i think but i don't know that no there were particular stages they were
02:09:44 they were around doing their work all over the place all the time like i said they were around doing things a lot can i take you to um the final test
02:09:56 can i take you to um the final test report which is bre 402497 at page 29.
02:10:14 402497 at page 29. this is a photograph which made its way into
02:10:18 into the final test report uh which is not one of the ones which you sent to mr roper obviously that white board is still partly there
02:10:30 partly there do you remember bre staff taking photos as you were dismantling that whiteboard i think that's your friend richard in there no no i don't recall anyone taking
02:10:42 no no i don't recall anyone taking photographs at any specific interval but i
02:10:44 i do i am aware that they were taking photographs as and when they deemed necessary they'll say that it was it was available it you know it
02:10:55 it was it was available it you know it was it wasn't available to be seen and photographed at any point in the forum so and they were doing such but you know with
02:11:03 with specifics no i'm just wondering if i
02:11:09 whether whether i was requested to take it down in that manner so that i could although again i'm just guessing i'm just guessing you can't remember any specific requests like that no
02:11:21 like that no no um apart from you and uh bre staff was there anybody else in attendance who was taking photographs
02:11:33 i don't i don't remember i don't i don't think so
02:11:37 think so but there could have been i don't know did anyone at the bre ask you about that white board whilst you were dismantling the room i don't specifically remember no
02:11:50 i don't specifically remember no thank you um i'm coming to my last topic uh which i can take fairly quickly um
02:12:00 there were we know from celetex that there were some revised drawings issued um after the second test which were then sent over
02:12:11 which were then sent over were you asked to check those stories at any point
02:12:15 any point i don't i don't ever remember um no
02:12:24 i don't i don't think so should i say i don't think so whatever you call
02:12:30 those drawings were sent to the bre um in july 2014 uh one of the changes which we can look at if we could get up side by side um cel
02:12:45 if we could get up side by side um cel 403194 and cel403201
02:13:14 sorry we may need to zoom in actually on um the top left hand corner photo diagrams both
02:13:27 it's very small here so you may not be able to see but there is a thank you that's very helpful can you see on the left hand side of the screen now about halfway across
02:13:38 screen now about halfway across there's a red red screw going vertically and the same it's on on a line with aluminium
02:13:47 aluminium continuous rail
02:13:50 yes and then there's nothing there's no text next to that red screw on the left hand side on the right hand side which is the revised version there's a very small number 10 um next
02:14:04 there's a very small number 10 um next to
02:14:05 to the red vertical screw yeah i could say that yes
02:14:08 that yes yeah um and that uh that is the introduction of a 10 millimeter vertical joint running through the system and can you
02:14:19 running through the system and can you recall what the width of the ventilation gaps were in the right
02:14:26 the right presumably since the only drawings which were actually available to you were the original ones which are the ones on the left which don't show the gap um you wouldn't have built that
02:14:38 in
02:14:42 no but but if
02:14:47 generally standard is is the the ventilation expansion gap is the same as the
02:14:55 the width of the panel so if that was an eight mil panel it it would have been a minimum of an eight mil gap or eight mil joint i would guess but we could go to the transcript for
02:15:07 but we could go to the transcript for day 72
02:15:08 day 72 page three
02:15:19 other than that i can't really recall uh if we look from line 16 this is mr robert giving evidence and at line 16 he was asked did you instruct patrick
02:15:32 16 he was asked did you instruct patrick jones or patch jones to construct the panels with very small under 10 millimeter gaps and he said yes and then he went on to say
02:15:40 say lines 21-24 we had a discussion i didn't fully understand the ventilation requirements but i think patch sort of indicated that you don't necessarily need eternal 12 mil gap and yes it's that
02:15:53 eternal 12 mil gap and yes it's that with the concept of trying to over engineer
02:15:55 engineer do you remember any conversation along those lines about the ventilation gap
02:16:02 not really right likely likely looking at that probably the same thing
02:16:10 thing not specifically but i've got a vague recollection of
02:16:16 do you think vaguely if you would have said what you just said to us that the minimum would be um yeah yeah i didn't i wouldn't i don't think it would have been any less than that it wouldn't be any
02:16:27 any less than that it wouldn't be any less than if it was the panel unless i was instructed to do that but i can't remember what it was generally
02:16:33 generally generally it would be 10 mil or the panel that you're using because because if you've got a piece of eight mil panel and the gap supposed to be out on you can cut paste that panel off
02:16:44 off and use the panel as the gap if you understand what i mean and the 10 ml packers are readily available which is a standard sort of a gap
02:16:51 gap so i wouldn't have thought even a smaller gap than that unless i was specifically asked to do that but i can't remember i can't remember putting a smaller gap in for any reason
02:17:02 in for any reason and did any of the conversations you had with mr roper when you're installing the two tests or otherwise
02:17:09 otherwise um touch on this idea that celetex were over
02:17:12 over engineering the rig no sorry and did you form any view that celetex were attempting to do that in order to secure a pass for their
02:17:23 in order to secure a pass for their second test no no what like for the second test what i said before what they were doing putting it
02:17:34 putting it two panels i don't know what is sorry putting a thicker panel at that point
02:17:40 point made perfect sense to me because it it wasn't the panel that was being tested the way i understood it so no i didn't i didn't think there was anything
02:17:49 anything um wrong with what they were doing thank you very much mr jones mr chairman and member of the panel that's the end of
02:17:57 of our prepared questions um might we take a break just see if there are any further questions from anyone following um yes certainly before
02:18:09 anyone following um yes certainly before we do mr jones what happens to all the materials after the test rig has been dismantled though there are skips or stillages then we dismantle it into that into the skips
02:18:22 dismantle it into that into the skips and then barely tipping into a larger one i believe yeah all right thank you very much um right well council's reached the end of the questions that she has that she thinks she wants to put to you
02:18:33 that she thinks she wants to put to you but we always have a break at this stage so that
02:18:36 so that she can just make sure nothing's been left out and also to allow others who are not
02:18:42 are not uh as directly involved to suggest questions which perhaps we might put to you so we're going to have a break now we'll
02:18:49 we'll come back at half past four and see if there are any more questions for you and um in the meantime please don't talk to anyone about your evidence while we're
02:18:59 we're out all right yep of course you would have passed for them please thank you very much
02:30:10 well welcome back everybody we're now going to see if there are any more questions for mr jones i'll just check that he you can see and hear me all right you there mr jones yes i can hear you answer you yes good
02:30:23 yes i can hear you answer you yes good thank you very much um well we'll now find out whether ms sullivan has any more questions for you if you're ready to go on yes ms sullivan thank you i'm afraid just a couple and could we look at cel50780
02:30:55 um mr jones this is a a a method statement prepared by simcoe uh which was then sent to the bre in advance of the prepaire test
02:31:07 in advance of the prepaire test did you ever see this method statement
02:31:11 i don't recall possibly i i really i can't remember it's usually it's standard procedure that i would i would say the method statement and the risk assessments before
02:31:22 assessments before i'll start any work i don't recall it but it is standard procedure so i might well have john do you remember seeing um any other method statements other than this one no i can't
02:31:35 other than this one no i can't i can't remember at all thank you um a couple of questions just about the photographs you took i think you said you think you would have been taking them on your
02:31:46 have been taking them on your mobile phone is that right yes would those have their dates stamp on them
02:31:52 them time and date
02:31:55 i've found those photographs because they're in i'm sure they'll be dated i don't think like the date stamp sorry i don't think i'll have a time stamp on them or anything but they're in they're in my google photos
02:32:08 they're in they're in my google photos that's where i found them from so they are dated do you still have them in your google photos do you i think so yes well we may come back to you by letter
02:32:19 well we may come back to you by letter about that but thank you we know you've already provided them and we have got them um the final question uh no sorry the last but one question
02:32:31 no sorry the last but one question did you keep a diary or a calendar at the time
02:32:34 the time showing your work commitments um no a very lacks long path i possibly got records uh i have got i did used to keep a diary but you know
02:32:46 i did used to keep a diary but you know i didn't keep it up i did in the first break i did run out of the garage another rumors through but i couldn't find one i may well have a record of the of the times
02:32:56 times but no possibly no thank you um final question then actually final this time um did you have any involvement we've spoken about the cavity barriers and
02:33:08 spoken about the cavity barriers and someone from sidewise maybe and did you have any involvement in the design of
02:33:13 design of where those were pushing the system no i was just instructed as to what to build and i built it now they just say please can you build this in this particular manner
02:33:26 this in this particular manner and i'll just do that no i didn't have any import in the you know the location or no no design input
02:33:33 input thank you well um mr sherman those are actually all of my questions um and i just thank mr jones for having come to assist us it's really very much appreciated
02:33:44 very much appreciated yes well thank you very much ms sullivan well mr jones it's right that i should thank you on behalf of the panel for making yourself available to give evidence it's been very useful to us to hear what you have to say and and we're very
02:33:56 you have to say and and we're very grateful to you for as i say making yourself available and and that's all the questions we have for you and now it's all over so thank you very much for the done thank you
02:34:13 all right thank you um
02:34:18 and i think we're going to be sent on a different on our different ways when someone yeah around to pressing the
02:34:28 buttons
02:34:41 you