CEP Evidence - Wednesday 23rd September 2020 (2/2)

Full transcript

00:00:08 right would you like to ask mr blades to come back please

00:00:27 all right mr blake is ready to carry on yes thank you thank you very much yes mr villain mr blades before the break we were looking at the email which had come from deborah

00:00:38 at the email which had come from deborah french it's cep3049719 can we get back to that please yeah and uh in the third paragraph she says and we've

00:00:49 the third paragraph she says and we've read it regarding the supply of rayna bond in the uk she says as you know we supply both pe and fr

00:00:56 and fr core so just pausing there it is quite clear from that point onwards that you were very clearly aware that

00:01:04 that rayner bond supplied acm panels with both a pe and an fr call that must be right wasn't it yes and uh if you then uh look down

00:01:16 and uh if you then uh look down at the

00:01:19 just give me a moment yeah the at the um third line down in that paragraph uh miss french refers to supplying rayner bond only to a very

00:01:30 supplying rayner bond only to a very small group of approved fabricators do you know what she meant by approved fabricators that would have i'm taking that to me in companies like cep and i think we there was something

00:01:43 cep and i think we there was something earlier where there was a few other company names mentioned um

00:01:48 i think sawtech was one and a couple of others mentioned that they had a what they're classed as a small group of fabricators who who didn't

00:01:59 fabricators who who didn't who weren't installers i think that's how they viewed it right she refers to approved fabricators what did you have to do did you think to be approved as she calls it i i believe one of the

00:02:11 as she calls it i i believe one of the criteria was you didn't install or you you weren't the sole

00:02:15 the sole or you weren't the end user of it as at may 2013 the date of this email how many projects do you think you would worked on with deborah french

00:02:26 end of which year sorry as as at the date of this email which is may 2013 how many projects do you think up to that date you'd worked on with deborah french or using

00:02:37 french or using her products not many the one i do recall was camden yes um

00:02:43 yes um right she says

00:02:49 um that uh in the third line that she always works with a very small group of approved fabricators working very closely with them on all projects

00:02:59 projects we are able to follow what type of project is being designed and then offer the right

00:03:04 the right the right specification including the core

00:03:09 core um would you say that arconic from your experience of them prior to this email always

00:03:14 always understands what core is being used in projects yes and and is it right that arconic controls what core is used in acm clouding in all projects as she says

00:03:25 clouding in all projects as she says exactly right i i i'm not sure i can't say that they control all codes i don't know from your but from your

00:03:33 from your experience of her to that point and she says

00:03:37 says uh um

00:03:40 uh um there's a controlled supply route on what she's saying there that i would agree that the iconic will have a full understanding of the projects that their

00:03:51 the projects that their their fabricators are working on yes i mean she says in the first line of that paragraph

00:03:56 paragraph that they can control and understand what core is being used in all projects and i'm just keen to know whether where she says arconic controls uh what core is being used that was consistent with your experience of

00:04:09 consistent with your experience of reno bond and debbie french in particular i wasn't aware i don't think cep aware that they actually controlled what core was was used from our point of

00:04:23 what core was was used from our point of view we would ask request information or prices or samples for renault

00:04:30 renault we would never uh cpa never requested a particular core

00:04:39 so in terms of whether they controlled it from their side i can't answer that right

00:04:44 right she says later on in that paragraph as i've read to you that arconic always made sure they offered the right raina bond specification including the call was that your

00:04:55 including the call was that your experience

00:04:59 in other words when they were putting forward a reign of one specification they would take into account the appropriateness of the call for the project

00:05:09 i would have believed so right

00:05:15 where she says uh in the last but one line we are able to follow what type of project is being designed stroke developed

00:05:23 developed and then offered the right renault specification including the core and what kinds of buildings would pe continue to be offered as opposed to fr do you know i don't know

00:05:37 did you get the impression from this email that she was saying that uh reyno bond or that is iconic um would match

00:05:49 um would match the appropriate core of an acm panel to the particular building the subject of the project in hand i would agree so i think that's the intimation of this yes that's how you understood it would agree this yes

00:06:04 yes did you think how the type of project was likely to affect what core was offered we put that slightly different way

00:06:14 way did what did what went through your mind as to the

00:06:18 as to the what the right project for a pe core was and the right project for an fr core was wean cp never distinguished and made

00:06:29 wean cp never distinguished and made reference to the core with particular projects certainly prior to rainfall fire right we would request an acm information in this instance on

00:06:42 an acm information in this instance on we would ask information about render bond as a sample or a price with no reference to a core right when you say we see ep never distinguished or made reference to the core does that

00:06:54 or made reference to the core does that tell us that in your experience of rayna bond until this point you've never had a discussion with debbie french about which kind of core pe or fr fitted what kind of project that's correct i see did it surprise you

00:07:08 that's correct i see did it surprise you when she said uh that uh arconic was able to follow what type of project was being designed and developed and then offered the right rainer bond specification including the

00:07:19 rainer bond specification including the core did that surprise you at the time given that it hadn't been your experience of them i would like to say probably not at the time but it does now does that mean that you didn't read it carefully at the time sufficiently for

00:07:30 carefully at the time sufficiently for it to surprise you probably yes okay now um by right specification given the context of this email which is a a cladding fire in the uae regarding acm

00:07:42 a cladding fire in the uae regarding acm or involving acm what did you understand at a mean by right specification the right rayner bond specification in that last line

00:07:53 i would refer i would believe that the will be referring to the specification that was used on the building in the uae

00:08:05 in terms of whatever material was specified there

00:08:10 yes in in other words safe in in relation to the fire risks posed by the building yes was it your experience with alcoa

00:08:22 yes was it your experience with alcoa and rainbow in particular that they work closely with cep to know what you were making and for what project yes and that included grenfell tower yes they were aware of the projects that we worked on

00:08:33 worked on yes does that mean that she knew once cassette had been selected later in the story and we'll come to it

00:08:45 later in the story and we'll come to it that uh

00:08:47 that uh that pe acm panels were going on to grenfell tower yes and she knew that the building so far as you recall it was above 18 meters in height correct did you take any steps

00:09:01 correct did you take any steps in the light of the email to make sure that the right technical specification including the core thereafter was offered on each project by

00:09:08 by rayna bond i personally didn't know did anybody appear at cep not that i'm aware of what did debbie french do in that respect do you know i don't know did you ray

00:09:19 do you know i don't know did you ray having got this email did you raise the potential dangers of using acm pe with anybody on the grenfell project no

00:09:31 so you didn't raise it for example with studio e no why's that i wasn't aware that that studio a was going to be used in reno bond on the project at that time well we've seen from the

00:09:44 at that time well we've seen from the discussions in late 2012 and certainly february and march 2012. uh 13. march february march 2013 that

00:09:55 uh 13. march february march 2013 that you were

00:09:56 you were discussing or proposing reyna bond acm panels

00:09:59 panels with a pe core uh for use on the building as the clouding rain screen material

00:10:04 material having done all that having had those discussions and introduced debbie french into the

00:10:09 into the into the story uh why didn't you having got this email go to studio e and say look there's been a fire in the uae we've been talking about acm panels for grenfell

00:10:19 grenfell um we need to be very careful that we get the right core for the building why didn't you do that i can't answer that

00:10:26 that do you think you should have done in hindsight yes yes

00:10:34 can you explain how if debbie french was able to control as she says what acm products went on to grenfell tower grenfell tower ended up with an acmpe core and not an fr core

00:10:46 core and not an fr core i i don't know don't answer right did you think that it was any part of your job

00:10:51 job to make sure whatever debbie french was doing that you made sure that studio e and others in involved in the project at the buying end made sure all they knew that at least the difference in terms of fire

00:11:03 least the difference in terms of fire performance between pe and fr core can you just repeat that yes it was a long question let me try and shorten it having got this email did you not think

00:11:14 having got this email did you not think that it was part of your job let me put it neutrally did you think it was part of your job to alert studio e or ryden or harley whoever you were dealing with to the differences between pe

00:11:24 pe and fr core

00:11:30 i don't believe i did know personally and why was that um

00:11:37 no particular reason and again do you think you should have done in hindsight possibly yes [Applause]

00:11:50 were you aware of a fire at nosley heights in 1991 an exterior fire i began i am aware of it but it was prior to me

00:12:01 prior to me joining cep it was when did you first learn about the fire i couldn't tell i can't recall he's something i just had heard or became aware of right

00:12:12 had heard or became aware of right before 2012 probably yes yes what about the fire at lachnal house in london in 2009. were you aware of that yeah

00:12:21 that yeah i i wasn't aware of it but again i don't particularly call it were you aware of a fire at the murmurs tower in ruby in france in 2012 exterior fire what about the um lacrosse

00:12:34 exterior fire what about the um lacrosse building in melbourne in 2014 no what about the address in dubai 2015 no the torch dubai 2015. no no

00:12:48 did you ever do any investigation yourself into the history of exterior cladding fires either in the uk or globally no okay we then turn to a totally different

00:12:59 different topic which is quotations in december 2013 and then into january 2014 so moving the story on um i think it's right isn't it that cep became involved

00:13:11 right isn't it that cep became involved in the grenfell tower refurbishment in december again i think there having been a a gap in december 2013. yes we left off the story i think in april 2013 we picked it up in

00:13:23 2013 we picked it up in december of that year do you remember that i do remember 13. now if we look at cep five i'm sorry six zeros

00:13:31 zeros six zeros 267

00:13:36 this is an email from you to mike alberston

00:13:39 alberston of harley dated the 20th of december 2013

00:13:43 2013 and i'm sorry what that what's going on to the page is uh the end of the email run i should show you page three first which starts at the foot of page

00:13:55 first which starts at the foot of page three

00:13:56 three and here is an email from you to mike albertson of harley on that date 20th of december 2013. morning mike following my telephone conversation with mark harris yesterday could you please forward your window and

00:14:08 could you please forward your window and curtain wall schedule with regards the rain screen overclouding we are to offer our system based on a cassette tray and face fixed acm

00:14:15 acm i.e rayno bond to this could you please forward elevation drawings and any other information you feel is relevant now you say there was that this was further to your telephone conversation with mark harris yesterday that would be

00:14:27 with mark harris yesterday that would be the 19th of december correct do you remember that conversation in yes what do you remember of it you tell us uh i

00:14:37 uh i i i'm assuming that i'd spoke to the architects or somebody and they they'd informed me that the job was out to tender the project was out to tender um in the wrong phone call

00:14:50 um in the wrong phone call i contacted harley's spoke to mark harris

00:14:55 harris he advised me that i think he at the time about that they had the documents they'd been talking to um studio e

00:15:06 they'd been talking to um studio e uh in the past about the project and about the products and that renabong was within the documents

00:15:13 documents and could we provide a price for that uh and with an option of range screen uh with cassettes and first fix panels right so you rang mark harris

00:15:24 harris correct what prompted you to do that because it's the type of work grenfell does a type of work that hollies would engage themselves in so um yes you get the case of bringing him

00:15:38 um yes you get the case of bringing him to find out if he was involved if they were involved as it's a type of work that they

00:15:42 that they work on yes and it's in london so it's on their on the in their area we've seen that you've had previous discussions with studio e earlier in the year and then they've been a long gap so my question is what

00:15:54 been a long gap so my question is what after that gap had prompted you to pick up the telephone at all to anybody on the project i may have wronged them during the course of the year and the response

00:16:05 course of the year and the response would could have been that at the moment in town we're still investigating options or we haven't finalized any details give me a call in

00:16:13 a call in three months time two months time right and that type of thing was it your your habit or practice to as it were keep tabs on potential subcontractors such as harley

00:16:25 such as harley because they offered a business opportunity for you occasionally yes no we won't particularly keep tabs on them um we'd more keep tabs on on the project itself to find out where that was at

00:16:37 itself to find out where that was at understand than the subcut tracks themselves yes i see so does it come to this you were involved earlier in the project talking to studio he you knew harley were a potential subcontractor you had

00:16:49 subcontractor you had from time to time discussions with them about the project and this was another and i had not spoke to harvest about this project till december 13. right so this is the is this the first contact you'd had with harley

00:17:01 first contact you'd had with harley about

00:17:01 about grenfell about grenfell yes right correct

00:17:05 correct and you say um in the email we are to offer our system based on a cassette tray and face fixed acm i.e rayno bond

00:17:16 fixed acm i.e rayno bond did mark harris ask you to quote specifically on that basis i can't confirm that specifically but i've i've mentioned it in the email here to mike alberston i would

00:17:31 email here to mike alberston i would propose that that was raised by mark harris

00:17:34 harris i would i wouldn't have had sight of the document so i wouldn't know what the documents consisted of so i think you're agreeing that the email rather suggests that mark harris asks you to quote specifically on that basis

00:17:46 basis yes yes do you remember whether mr harris asked you to quote on the basis of any other product product such as the luco bond no so only rayna bond yes i see

00:17:59 did you ask him how or why he was interested in only having rainer bond and no other product other than the fact he will he probably mentioned that it was in the documents right and now let's move to january 2014

00:18:12 right and now let's move to january 2014 can we go to cep60205 please

00:18:20 and we can see that here is an email at the top

00:18:26 which responds at least in email terms to your email of the 20th of december we've just been looking at and it comes back to you from mike elviston 6th of january

00:18:35 january with some attachments including the last attachment nbs spec h92 rain screen cladding do you see that yes

00:18:45 yes so that's the h92 part of the mbs specification dealing with rain screen and hi jeff it says further to our telephone conversation this morning please find attached

00:18:54 attached schedules and nbs specifications for this curtain wall and windows i have also included the nbs specification for the rain screen and the elevation drawings i will send you a link for further drawings in dropbox

00:19:08 and if we go to the attachment uh the nbs specification h92 it said cep60215 please

00:19:19 cep60215 please six zeros two one five

00:19:23 when you got this from mr alveston on that day

00:19:26 that day did you look at that yes if you go um please to page two of this document

00:19:38 um please to page two of this document the specification there under types of range screen you can see is kme architectural solutions and the product reference is

00:19:49 solutions and the product reference is proteus hr honeycomb rain screen panel see that yes that's a zinc cladding with an aluminium core and a honeycomb pattern isn't it i i believe so

00:20:03 i i believe so as i said earlier i've never worked with it so i'm not aware and if you turn back a page you can see that there is a reference to some comparison quotations or comparative supplied

00:20:16 quotations or comparative supplied installed costs and there you see rayno bond duragloss 5000

00:20:23 5000 metallic standard and non-standard satin gloss chameleon anodized look satin gloss and a leukobond spectra sakura 917 and then zinc quartz zinc composite polymer paddle by vm zinc

00:20:37 polymer paddle by vm zinc uh note face fastened solutions permitted

00:20:40 permitted now what did you understand by a quartz zinc composite polymer panel by vm

00:20:48 vm zinc to be i would have taken that to be the zinc that was discussed way back in october 12 right so

00:21:03 october 12 right so is that the zcm supplied by iconic

00:21:08 i yes i would believe it was right by them

00:21:11 them not another not another manufacturer it could have been i see according to debbie french she says that

00:21:18 says that that was zcm manufactured by rcm so that was your understanding of that was it if yeah it was a product that we we didn't

00:21:26 didn't associate with yes and then uh it clause 11 higher up it says reynabond duragloss 5000 metallic standard a non-standard satin gloss

00:21:39 standard a non-standard satin gloss what was standard a reference to did you think when you saw that uh

00:21:48 the standard would have been their standard colors right so not a reference to pe core not that i'm

00:21:54 that i'm aware of no right just picking up the reference to face fast solutions now um what did you understand by that the name

00:22:02 name facebook solutions that would be a to me that would be a reference to to rivet fix

00:22:08 fix flat panels right and it says permitted uh permitted as opposed to um what

00:22:19 uh what do you mean well um it says face fast and solutions permitted did you think when you saw this that you were to quote for cassette but that face fasting solutions were also

00:22:30 also i wouldn't take it right yeah they would accept a face fix panel i see and looking at the different rain screen products listed there did you ask harley why they weren't

00:22:41 did you ask harley why they weren't asking you to quote for any product other than rayna bond acm pe panels no

00:22:50 then if we go to page five of this document still part of the nbs specification we can see paragraph 220 specification compliance standards the

00:23:02 specification compliance standards the center for window and clouding technology cwct standard for systemized building envelopes did you read that at the time and noted

00:23:13 did you read that at the time and noted not in great depth no were you familiar with the cwtc standard no you weren't in your experience as a cladding fabricator is is the cwt cwct standard commonly specified in

00:23:25 cwct standard commonly specified in specifications it does occur quite frequently in a specification had you come across it before i'd seen that that

00:23:33 that that paragraph before yes but you hadn't explored what cwt ct standard actually contained have you ever read it no right have you read it to this day

00:23:44 no right have you read it to this day no

00:23:48 is that is there a reason why cep is a a a manufacturer of or fabricator of cladding panels um is there a reason why

00:23:59 cladding panels um is there a reason why you

00:24:00 you were not familiar with that standard my understanding it was more for companies that did a supply and fix

00:24:07 fix um a total contract supply as opposed to a manufacture of a panel or

00:24:17 you a paneling a rail system right right was anybody else within cep do you know familiar or he

00:24:28 had a working knowledge of what the cwtc standard contained i'm not sure i couldn't answer that right

00:24:34 right what did you understand was the intended purpose of including the reference to the cwct standard in this specification

00:24:45 i i wasn't sure did you ask anybody no why is that i i left those type of questions to designers

00:24:55 designers um who would have a better knowledge of what that referred to than myself right did you in your mind make any connection between the specification compliance

00:25:07 between the specification compliance standards cwct standard for system iron building envelopes here and the list of alternative rain screen cladding products

00:25:18 cladding products uh on pages one and two of this document i didn't you didn't were you aware in general terms i know

00:25:31 were you aware in general terms i know you say you weren't familiar with the standard but were you aware that the cwct standard for systemized building envelopes contained guidance that said that the building

00:25:43 guidance that said that the building envelope shall not be composed of materials which readily support combustion add significantly to the fire load

00:25:50 load and or give off toxic fumes no i wasn't you weren't you weren't aware with that no aware of that no okay uh were you aware

00:26:01 uh were you aware that it said that when one of the cladding elements is a composite of two or more materials the element as a whole must demonstrate the appropriate fire performance no it wasn't

00:26:24 performance no it wasn't so do we take it that at least so far as cep's involvement was concerned and and that involvement extending to discussions about the appropriateness of rayna bond acm

00:26:35 rayna bond acm for the building did you take any action to ensure that the two standards i've just referred you to were adhered to or in any way no we would have left that to the designing

00:26:50 subcontractors was it not important for you to know what standards your client had to meet so that you could provide a suitable product or suitable um finished product

00:27:03 product or suitable um finished product for

00:27:03 for applying to the building

00:27:08 can you just yeah where's that one was it not important for you to know uh what standards your end users had to meet

00:27:18 meet this is a a spec an nba specification probably would have been in hindsight now right

00:27:26 now right i see so you accept that you should have you should have done but didn't at the time

00:27:29 time yes yes

00:27:39 do we take it from your answers earlier on the debbie french email of the 13th of may

00:27:44 of may and looking at the nbs specification of putting the two together that even though you saw the 13th of may email about the fires in the

00:27:55 13th of may email about the fires in the uae

00:27:56 uae you didn't change your approach and make sure that your products when used on buildings

00:28:02 buildings in excess of 18 meters would comply with the cwct guidance i didn't personally know

00:28:12 and why is that

00:28:15 it would have been beyond my knowledge of those technical points and i would have had to refer those back to

00:28:26 a technical designer or somebody with more knowledge of those documents than myself can i then turn to the subject of insulation now if we stick with the nbs

00:28:37 now if we stick with the nbs specification document and go on in it to page 10. you can see there that um

00:28:47 we have at the top of the page paragraph 776

00:28:52 776 under the heading thermal insulation and then the second bullet point down manufacturer celotex limited and just a bit below that you can see product reference fr 5000 aluminium foil

00:29:03 product reference fr 5000 aluminium foil face both sides and three lines down below that

00:29:10 that's where we find the required performance now did you read this part at the time

00:29:19 as part of the nbs spec probably not why is that we've never used cep would never use a product like celertex we've always used mineral wool right um dual slab rockwell dual slab

00:29:32 right um dual slab rockwell dual slab canal

00:29:33 canal can you just explain why that is a from what our design engineer tells us that is non-combo stool and that's all it would ever put in if it was a cep project yes

00:29:45 if it was a cep project yes we would always use a mineral wool you always use always you a cep project always

00:29:53 always use mineral wool when you say a cp project you mean one which is a bespoke package

00:29:59 package if we designed if the design element was by sea

00:30:02 by sea and why is that can you explain because it was i well i was told and led to believe and that was the reason that mark he would have thought it uh it was non-combustible and and he wouldn't or they as a company he would

00:30:14 wouldn't or they as a company he would never sign anything off other than that right from a cep point of view

00:30:19 of view given that as you say it was a it sounds like a golden rule cep when designing the full package would never use a product like set like this celitex product can you explain why

00:30:31 product can you explain why you didn't spot its presence here in the nbs specification i probably skipped over it to be honest on that i said because my quotation which from doubt will go on soon qualifies that we have used uh mineral

00:30:43 qualifies that we have used uh mineral wool

00:30:44 wool would it not have stuck out like a sore thumb to you i wasn't aware of celotex to be honest i wasn't aware of the company name or with that i can read now and understand what that product is yes well i i we would never have quoted

00:30:57 yes well i i we would never have quoted that

00:30:59 that even it's in the documents how do you spot it that this was a rigid pie polyester signature insulation board being proposed within the nbs spec together with a brainer bond as an alternative

00:31:12 brainer bond as an alternative if you'd spotted it what would you have done well as we was quoting a another company

00:31:18 company a subcontractor um i would take it that the architect and all

00:31:25 all other people has been involved in the design and putting together specifications they would have knowledge of this product and they would deem it to be acceptable

00:31:35 as i said cep wouldn't use that as a product going back a little bit to an answer earlier on about uh

00:31:46 an answer earlier on about uh mark haywood wouldn't would only ever use a non-combustible insulation can you explain why that is and in particular why that

00:31:58 why that is and in particular why that is the case where it's being used within for example an acm

00:32:04 an acm brain screen i can't answer why mark here would have thought he's always used uh a mineral wool but that is all that he's ever used as far as i'm aware on all cep projects do you know

00:32:16 aware on all cep projects do you know why that is because he believes you see well you know it is a non-combustible which is a product that he will work with right was it was it something i don't want to put a thought into your

00:32:28 i don't want to put a thought into your mind but try and prompt it if i can was there something in his concerns that you knew about about mixing uh a pir insulation product

00:32:41 pir insulation product with a rain screen panel compressed i don't believe you don't i think it was there as market what i thought it was a business they had a view that they would only use mineral wool insulation right

00:33:03 were you aware of the difference in terms of fire performance between pir which is what this celetex product is or was

00:33:10 was and mineral will at the time you received the specification

00:33:16 no no were you aware at least in general terms of the role that combustible insulation can have in a an exterior fire

00:33:26 not really not

00:33:40 did you

00:33:43 having seen the nba specification and i take your

00:33:46 take your point that you didn't read at all did you have a discussion with deborah french

00:33:52 french about the appropriateness of using pir as the insulation material together with the rain screen acm that she was i don't recall i did no proposing right

00:34:05 did you ever have a discussion at all with studio e or harley or ryden no about the insulation no can we then go to cep 60244 please this

00:34:20 can we then go to cep 60244 please this is an email chain between you and deborah french in early january 2014 and this is on now on the 7th of january 2014. if we go to the bottom of

00:34:31 2014. if we go to the bottom of page 1 we can see you go to deborah french

00:34:35 french on that day this is the day after you get the nbs spec and you say hi debs please see the attached rain screen spec ref the above could you please advise rates for rayna bond accordingly

00:34:46 rates for rayna bond accordingly see that yes and then you end the email and we need to turn to page two for that catch up with you these next couple of weeks

00:34:58 weeks and would you normally send a manufacturer an nbs specification for a particular project

00:35:05 not normally but in this instance because

00:35:09 because um we was asking for well we're sending this specification over to her with the with the various color options um send it there for a reference

00:35:27 probably more for prices for the two for the colors the chameleon and the other colors it was was reference in there right why do you think she needed to see the full

00:35:38 the full nbs specification that you'd been sent by mike albiston the day before in order simply to quote rates for rayno bond that you'd ask that you'd asked her for i i don't

00:35:49 that you'd asked her for i i don't recall it could have been simply just to forward that part of the documentation we received from harley's than try and separate out pages

00:36:01 than try and separate out pages yes i could see that would have been convenient but um why did you center the whole thing as opposed simply to separating it out and saying well could you please quote for these particular uh rainer bond

00:36:13 for these particular uh rainer bond products i don't recall as i say it was probably simply just to send that then try and separate pages out right did you expect her to advise you about whether or tell you about whether the rainer bond products

00:36:24 about whether the rainer bond products listed in the nbs specification were appropriate for the grenfell tower project

00:36:29 project i didn't send that with that purpose in mind

00:36:33 mind no but did you have an expectation that if there was something inappropriate or wrong she would tell you i would i would have thought so but it wasn't to say it wasn't in my mind to

00:36:45 wasn't to say it wasn't in my mind to do that that wasn't the purpose if they'd have spotted something that they had a concern about then i would expect them to flag it up but as i say it wasn't the purpose of sending that document across in its fullness

00:36:56 fullness right given the email that you'd received from debbie french on the 13th of may 2013 about controlling the supply

00:37:09 about controlling the supply why didn't you expect her to to tell you if she'd

00:37:12 if she'd seen something wrong with the specification or something that didn't fit

00:37:16 fit i probably didn't link those two the the the email i sent and the email that we received in may 13. you didn't put the two and two today

00:37:25 today i put the two and two together right did you and she speak after you sent the specification to her do you think i can't recall let's scroll up to the top email in the chain this is hers

00:37:37 chain this is hers to you of the 15th of january 2014 and she says here that she's um confirming the exceptionally good rates i quoted you for grenfell towers

00:37:48 i quoted you for grenfell towers double exclamation mark and then she sets out uh some specifications and then underneath that

00:37:56 that a price 28 pounds per square meter was there a discussion about these rates between you and her before she sent you this email no because she says just to confirm it

00:38:08 because she says just to confirm it looks from that as if there was an earlier discussion but she's now confirming if the water don't recall it all right

00:38:14 all right now she's creating 28 pounds per square meter which she describes as exceptionally good was it was it exceptionally good at that price i can't recall what the rates were for any other project to be honest now

00:38:26 for any other project to be honest now we've seen in your january email [Music]

00:38:31 [Music] it's short we can get back to it if you need to but we can tell that you didn't specify

00:38:35 specify what sort of core you wanted for the acn fr or pe

00:38:39 fr or pe and um nor did the specification that you sent her um when she came back to you on the 15th of january as we see here she didn't specified whether she was

00:38:50 she didn't specified whether she was quoting p

00:38:51 quoting p or fr either did she believe not no what did you understand she was quoting for pe or fr i would have understood that that would be

00:39:01 be um the standard rena bond product that had been used in the past by cep and other companies and looking at it now that would have been the pe core

00:39:12 the pe core so you refer to the p as the standard reynaband product yes passed by cep as i said we we would ask for renabond as a product for samples and price uh the core was

00:39:23 for samples and price uh the core was never discussed i see so am i right then well let me ask you

00:39:29 you your comment on this was it the case that in your understanding at this time early 2014 if someone asked for acm that would be pe core acs

00:39:40 pe core acs correct

00:39:44 now um uh we see 28 pounds per square meter is that not rather higher than you would usually pay for rain and bond i don't i don't know i we we got

00:39:57 i don't i don't know i we we got prices per per project and varying colors

00:40:02 colors right um can i just suggest to you that in fact you would normally pay four or five pounds less than 28 pounds per square

00:40:13 pounds less than 28 pounds per square meter okay yes you'll accept that i couldn't tell you well let's have a look at what debbie french says it's um m-e-t three zeros five three one six two

00:40:28 and i'd like to get page twenty two this is her witness statement of the fourth of november 2019 and at um page 22 paragraph 76

00:40:46 she says that she sees that she did provide a quote of 28 square meters for rayna bond she says i cannot recall the exact details of how i calculated this

00:40:57 details of how i calculated this quotation

00:40:59 quotation however this was a relatively high price for rene bond and cep would have known this because of their involvement in the market and the fact that they purchased renewable on previous occasions

00:41:10 renewable on previous occasions from the best of my memory i included a price at this level because i was aware that there was to be some form of discussion or negotiation between cep harley and the project managers and i make reference in the email to the price being a good starting

00:41:21 email to the price being a good starting point

00:41:22 point i do not remember any discussions about price at the time so is it right that your understand well did you understand debra french to be quoting

00:41:29 quoting 28 pounds per square meter expecting to be knocked down a bit from this i would say yes well this is her this is what she intended what was your understanding

00:41:42 your understanding in the natural course of of projects like these the client the contractor down the supply chain they always want a little bit off somewhere along the way let's go back to the email then which is

00:41:54 let's go back to the email then which is at the top of cep

00:42:00 60244

00:42:05 she says hope this is okay to start the bidding with harley's i'm sure you or neil will be back on the phone if you need any other detail straight reductions and then there's a whatever the opposite of a smiley face

00:42:16 whatever the opposite of a smiley face is yeah um

00:42:19 does that not did that not suggest to you at the time that she might be expected to be knocked down further on the price yes it would sound uh that she was

00:42:30 sound uh that she was expecting that um there there will be a request for akina price throughout the supply chain she was probably preempting what was going to

00:42:41 probably preempting what was going to happen

00:42:42 happen given that by this stage you knew that fr was available as a core and given the warning that debbie french had given about the about fr as opposed to pe and controlling the supply route carefully

00:42:55 controlling the supply route carefully can you explain why you didn't seek a quotation for the fr core acm given that you knew that it was going to go onto a building over 18 meters in height we would never cp we never asked for an

00:43:08 we would never cp we never asked for an fr core

00:43:09 fr core and to the best of the knowledge that we understood that the class or renaissance met the building regulations and is that why you didn't seek a quote

00:43:21 and is that why you didn't seek a quote for the fr core i would say so yes did you seek any quotations from any other manufacturers for example a luco bond at this stage

00:43:32 bond at this stage and is that the same reason i asked you before yes essentially um you said politeness i said loyalty correct we may agree or disagree about that but the same wrath yep yeah um now

00:43:46 if we go to um

00:43:52 cep6026 please sorry 268 please 268.

00:44:01 this is

00:44:04 an attachment that you sent to mike albertson on the 21st of january containing the cep quote and this one

00:44:18 and this one is for a metal tech system thermally broken aluminium profile windows and the rain screen over cladding there's another one i think you

00:44:30 there's another one i think you remember which had a quotation for wikona windows but the same clouding quotation correct you send them two quotations on there today just just for our record references that that one

00:44:41 that one is at cep60270 um but this one 268. um it says in terms of rain screen halfway

00:44:52 says in terms of rain screen halfway down rain screen over clouding panels are to be manufactured utilizing formula meter rayno bond acm and it says are to be manufactured does that reflect the fact that you were asked specifically

00:45:04 asked specifically by by mike albertson to quote for panels using four millimeter rain aboard acn

00:45:13 that sentence is a standard sentence within a quotation that cp would send out

00:45:21 out i see it could have been um panels may be manufactured utilizing yes it could have been manufacturing utilizing steny for instance

00:45:32 utilizing steny for instance but the wording would have been it was a fairly standard sentence i see so r b doesn't reflect a a

00:45:40 a specific request from no no and to be fair to you in fact the quotation that you supplied to mohit kitecha in february 2013 contain the same wording

00:45:52 following these quotations in

00:45:58 2014

00:46:02 uh i'm so sorry let me go back just ask one or two questions now we saw we saw in the h-92 specification that cep

00:46:11 that cep should have quoted for proteus hr honeycomb

00:46:14 honeycomb is the reason why cep didn't provide a quotation for that that cep simply didn't fabricate we we never used a company um no yeah

00:46:26 um no yeah and why not a quotation for a leuko bundle called zinc the luca bond i think we've covered uh and when

00:46:33 and when we don't do zinc turning to later in 2014 do you remember that cladding samples were sent for the grenfell tower project which which month

00:46:44 which month 2004 later in 2014 the summer of 2000 yes there were some requested yes normally am i right that samples are normally provided as a small flat sheet

00:46:55 normally provided as a small flat sheet which consists of a sample of the composite panel yes so you you get the aluminium sheet and then the core in the middle yes there's a square uh postcard side normally

00:47:05 normally right okay well let's see if we can get a picture sea three zeroes one four four five six please

00:47:16 this is a photograph of one of the samples which was sent to studio e

00:47:22 studio e can you see that yes now we can see here that it actually says this sample has an fr core you see that i do yes and given that you hadn't been asked to

00:47:34 and given that you hadn't been asked to quote for fr uh why were you sending a sample of fr called atm i don't i'm not aware that that came directly via cep

00:47:46 directly via cep i see i see um let's see what you did see um

00:47:58 you did see um you were copied in on a number of emails arranging for the delivery of samples weren't you not all of them but some of them um let's have a look at one cep

00:48:07 cep three six zeros two seven five

00:48:20 three six zeros two seven five and the second email done on that page is an email from deborah french to mark harris

00:48:27 harris 19th of march highmark good news ref grenfell towers in terms of samples and color options i will arrange to send the following and then she sets out a number of colors and then after the second set of

00:48:40 and then after the second set of products she says gwen could you please arrange to have the above samples for a6 sent out to mark harris at harley curtin wall asap and then you're copied in on that hi jeff

00:48:51 jeff this is on the 20th of march at the top of the page fyi email and samples we are sending over to mark at hurley harley curtin wall r grenfell debs did you see these

00:49:03 r grenfell debs did you see these samples that were sent no right were there any telephone conversations you had with arconic about sending samples to to to harley no do in any of the exchanges that you had

00:49:15 in any of the exchanges that you had about samples do you remember any discussions about what the core of the acm would be fr or pe no

00:49:32 have you any do you understand or know why

00:49:35 why the the picture of the sample i showed you earlier was a picture of a sample panel with an fr core

00:49:42 fr core no can we then turn to the mock-up in june 2014 do you remember cep was asked in june 2014 to make a mock-up

00:49:53 2014 to make a mock-up of the facade provide samples for the mock-up to provide samples right now let's go first to cep3051814 this is an email of the 25th of june

00:50:04 this is an email of the 25th of june 2014

00:50:07 2014 from sam ankita jones he's dan angel jones's brother to you attachments latest grenfell drawing 25th june 2014. hi jeff it says

00:50:19 june 2014. hi jeff it says the attached pdf shows the whole mock-up this should clear some things up for would you remember what

00:50:26 what it was that needed clearing up which you'd asked him to clear up i i don't know

00:50:33 maybe it was the measurements of some panels or the colour reference that i don't i don't it appears from this you had asked for the whole mock-up do you remember why that was we were

00:50:45 do you remember why that was we were asked to provide panels for the mock-up for harley's or harley's asked for a mock-up to made and we were asked to supply the panels right um could you let's go to the document

00:50:58 could you let's go to the document we need the offline reference please and it's cep3051815

00:51:17 do you recognize this as the drawing that was sent by sam and jones to you i recognize your drawing if you i can't say it was sam that sent to me but i believe that will be the case then

00:51:28 then we can see at the bottom of the page that it was it was created by harley on the 10th of june 2014 if we just go to the very bottom drawn by s.a.j yeah sam and jones

00:51:41 drawn by s.a.j yeah sam and jones and if we go to the top right hand corner

00:51:45 corner we can see it says for viewing purposes only no

00:51:48 only no insulation on mock-up you see that yes dude

00:51:51 dude did you see that did you spot that i would have done yes did you investigate what the insulation was going to be no i from that point they didn't require insulation on the mock-up

00:52:05 insulation on the mock-up from that point it was just they were looking to provide just the panels right no no insulation oh i see so the mock-up

00:52:16 no insulation oh i see so the mock-up didn't actually have the insulation on it just the panels i believe not yeah

00:52:23 now if we look at the drawing we can see that there are i think three different finishes

00:52:34 three different finishes champagne metallic smoked silver metallic

00:52:38 metallic and natural aluminium brushed and is it right all of those are rayna bond acm pe core foreign oh yes yeah is it usual for only

00:52:49 foreign oh yes yeah is it usual for only one type of clouding to be considered at a mock-up

00:52:54 or was it usually it's yes it's usual once they've got to a point where that's what

00:53:00 what the client and design team and subcontractors are looking at now these are all face fixed aren't they renamed acm they appear from the drawing whether they were on the mock-up i couldn't tell

00:53:11 they were on the mock-up i couldn't tell you

00:53:12 you yes and the note says that the uh drawing represents a temporary mock-up structure to show panel positions

00:53:20 positions and colors for visual purposes only um do you know why only um the face fixed

00:53:31 only um the face fixed uh panels were shown in the mock-up and no cassette i don't know

00:53:40 because we can see that no cassette fix was supplied for the mock-up do you know why one wasn't i don't were you aware that at this stage

00:53:49 stage the planners and indeed studio e were leaning heavily towards a cassette fix no did you get any sense from your dealings with harley or studio

00:54:00 from your dealings with harley or studio e or

00:54:01 e or or ryden at this time so far as you had any

00:54:04 any no that there was there was a i wouldn't say dispute but perhaps a difference of uh view as to whether face fixed or cassette should be used

00:54:15 cassette should be used no i wasn't aware it went on did you wonder why you weren't asked to provide a cassette for the mock-up for the mock-up not particularly

00:54:26 particularly uh as my understanding of cep's understanding it was to show the colours more than so it you know i never asked i personally never asked a question i don't think anyone else did

00:54:38 question i don't think anyone else did right because of course if it's just for the appearance it still makes a difference whether it's cassette or or face fixed so i just wondered whether it had gone through your mind to ask

00:54:49 through your mind to ask why it wasn't that a cassette mock-up wasn't also required no

00:54:54 now in terms of what was supplied for the physical mock-up we know that iconic sent smoke silver and metallic champagne both with a pe call

00:55:03 did you remember that i remember samples coming in

00:55:07 coming in yes and and then if we go to arc 7098 we can see the email chain about the cladding for the mock-up and i'd like to go into that email with

00:55:19 and i'd like to go into that email with you please to the bottom of page one on the top of page two

00:55:26 the bottom of page one and the top of page two

00:55:29 page two this is an email from debra french of thursday the 22nd of may 2014 to guanil dereninger copy to you do you see that hi

00:55:41 copy to you do you see that hi gwen and then if you go to the top of page two

00:55:48 page two she says we spoke this afternoon about natural brushed aluminium panels h9183s we have at the factory could we please send as foc mock-up

00:56:01 as foc mock-up material for project grenfell towers to cep facades and she gives the measurements many thanks debs so you could see from this email that you were going to be getting that product part of the mock-up

00:56:13 that product part of the mock-up and if we go to the top of page one we can see that mr endinger responds the next day the 23rd of may dear debbie and you're copied in on this as well mr

00:56:24 and you're copied in on this as well mr blades dear debbie i have spoken yesterday on the phone we have some rayna bond fr sheets on stock in four by fifteen hundred millimeter times different lengths including length below required

00:56:37 lengths including length below required two thousand two hundred and seventy millimeters that we could use for this mock-up

00:56:42 so we see her offering fr core acm for the mock-up did you accept that offer i can't recall whether we took those panels or whether we took

00:56:53 those panels or whether we took the original ones like did it occur to you as odd or unusual perhaps that you were being offered reyna bond 55 fr sheets for the mock-up

00:57:07 reyna bond 55 fr sheets for the mock-up the way i would have read that at the time it there was uh maybe that those panels were quicker to dispatch than the the the other

00:57:19 dispatch than the the the other requirements

00:57:23 you could see from from this could or could you see from this that at least so far as

00:57:27 far as uh alcoa was concerned deborah french and uh gwen is they saw the reiner bond 55 fr sheets as

00:57:39 they saw the reiner bond 55 fr sheets as interchangeable with pe sheets at least so far as the mock-up was concerned i agree yes did you think to explore with them

00:57:47 with them whether in fact given that grenfell tower was a building in excess of 80 meters

00:57:51 meters you you should actually be suggesting fr call to the client i i didn't and i don't believe cep did and at this stage of the project

00:58:03 did and at this stage of the project we were just working to other people's requirements yes

00:58:15 it's it's right i think that you actually then sent an acm panel for the mock-up with an fr core weren't you i can't remember well let's

00:58:26 let's let's have a look um arc six zeroes sorry five zeroes 103 arc five zeros 103. this is an order acknowledgement date of

00:58:39 this is an order acknowledgement date of the 10th of june 2014 so the same date as the drawing that we saw earlier with the mock-ups on it and we can see

00:58:50 with the mock-ups on it and we can see from this order acknowledgement that the natural brushed aluminium was supplied with an fr core do you see that i do yes yes and it was dispatched i think on the 6th of june 2014

00:59:03 of june 2014 delivery conditions dap saint helens

00:59:09 and the delivery address at the bottom is cep architectural facade in st helens you see that yes and the product a rene bond 55

00:59:20 and the product a rene bond 55 natural aluminium h103s wash coat and then reverse side coating fr you see that

00:59:28 that yes so it looks on the face of this document

00:59:33 document that an fr panel was supplied for the mock-up

00:59:39 yes i will agree with what's in front yes and that it went to cep architectural facade yes and in the box at the bottom it says mock-up for grenfell tower project to the attention of jeff blades that's you

00:59:51 the attention of jeff blades that's you yes so you would have received looking at this document is this right an fr reyna bond 55 panel so the that panel

01:00:02 so the that panel would have come into the factory i wouldn't necessarily have seen the panel because at that stage um all in cep were aware that the panel was coming in to be

01:00:13 coming in to be shipped back out for a mock-up so in case the panel was coming to his i guess

01:00:19 guess from this that we had to do some work cut it to a size maybe just drill some holes

01:00:26 holes it was coming to us to ship down to harley

01:00:30 harley um the fact that it's for my attention was i was

01:00:33 was i was probably a point of contact through the emails i may or may not i don't recall particularly seeing the panel i've come into the factory onto the shop floor

01:00:42 floor you know i would have no particular reason to go and inspect the panel itself per se would you not given that you were involved closely in the arrangements for the mock-up it was a name on a delivery dress that

01:00:54 it was a name on a delivery dress that came into the factory it could have been any one

01:00:57 any one name it he could have it wouldn't have to be my name it could have been the company address and the panel would have arrived on the shop floor um and

01:01:07 um and following the information that anchor tell jones had passed the panel would be um shipped out in accordance with that so i you know i don't recall seeing the panel

01:01:17 panel i was probably aware that he'd come in so i could advise or somebody and see if advise hull is that the panel would come in and it was going out

01:01:25 going out were you not well it says on the document

01:01:29 document mock-up for grenfell tower project to the attention of jeff blades and my question is given that it was for your specific attention

01:01:41 why would you not have gone to see it made sure it was the right thing and made sure that what was going out to harley for their mock-up

01:01:52 going out to harley for their mock-up was appropriate i would have maybe i went down and looked to make sure it was the right cooler do you remember i don't know i don't recall no

01:02:03 recall no i mean on the face of the documents we've seen so far it does very much suggest that you were at least by this time june 2014 aware that reynold bond 55

01:02:13 bond 55 came in an fr and was suitable at least for the purposes of the mock-up for use at grenfell and i've got to put it to you was this not something of a missed opportunity

01:02:25 not something of a missed opportunity in hindsight yes yeah now were you at the mock-up the actual viewing of the market you weren't was anybody from our iconic to your knowledge i can't tell you who was there is anybody else from

01:02:36 you who was there is anybody else from cep there not that i'm aware of it now cep i think didn't charge for the fabrication of the mock-up did it correct can we go to cep

01:02:49 504296 please

01:02:57 this is an email chain in june 2014 and if we go to the um the second email in the chain it's from mark harris to you on the 17th of

01:03:08 from mark harris to you on the 17th of june 2014. and if we look at the fourth paragraph down it says ryden are looking this is about the mock-up ryden are looking to harley and its supply chain to provide the

01:03:19 and its supply chain to provide the mock-up free of charge certainly alcoa have stepped up to the plate and agreed that the material will be free of charge from harley's end we will provide the mock-up design and installation free of charge and we'll look to your good selves as our supply chain partner

01:03:31 selves as our supply chain partner fabrication and delivery of the panels on a free of charge basis uh the description by mark harris uh of cep as harley's supply chain partner

01:03:44 is that something you would agree with were were you their supply chain partner in that sense we we supplied to them and in this instance we would probably be in a supply

01:03:55 we would probably be in a supply partner um yeah i think that's a little bit of um

01:04:04 of wrecking the pudding but yes we were a supply chain company to them yeah and was the reason the cep did the mock-up for free uh was because you were expecting or at least hoping that

01:04:15 least hoping that cep would be chosen for the fabrication for the project yes and probably wouldn't have paid for it anyway they would wanted it free

01:04:26 anyway they would wanted it free that's the nature of the business no i understand can i go then in in light of nature of the business to an email chain from the same period this is

01:04:38 cep505371

01:04:45 and page two

01:04:49 we can see an email from simon lawrence to uh bruce zone's mark harris copy to ray bailey you see that uh you wouldn't have seen

01:05:00 you see that uh you wouldn't have seen that

01:05:00 that at that moment uh and if we look at the fourth bullet point down

01:05:10 um mr lawrence says mark to contact mark harris to contact rayna bond about time scales

01:05:17 scales to get materials for mock-up natural aluminium brushed h9183s and champagne metallic e 101s then if we look at the bottom of page 1

01:05:28 then if we look at the bottom of page 1 we can see what happens to this email chain

01:05:32 chain you can see that mark harris sends that email on to deborah french on the same day half an hour later

01:05:45 on the same day half an hour later and it's copied to you you see that yeah deb jeff to keep you in the loop this will be no problem for cep they have very little on at the moment haha exclamation marks and then

01:05:58 exclamation marks and then um goes up going up the chain you can see that deborah french responds on the 9th of june to mark harris copper to you mark you're cruel smiley face i will bring the smelling souls round jeff

01:06:09 souls round jeff exclamation marks

01:06:12 and then you respond the same day a few minutes later to deborah french and mark harris saying nothing's too much for us at the moment we just keep fabricating rain screen and

01:06:23 we just keep fabricating rain screen and glazing and then send it out with whichever project was last spoke about lol mark all i can say is you'll be taken out for a very nice meal very soon somewhere very nice now i've shown you all of that were you

01:06:36 now i've shown you all of that were you expressing gratitude in this email for your involvement in the project

01:06:47 for your involvement in the project not particularly it was a turn of phrase that i think is used um

01:06:56 and i think it was just meant tongue-in-cheek that um what it says you know you may get something i don't think it's meant to be a weight is being

01:07:08 think it's meant to be a weight is being presented

01:07:09 presented well it says what it says yes and i'm just asking you um were you expressing gratitude to martial thank you

01:07:17 thank you for giving us the opportunity to quote them yes

01:07:20 them yes yeah and is that because harley you felt harley had done you a favor by pushing the grenfell tower project your way

01:07:29 way i wouldn't have said they've done it a favor but they certainly gave us the opportunity of the business

01:07:40 can we turn on then in the story uh is it right that from june 2014 at the latest the only cladding being

01:07:51 at the latest the only cladding being discussed so far as you were aware was reyna bond pe acm on grenfell on grenfell yes yes yes

01:08:09 uh and if we go into august 2014

01:08:15 cep60443 please this is an email chain that starts at the end of july if we look at the second email down on that page

01:08:25 that page mark harris sends an email to you copyright french 31st of july jeff deb copy for your interest

01:08:34 interest and below that you can see that simon lawrence was telling harley that in the third line the client has just confirmed to

01:08:45 the client has just confirmed to planning that they are looking to proceed with rainer bond champagne color as shown on the mock-up for the main body of the building and the cladding will be the cassette fixing version so you all sent that

01:08:57 version so you all sent that and if we then go to the top of the page we can see that the next day first of august 2014 deborah french responds to mark harris and you hi mark it's

01:09:08 to mark harris and you hi mark it's getting exciting thanks thank you for your hard work and perseverance in putting rayner bond forward

01:09:14 forward i think i owe you and jeff either lunch or dinner at some point debs

01:09:22 now presumably is this right the debra french

01:09:25 french was also very grateful to uh mark harris and to you uh for involvement in the project i would think that's a question for deborah french to answer

01:09:37 deborah french to answer okay is it was it your understanding receiving this email from deborah french that she was grateful to you given that you were one of the invitees to the lunch or dinner

01:09:48 of the invitees to the lunch or dinner that she was proposing um all i can say is that

01:09:51 is that the three companies acted very professionally and i never got took out for lunch

01:09:57 for lunch by anybody um i take it from the debbie french was thankful that renner bonded got some work out of a project in the uk yeah and you may or

01:10:08 project in the uk yeah and you may or may not have got your lunch i didn't mr blades but the point is she was grateful for you to you for your role in putting reigning bond forward it would appear so yes yes can we then

01:10:19 it would appear so yes yes can we then look at your second statement paragraph 62. this is cep3064247 page 13 paragraph 62.

01:10:31 page 13 paragraph 62. you say there no we looked at this before no i did not put rayna bond forward

01:10:35 forward in the light of this email that we've just been looking at it's not a it wasn't only mark harris who was putting rainbow on forward it was you as well hence debbie french's gratitude to you and the offer of lunch or dinner

01:10:47 and the offer of lunch or dinner i would say yes yes mr chairman we're going to turn to a different topic a slightly longer one

01:10:58 a different topic a slightly longer one which will take me well beyond the next 10 minutes and a break i don't know whether you would you rather break at this point well it might be sensible um it depends on how long that topic takes it might

01:11:09 on how long that topic takes it might take

01:11:10 take 15 minutes it might take five it depends but i'd rather not take the chance all right and we'll have a break there then well i'm happy to continue but we we could

01:11:19 we could we it's it's been early isn't it early yes yes

01:11:22 yes yes see if okay we'll press 5 rather than 15. all right i'll take a i'll i'll take the risk um i want to ask you about the bba certificate i should have asked you you're happy to carry on for another 10 or 15 minutes

01:11:35 carry on for another 10 or 15 minutes five minutes with yourself sir five minutes five minutes five minutes let's see may not be um we've talked about the abba certificate or talked around the subject i'd like to to talk about it in particular

01:11:47 to talk about it in particular can we start with cep60281 please this is uh an email of the 23rd of april 2014

01:11:56 2014 from debbie french to mark harris yes and you can see it there and you are copied in on it as is mike alveston and harley

01:12:06 harley and attached to that are a series of documents the first of which is the bba certificate zero eight four five one zero as a pdf do you see that yes

01:12:21 that uh email followed as you can see just below it a request

01:12:29 a request uh by harley which i don't need to show you i want to show you the certificate that's at cep60282 please

01:12:45 now before the 23rd of april 2014 mr blade had you seen this certificate i will have done yes you would have done

01:12:57 would you how often would you have seen it do you think or looked at it once maybe twice we can see that it was issued in january 2008 if you look at the large blue box

01:13:09 2008 if you look at the large blue box towards the bottom of the page do you remember when you first looked at it of the once or twice no i don't recall did you look at it when it was first issued

01:13:20 when it was first issued i i can't say i don't recall do you recall

01:13:23 recall a grand discussion about this this certificate particularly involving uh ray bailey and harley no in general terms

01:13:34 terms no ever i don't recall one right

01:13:41 you say you'd seen it once or twice were you familiar with it well you were familiar with its terms i hadn't read it in great depth to be honest right

01:13:51 when you received it from debbie french on the 23rd of april 2014 did you read it

01:13:56 it again no you didn't did you open the attachment even possibly

01:14:03 possibly it was obviously a a request for documents

01:14:07 documents i think you came from ryden's to harley's

01:14:11 harley's and harlow's to iconic right so i was being copied in um and i took it it was i would have taken it it was something that was being asked for

01:14:22 for for ryden's files

01:14:30 do you know whether cep had ever had any input into the technical content of this but bba certification

01:14:40 were you or anybody else to your knowledge at cep aware of any testing that supported the claims in this certificate no

01:14:50 do you know did you what did you understand at the time the bba certificate covered

01:14:59 it covered various aspects fixing um cooler of the product let me be more specific did you understand that it covered the sheet

01:15:10 understand that it covered the sheet the reynabond acm sheet that came to your factory for fabrication or did it cover the product as fabricated as it left your factory

01:15:21 fabricated as it left your factory or both it it would have well i i we would have taken is it covered the product

01:15:28 product as it came into the factory in a in a sheet

01:15:31 sheet in a four mil sheet and it would also still cover the products that left the factory

01:15:38 factory were you ever concerned that the fabrication process itself might undermine the certification by the bba of the sheet as it left the rainer bond factory

01:15:49 rainer bond factory no can i ask you to look please at cep3053378

01:16:02 this is a document published by rayno bond

01:16:07 bond called a fabrication guideline step by step

01:16:10 step to a perfect cladding

01:16:14 dedicated to your success and it it's dated you can't see it here but it's dated the 19th of july 2010. are you familiar with this document

01:16:27 are you familiar with this document i don't believe i am it doesn't spring to my mind can you explain why that is

01:16:36 you are cep for present purposes a fabricator of these panels is this not a document that was familiar to you not to me personally do you know whether it was in the cep

01:16:47 do you know whether it was in the cep office in saint helens and regularly read by those on the shop floor even if you couldn't i couldn't say right well let's see how we go with it um can

01:16:58 well let's see how we go with it um can you please go to page 12.

01:17:06 this is about machining and on the right hand side

01:17:12 it says preparation for machining calculation of design dimensions closed 90 90 degree fold milling cutter with three millimeter flat surface i'll just read this out to you when

01:17:23 i'll just read this out to you when milling for a fold a thickness of three millimeters of polyethylene should be left in the bottom of the groove on top of the thickness of the aluminium c procedure in the milling chapter for a fold milled with a cutter with a

01:17:34 for a fold milled with a cutter with a flat surface of three millimeters the fold axis will be in the middle of the mill groove flat therefore 0.8 millimeters from the visible face this in the case of a closed 90 degree fold leads to an oversize of 0.8

01:17:46 fold leads to an oversize of 0.8 millimeters per angle in practice we round this off to one millimeter for ease of calculation we're making a closed fold with a milling cutter with a three millimeter flat surface the exterior finish

01:17:57 flat surface the exterior finish dimensions is increased by about one millimeter now that that's more or less comprehensible to the layman um but just in terms of of what it's

01:18:09 um but just in terms of of what it's telling you is it telling you that it's not you need to cut through one sheet of aluminium and most of the way through the polyethylene core leaving only about one point 0.3 millimeters of core remaining

01:18:22 0.3 millimeters of core remaining i believe that is the case here i wasn't involved in the fabrication side of of the of the business no and i'm asking you really to comment on this documentary that sounds reasonable in in what i'm

01:18:35 that sounds reasonable in in what i'm i've seen them aware of when you fold the panel

01:18:39 the panel yes and did you understand that this exposed all of the inside of the core the polyethylene in this case apart from the remaining 0.3 millimeters

01:18:51 i would have been aware but i i wasn't particularly aware because i didn't get involved in that but seeing this document here now i can see what you're saying but i wasn't involved in the factory side of things

01:19:02 involved in the factory side of things so i wouldn't take notice of of of that in general terms though were you aware that when a flat sheet was then was fabricated by cutting into a cassette portions of the

01:19:14 into a cassette portions of the pe core would be exposed yes yes being aware of that did it cross your mind that that would present a fire risk or fire hazard no it didn't

01:19:25 or fire hazard no it didn't did you ever query or what did you ever bring to the attention of studio e or harley or ryden or anyone you were dealing with on the grenfell project

01:19:36 dealing with on the grenfell project the fact that milling a flat sheet and exposing the pe core would present a fire risk

01:19:41 fire risk no

01:19:48 do can we go to the evidence of mr vela of arconic this is met3053190

01:19:59 of arconic this is met3053190 at page 20. and i'd like to look with you please at paragraph 68

01:20:10 he says there on the 7th of november 2013 the cstb as the french testing body informed philippe

01:20:21 philippe that's philippe volanton uh who was a colleague of mr velas that the first sbi tests had been completed on the sample sent and the rivet sample had indicated

01:20:33 sent and the rivet sample had indicated behavior equivalent to a c classification on one sample and that the test on the cassette sample had been stopped due to a flashover so the best achievable classification for that variant would be an

01:20:44 that variant would be an e using an ignitability test now just stopping there it looks from that

01:20:52 that that the cassette fix is significantly more complex significantly more combustible than a rivet fix did you know that no did anybody at arconic ever discuss the

01:21:03 did anybody at arconic ever discuss the fire performance differences between a cassette fix of this product and a face fixed or riveted no not to my knowledge

01:21:12 knowledge does anybody at arconic ever tell you about the results of the european classification testing done at cstb on rainy bond acn again not too many different configurations no no do you know that cassette had also

01:21:25 no no do you know that cassette had also failed

01:21:27 failed combustibility tests in 2004 no and did you know that in 2013 it had obtained an e under the euro classification systems no are you surprised to hear any of that i am yes i'm surprised that

01:21:39 i am yes i'm surprised that they didn't make us aware of it what have you done had they made you aware of it

01:21:45 it um well obviously we would have acted differently what would you have done uh i'm not sure i can't recall because i don't get any of the manufacturing side of it but i'm sure that somebody in cep

01:21:56 sure that somebody in cep um would have would have addressed the situation with arconic as to how to overcome that problem right now what i'm going to do next is to take a closer look at the certificate and see

01:22:07 a closer look at the certificate and see uh see how much you can tell us about it um but i take on board the fact that you were

01:22:13 were only only vaguely familiar with it is that a fair description of your overall yes so i can probably take it a bit more quickly with that in mind yes that may be a convenient moment

01:22:24 convenient moment yes i think at that point we shall have a okay a break mr blades we'll come back at uh

01:22:29 at uh 22 4 please and while you're out of the room

01:22:33 room please don't talk about your evidence or anything to do with it thank you all right thank you very much

01:22:46 all right twenty to four please thank

01:22:50 you

01:41:02 uh would you ask mr blades to come back in please

01:41:20 all right mr blades thank you ready to get keep going yes thank you yes listen mr mr blades can i then take you back to the uh bba certificate for this product the rainerbond pe55

01:41:33 for this product the rainerbond pe55 rainy bond acm panels uh at cep60282 please

01:41:47 panels uh at cep60282 please uh on the front page we can see under key factors assess the third entry down behavior in relation to fire and it says in relation to the building regulations for reaction to fire the panels may be regarded as having a class

01:41:59 panels may be regarded as having a class naught

01:42:00 naught surface in england and wales and a low-risk material in scotland c-section six

01:42:06 when you first and perhaps second time read this certificate did you note that

01:42:15 that did you note those words yes possibly and if we can look at page two of the certificate at the top under the header building regulations 2000 as they then were

01:42:26 2000 as they then were under requirement b 4 1

01:42:32 you see it says the panels are judged to meet the class naught requirement c section 6.1 to 6.6 of this certificate you see that yes did you note that at the time

01:42:43 yes did you note that at the time possibly

01:42:44 possibly now if we go to

01:42:48 section 6 of the certificate

01:42:52 we can see under 6.1

01:43:01 then this is a page five

01:43:05 under 6.1 this is under the whole heading behavior in relation to fire 6.1 a standard sample of the product with a grey stroke green duragloss 5000 coating

01:43:15 coating when tested for reaction to fire achieved a classification of bs2 d-naught in accordance with en 13501 of 2002 a fire retardant sample of the product with a gold-colored duragloss finish

01:43:27 with a gold-colored duragloss finish when tested for reaction to fire achieved the classification bs 1d naught in accordance with the m13501 2002 and then under 6.2

01:43:38 2002 and then under 6.2 a fire retardant sample of the product with a metallic grey green pvdf finish when tested in accordance with bs 4766 achieved a fire propagation index of

01:43:50 achieved a fire propagation index of naught

01:43:51 naught and when tested in accordance with bs4767 achieved a class one surface spread of flame now just pausing there did you ever read that part of the certificate do you

01:44:04 think i don't recall but i would say i've probably

01:44:10 probably skimmed through it right in 2014 would you have known or understood what those results meant no results no reading this now can you see that fr has

01:44:22 reading this now can you see that fr has a different result in fire performance from the standard sample yes

01:44:30 and in fact it's only the fire retardant sample that was tested in accordance with bs476 and 7 not the standard sample yes

01:44:45 am i right that you assumed at the time this is really any time from 2012 to 2015 that all of these panels all rainer bond panels the subject of this certificate were

01:44:57 the subject of this certificate were class nor whether they were fire retardant

01:44:59 retardant or standard yes do you see now that that's not actually what the detail is now yes yes is that a surprise to you to see that

01:45:11 uh yes

01:45:14 and now if we go to

01:45:18 well i should just show you for fairness is sake section 6.3 as a consequence of section 6.1 and 6.2 the products may be regarded as having a class naught surface in relation to the approved document b

01:45:31 in relation to the approved document b did you understand at the time the basis on which

01:45:35 on which even though a class naught test had not been undertaken in relation to the standard sample nonetheless a standard sample could be regarded as having a class naught surface

01:45:46 surface yes i would have cl i would my understanding as i believe cep's understanding was that the renault products and and ones that we'd used

01:45:57 products and and ones that we'd used uh add a class or um fire rating but the class not fire rates oh no yeah but they hadn't been tested to class naught but they they could they should be regarded as class

01:46:08 could they should be regarded as class naught

01:46:08 naught right yeah yes is that what you understood that's what we understood yes right

01:46:12 right so you understood that they hadn't actually been tested to class naught i wasn't aware they hadn't been tested to it no right i followed can we then look at section 6.4 just a

01:46:23 can we then look at section 6.4 just a bit lower down these performances may not be achieved by other colors of the product and the designations of a particular color should be confirmed by and then england and wales

01:46:33 and wales test or assessment in accordance with the proof document be appendix a clause 1.

01:46:38 1. um it's right i think that the um bba certificate um at the time it was supplied in april

01:46:49 um at the time it was supplied in april 2014

01:46:51 2014 um there it was renault bond champagne and smoked silver that were under consideration

01:46:59 yes and now they're not colors mentioned anywhere in this certificate are they i can see not no no did it occur to you at the time that the colors being considered for the tower

01:47:11 colors being considered for the tower uh namely uh champagne and and smoke silver were not covered by this certificate no why is that i

01:47:22 no why is that i would have said anything and i'll tell you i'll say that cep would have taken it that all the colors um would have been covered by the same

01:47:33 um would have been covered by the same certificate but it tells you in terms that these performances these are fire classification performances may not be achieved by other colors of

01:47:44 may not be achieved by other colors of the product and the designations of color should be confirmed by a test or assessment under approved document b did you not know that no if you'd read the certificate

01:47:55 no if you'd read the certificate you would have known it wouldn't you yes but i couldn't imagine that a renovon would test every color

01:48:06 so this to test every color to be a right you know a vast amount of testing to do plus the fact i believe that them and other

01:48:15 and other asms they can provide specific colours at customer requests the view would have been that the renault product

01:48:26 renault product in any color would be in line with this with the with the class or the or the regarded having class or so when you read 6.4

01:48:37 so when you read 6.4 what did you think it meant well having read it now it the way it reads is that it's only the colours you'd have to get confirmation that any

01:48:49 you'd have to get confirmation that any other colour than what they have highlighted in the vba it would have to be confirmed by rena bond as to their performance yes you say having read it now now you're reading what it says but at

01:49:01 now you're reading what it says but at the time when you first read this what did you think it meant i don't recall reading in great depth to pick out that point uh 6.4

01:49:12 point uh 6.4 um can i ask you to look at the transcript of ray bailey's evidence he was asked about this exact topic day 33 page 45 please and i'd like to show you lines 10

01:49:23 please and i'd like to show you lines 10 to 25

01:49:25 to 25 and then over on to page 46 down to line 11.

01:49:30 at page 45 line 10 he was shown this passage in the certificate and he is asked at line 10 did you consider whether the finish

01:49:41 whether the finish that was on the product may have made a difference to its classification answer it's strange it was a question that i asked at the time who did you ask answer believe it or not i can't recall who i asked whether it

01:49:52 i can't recall who i asked whether it was rainable direct or through cep and if it was through cep it would probably have been roy thuster and the reason for the question was the delamination we were having with the ethel bond and it was suggested

01:50:03 ethel bond and it was suggested that the paint on that may have had something to do with the delamination so when i saw grey green i thought does this apply does this only apply to this certificate and i was told no it's not on the certificate because

01:50:14 it's not on the certificate because that's the color that was tested over the page and it has to go on there and it dot and does it apply to everything else well yes otherwise there would be 200 of these certificates one for each color that they sell

01:50:27 one for each color that they sell questions so that was the answer you were told it would make no difference answer yes who was it who told you that answer i believe that came back through roy feuster

01:50:36 feuster although it's a long time i can't remember who it was but i think that's the route

01:50:40 the route it actually came back through

01:50:44 were you aware of any conversation at any time between ray bailey and roy feuster

01:50:50 feuster or anybody else at cep about clause 6.4 of the bba certificate and it only applying to the particular colors no

01:51:03 can you comment on ray bailey's recollection about such a conversation other than if it was i'm not aware of him

01:51:12 him having a conversation with anybody at cep obviously the name in there isn't my name so i didn't have a conversation with him

01:51:19 with him whether he's had a conversation with renavon

01:51:22 renavon and not mr fuster i i couldn't answer i don't know

01:51:29 did you ever ask to see any test evidence fire test evidence for colours of rain or bond panels that were being considered other than those set out in the certificate no

01:51:48 and did you uh ever have a conversation with anybody about

01:51:59 with anybody about the reason why you needed to obtain particular test evidence for particular colors other than they set out in the in the certificate no

01:52:13 was it your practice at the time in other words between 2012 or even before 2012

01:52:21 2012 to use or

01:52:25 to use or send out the bba certificate in relation to colors

01:52:30 to colors of panels that you were fabricating which were not the colors referred to in the bba certificate no so you didn't send the bba certificate only if we requested it right do you remember an

01:52:41 requested it right do you remember an occasion when you sent a bba certificate out in relation to a fabricated panel of a color different from the color set out in the um in the certificate no i don't

01:52:56 can we then turn to a different topic which is the 2015 reyno bond order which you got from harley can we start with cep60512 please

01:53:14 this is an email from mark stapley 25th of february to you attaching acm panel requirements for grenfell tower hi jeff please find attached our cladding panels our cladding panel's

01:53:27 cladding panels our cladding panel's requirements for grenfell tower please can you provide us with your most competitive price and also confirm lead times

01:53:33 times do you know why it took hardly so long to place this order given that you appear to have secured the project back in june 2014 i don't know let's look at the

01:53:44 i don't know let's look at the attachment it's cep

01:53:52 60513 this is harley's order for your supply

01:54:01 maybe we've got the wrong reference there um

01:54:06 can we go on to page

01:54:11 i'm sorry it's my fault um cep60512

01:54:20 please

01:54:25 cep60512

01:54:35 now we want the attachment for that which at the moment i'm struggling to find

01:54:39 find to find um but do you remember that the specification was renault bond and the finish was smoked silver metallic eurogloss 5000 satin

01:54:48 satin i don't recall what the color was but if that was on the order then right and there was never any specification as to whether it should be pe or fr

01:54:57 pe or fr not that i'm aware of no okay then let's go to the quotation um on the 6th of march 2015 do you remember that cep sent quotations with a revised quotation

01:55:08 sent quotations with a revised quotation a final revised quotation on the 13th of march for the supply of the acm panels do you remember that i am vaguely yes i didn't don't believe i sent the email but i could stand correct

01:55:20 sent the email but i could stand correct yes and by that stage the request for quotation and the quotation is pe no reference to fr at all

01:55:27 all yes

01:55:31 and if you go to um cep60528 you can see that ben bailey accepts your quotation this is the email

01:55:42 accepts your quotation this is the email of the 13th of march 2015 and he sends an email to rob maxwell mark stapley and you neil as it goes to neil wilson at cep neil

01:55:54 as it goes to neil wilson at cep neil please find our purchase order to cover the items below i'll be sending over a delivery schedule shortly and you can see the email to which he's responding below that where neil wilson confirms to mark

01:56:05 where neil wilson confirms to mark stapley copy to roy fuster and you the revised price for the supply fabrication of the acm panels for the above

01:56:11 above project and you can see that they're the smoke silver panels as detailed you see that yes

01:56:18 now it looks uh as if the price that was created there or confirmed there is around 300 000 pounds

01:56:29 pounds you see that yes

01:56:34 did um

01:56:38 yes now let's go to cep 60528 please at

01:56:47 page two

01:56:55 and you can see that this had come from neil wilson um do you remember given now i've shown you the entire entire email run

01:57:05 email run um whether mark stapley had asked for a discount from neil wilson i don't know you don't know

01:57:14 do you think they got a discount i honestly don't know do you remember that the price that cep had originally quoted i think we saw from the 21st of january 2014 uh letter i showed you earlier to

01:57:28 2014 uh letter i showed you earlier to mike alberston was 525 394 pounds yes correct yes but we now see from this email perhaps we should just go back to the bottom of page one the price cep

01:57:39 to the bottom of page one the price cep ended up charging was about three hundred thousand pounds you remember that you could see it i can see it correct yes can you explain that why cep was prepared to drop its quoted price by over forty percent

01:57:51 by over forty percent quotation back in january 2014 uh that for the rain screen that included um if i remember correctly from earlier

01:58:02 if i remember correctly from earlier that included insulation fire barriers um

01:58:08 rails i can't just recall exactly what was it but it was a full what i would have classed as a full system this price is purely for a fabricated panel and when did

01:58:19 fabricated panel and when did the spec the cep spec if you like change but between the quotation for the full system

01:58:27 system at least including rails and fixings to simply the supply of the fabricated panels

01:58:32 panels when harley sent the enquiry through for the request just for the panels i see so march 2015 yes i see

01:58:48 march 2015 yes i see uh and in the last paragraph of mr wilson's email he says i will confirm we will supply the remainder of the panels yet to be finalized what was um what was to be finalized

01:59:01 um what was to be finalized i don't know i'm not aware it could have been they hadn't designed a certain element of the building i see i was going to ask you was it design or was it simply quantification

01:59:12 was it simply quantification quantities it could have been either i you know i don't recall

01:59:18 and then turning to the supply itself it's right i think that cep supplied the cladding

01:59:24 cladding under a separate contract um from the contract under which it supplies the glazed window elements didn't it i believe it was two separate orders yeah two separate orders and that was to the supply of the range screen was 2015

01:59:37 the supply of the range screen was 2015 and again into 2016 in terms of the purchase and delivery right

01:59:43 right are you familiar with that i don't know what was in 2016.

01:59:54 uh so well what do you recall of the dates of delivery i wasn't even particularly involved in the delivery so what went out

02:00:06 so what went out once the program started to deliver panels the program went out from the factory

02:00:11 factory in line with their delivery requirements and as to what they were i wasn't involved right do you remember that in about april 2015 arconic

02:00:22 that in about april 2015 arconic advised that the core of the reynabond acm clouding would be black as opposed to translucent

02:00:30 no you don't know anything about that no

02:00:38 right i see so i don't need to ask any further questions about that well um mr blades i've covered a lot of ground with you today and i've come to the end of my questions

02:00:49 and i've come to the end of my questions that i've got prepared for you um it's normally the the process that i then look back at my notes and see if there are any further questions

02:00:59 questions uh or take them from elsewhere outside this room okay so we're gonna have a break now i'm gonna ask the chairman to break

02:01:04 break for the moment and uh come back again shortly okay do you have any idea how long you might need maybe ten minutes can we say fifteen we'll say fifteen forty on the same side i think so

02:01:16 forty on the same side i think so very generous um well mr blades as mr miller's explained he needs a moment just to check that he's covered all the ground and there are other people watching very intently who may have questions they

02:01:28 intently who may have questions they want

02:01:28 want to suggest should be put to you so we're going to break now until quarter past four

02:01:33 four and then we'll see whether there any more questions okay i hope not too many thank you so um you get the usher and no talking to anyone about your evidence

02:01:44 no talking to anyone about your evidence while you're out of the room okay all right thank you very much

02:01:55 all right 4 15 minutes

02:15:33 yes would you ask mr blades to come back in please

02:15:46 all right mr blades we'll see if mr millet has any further questions okay thank you yes mr chairman thank you just the one mr blades and it's this we've gone through a lot of evidence today and a lot of questions and answers about the project and your

02:15:57 and answers about the project and your role in it looking back on it now um would you have done anything differently on the project knowing now what um what you now know yes i i think the company would and i would as well yes i think we'd have looked

02:16:08 as well yes i think we'd have looked more deeply into the documents that were made available and what documents the bbs certificate and the mba in particular and probably inquired more

02:16:19 in particular and probably inquired more um as to what you know other products that was associated with the rain screen system did and how it affected the panel or not in

02:16:27 or not in in that case yes thank you very much mr chairman i have no further questions um mr blades it only remains for me to say

02:16:35 say thank you to you for coming to the inquiry today and assisting us with our investigations we're extremely grateful great thank you yes well again i'd add my thanks to those of mr millet it's been very good of you to come to

02:16:46 it's been very good of you to come to the inquiry thank you for doing so i know it's been quite a long journey for you hasn't it uh but at least you're going to be able to get home i think without too much difficulty this afternoon fingers crossed yes fingers crossed

02:16:57 crossed yes fingers crossed so thank you very much for coming it's been very helpful to have your evidence and you're now free to go great thank you very much

02:17:15 you very much thank you mr millet now that presumably is it for today that is it for the day and tomorrow we have another witness mr mcquatt

02:17:22 mcquatt um whom ms grange will be examining good thank you very much we're well 10 o'clock tomorrow then please thank you

02:17:46 you