Evidence from Mike Alveston, estimator at Harley Curtain Wall who worked on the Grenfell Tower refurbishment tender. His testimony reveals significant gaps in fire safety knowledge and product awareness during the specification process.
00:00:14 oh right
00:00:18 good morning everyone welcome to today's hearing
00:00:21 hearing today we're going to hear some more witnesses from harley yes mr minute yes mr chairman good morning we're going to hear from mr mike alveston please
00:00:33 alveston please can we please call mr alveston
00:00:46 [Music]
00:00:50 i do sincerely and truly declare and affirm that the evidence i shall give shall be the truth the whole truth and nothing about the truth thank you very much mr charleston sit
00:01:01 thank you very much mr charleston sit down and make yourself comfortable
00:01:12 down and make yourself comfortable all right yes it's stability mr robertson good morning thank you very much for attending today to give evidence to the inquiry we're extremely grateful to you um if you have any difficulty understanding any of my
00:01:24 any difficulty understanding any of my questions
00:01:24 questions or you would like me to ask them again i'll do that or i'll rephrase the question
00:01:29 question can i please also ask you to keep your voice up so that the transcriber who sits to your right can hear clearly what you're saying and i should also say that a nod or a shake of the head
00:01:40 say that a nod or a shake of the head doesn't get down onto the transcript so if the answer is yes or no please say yes or no
00:01:44 yes or no and don't nod or shake your head please yes thank you um now you've made a witness statement for the inquiry date of the 8th of november 2018 it's in a folder on the desk in front of you if you want to look at the hard
00:01:55 of you if you want to look at the hard copy or it'll be on the screen in front of you
00:01:57 of you it's har3010151 please is that your statement can you it is yes thank you could you please go to page 15
00:02:09 to page 15 is that your signature
00:02:15 uh it is yes and uh have you read this statement recently i have can you confirm that the contents are true they are true thank you have you discussed your statement or the evidence you're going to give today with anybody before coming
00:02:27 to give today with anybody before coming here today uh no i haven't thank you now i want to start some questions about your background please you began work in the construction industry i think in 1983 as a trainee quantity surveyor that's
00:02:38 as a trainee quantity surveyor that's right yes and you received a diploma in quantity surveying in 1994 i think that's right yes since that time i think you've worked as an estimator is that right that's right yes
00:02:48 yes can you provide us with a brief description of what that role entails um basically um when tender enquiries are received i go through the documents the drawings
00:03:01 do a measure of the materials needed on that project contact suppliers material suppliers to get prices and compile the quotation for submission
00:03:12 and compile the quotation for submission to the main contractor or an architect and uh that would involve also pricing jobs in order to tender for projects
00:03:23 jobs in order to tender for projects would it
00:03:24 would it that's right yes it basically means like compiling the prices from prices from other materials suppliers and would that involve consideration of things like the cost of materials the cost of fabrication cost of design
00:03:37 the cost of fabrication cost of design works
00:03:37 works that's right it's all costs really all costs just a minute i'm sorry to interrupt you so soon but my transcript is not running he's yours no it isn't and i was going to mention that if it didn't
00:03:48 to mention that if it didn't um bring it to life so i don't know what's
00:03:51 what's gone wrong would it be possible to look into that because there are a lot of other people who are seeking to follow the transcript as well
00:04:02 mr enters yours and we see your favorite um do
00:04:11 um do you have any idea where the problem may lie
00:04:17 no i didn't think yours would be a flame
00:04:22 but mr albertson will take a short technical pause i think well i'm sorry about this was troublesome but some people find it very useful to have the transcript running in front of them
00:04:33 front of them i think mr chairman the the remote access to the transcript is working in the room isn't thank you no
00:04:49 solved thank you good thank you very much indeed thank you right sorry about that
00:04:54 that we're ready to go on yes mr mr chairman thank you uh now i want to ask you some questions about that role in general uh at harley
00:05:00 at harley that you say that you began working at harley curtin wall in 2013. is that right that's right yes when in 2013.
00:05:08 2013. of october beginning of october that's right
00:05:12 right and before that you'd worked for astrolyte that's right yes did you all so you went from astrolite to harley
00:05:19 to harley um it appeared about a year when i was not working but um yeah i mean um there was no drops in between that right i see okay um and of astrolite you
00:05:30 right i see okay um and of astrolite you were working on jobs of a value between something like 50 000 pounds and 750 000 pounds that's right yes it was harley a larger organization than astrolyte um it was similar in size and i think
00:05:43 um it was similar in size and i think the big difference was that um astrolite was a more of a fabricator of materials like coach maulin whereas harley brought in all their materials
00:05:54 in all their materials so they didn't actually they only just supplied the service of actually installing the products i see would it be fair to say that after you joined harley in october 2013 you were
00:06:05 joined harley in october 2013 you were dealing predominantly with projects of a much higher value than the project you were dealing with when you were at astrology um yes i would say yes were you provided with any training by harley when you arrived
00:06:16 arrived um no were you provided with any supervision to make sure that your work on these larger projects was suitable um i only really that when i prepared a quotation it would be checked
00:06:27 quotation it would be checked by um ray bailey or mark harris before it went out i see how many projects did you work on at harley before working on grenfell tower
00:06:38 before working on grenfell tower um it's probably about two or three two or three
00:06:41 or three i see can you name those um i believe one was um great alpha house i think it was called she's in
00:06:52 she's in new golden square which is a tower block and it may be in a small um curtain wall project i can't call the name of it right uh you say great arthur house was a tower block did it exceed 18 meters in
00:07:04 a tower block did it exceed 18 meters in height
00:07:04 height um i believe it did but it wasn't um it wasn't clad it was more uh windows and uh glass cladding it wasn't actually any acm or aluminum
00:07:16 any acm or aluminum was it residential uh it was residential yes
00:07:19 yes and um was grenfell tower the largest project on which you've ever worked um possibly yes i i can't recall as you know i've worked a lot of projects at my previous jobs but it
00:07:31 projects at my previous jobs but it probably was one of the largest ones yes now before you would ordinarily provide a price on any project would you need to consider
00:07:38 consider the nbs specification for it um yes i would yes
00:07:43 would yes and also any drawings prepared by the architect that's right yes and what about employers requirements would you consider those as well um i would briefly look through those but they would be more of um jobs that mark harris or ray bailey
00:07:55 um jobs that mark harris or ray bailey would look at into right and and is the reason you looked at what you did look at um that without that information you wouldn't be able to consider what harley
00:08:06 wouldn't be able to consider what harley was required to do for that particular job that's right yes yes so is it fair to say that as an estimator you would have a you'd have to have a broad knowledge of design in order to be able to price the works accurately
00:08:18 works accurately um yes um if you've got drawings to sort of
00:08:21 of to follow to sort of get measures off of but um yes pretty much yes and in general terms would you agree that i mean tell me if this is right or wrong that the aim your aid would be to provide a quotation that was competitive
00:08:33 quotation that was competitive but also maintained as a large a profit margin for harley as possible um yes it was so when you were looking for costings would you also consider whether the job could be done for less
00:08:44 whether the job could be done for less money using alternative products um possibly but then it was really down to the mbs what was specified in that really so i would follow that right hand just just
00:08:55 follow that right hand just just following up on that answer that does that tell us that you were estimating were confined or constrained by what the nbs told you pretty much yeah that's obviously instructed otherwise
00:09:07 obviously instructed otherwise and who would normally instruct you otherwise uh that would be ray bailey or mark harris and generally what would be the reasons for instructing you otherwise um well for example on grenfell tower
00:09:19 um well for example on grenfell tower we change where we specified a different window system from the specifier which was wherever kona and we specified we quoted for uh metal technology which was
00:09:30 quoted for uh metal technology which was a
00:09:30 a sort of product that hardy has worked with extensively when doing the estimating would it be your job to make a selection of alternative products or simply to cost what you were told to
00:09:41 or simply to cost what you were told to cost just cost was how to cost right and where you did choose alternative products would that would that process extend to assessing whether the alternative project products were compliant with the building regulations and
00:09:53 building regulations and and associated guidance um i wouldn't be choosing them so i'd just be told what they were
00:09:59 they were i see
00:10:04 i see did harley at any stage provide you with any training or uh or cpd to assist you with your role no right did you yourself undertake any training yourself to
00:10:16 training yourself to get up to date with or familiar with the building regulations for example what about statutory or industry guidance no what about best practice within the facade industry no
00:10:30 does that tell us that you didn't keep abreast of general developments in the clanning industry i would
00:10:37 would yeah keep abreast of it in the news or you know in the construction news but i wouldn't actually be trained on that i see
00:10:45 so you say construction news does that refer to particular publications specialist publications um yeah that building magazine construction news things like that really but um not in great detail right would you
00:10:57 um not in great detail right would you look at those regularly or just whenever the fancy took you whenever really it wasn't really a it wasn't necessarily my job to actually keep that fully informed of that sort of information yes i see
00:11:08 information yes i see turning to your role at grenfell in your role as estimator on the grenfell tower project
00:11:13 project you considered all the elements i think that harley was being asked to subcontract and would provide a price uh for which harley was to do that work is that right that's right yes now if you can go to paragraph eight
00:11:25 now if you can go to paragraph eight please of your statement bottom of page 2 you say my involvement with the refurbishment works carried out at grenfell tower was to produce a quotation for holly
00:11:36 was to produce a quotation for holly scope of works based on the tender documents received from the potential main contractors which included an nbs specification and architects design drawings would your work be done in order to
00:11:49 would your work be done in order to tender for the project that's right yes yes and would it be fair to say that your involvement was therefore
00:11:54 therefore predominantly in the pre-contractual stage
00:11:58 stage that's right yes it was did you receive a tender package from each of the main contractors who were tendering for the works
00:12:04 works um i believe i did yes and did each of those tenderers provide the nba specifications they would have done yes i see and then you would have looked at those
00:12:12 those for each potential yeah that every mbs would be the same document anyway yes i see
00:12:20 and would the same apply to drawings which had been created by studio e at that stage again yes would be the same topic
00:12:26 topic now when you got the tender package from the main contractors well sorry let me there's a prior question do you remember how many
00:12:34 how many tender packages you looked at from different ma potential main contractors um i only remember from just seeing the names on the on my um transcript so that was probably
00:12:47 on my um transcript so that was probably the absolute amount we got but paragraph seven i think yes that's right so so did you get i think you say you did you got um a tender package from all or each
00:12:59 a tender package from all or each of uh ryden waits mulally and uh durkheim and keep mode that's right yes i see and did you provide estimates and
00:13:10 and did you provide estimates and quotations for each of those potential main contractors i believe from memory that i think weights may have pulled out before attending submission so it would have
00:13:21 attending submission so it would have been just the others right and when you got the tender package from any of these uh potential main contractors did you form an impression when looking at them about the nature of the documents you
00:13:33 about the nature of the documents you were provided with um in what ways uh well were they more or less detailed or prescriptive than normal
00:13:40 normal in your experience they were probably more um
00:13:43 more um on the higher side of being you know detailed
00:13:46 detailed and normal i see so more detail than you would normally have seen in the past that's right but nbs documents usually are quite detailed but the drawings were quite detailed i see
00:14:01 now i want to turn to look in a little bit more
00:14:05 bit more detail about your involvement pre-mbs specification can we turn the page in your statement please to page three paragraph nine and you say there my work on the project
00:14:16 my work on the project began in december 2013 when the tenders were received from a number of potential main contractors i reviewed and assessed the tender documents and built up a cost estimate based on the specification and drawings is it quite accurate to say
00:14:30 and drawings is it quite accurate to say that your work began on the project in december 2013. that's right yes when the tender inquiries were received well let's just explore that a little bit more closely can we please look first to
00:14:41 first to har four zeros five five five five this is an email uh from mark harris to thomas wreck at studio e dated the first of november
00:14:52 studio e dated the first of november 2013 and it concerned pricing as you can see down the email string
00:14:58 string for zinc cladding you see down the page and it's a series of emails and they go over this page but you can see running your eye up from the bottom of page one up
00:15:09 bottom of page one up the subject is zinc cladding um now this was
00:15:12 was as we can see from the date before the nbs specification was received by harley correct yes uh and you can see from the top email that you are copied in by mark harris in his
00:15:23 are copied in by mark harris in his reply to thomas wreck on that date first of
00:15:26 of november that's right yes was this your first involvement in the grenfell tower refurbishment project do you think
00:15:33 you think it's probably the first time i actually was aware of the projects but once i was actually involved with it right what caused you to be involved in the project from this point um whenever when we received attended documents in
00:15:45 received attended documents in december uh that wasn't quite my question let me ask it a different way how come you got involved at this point by mark harris on the 1st of november
00:15:57 by mark harris on the 1st of november 2013.
00:15:58 2013. right well knowing that grandfather was going to come out for tender in december mark um copied me into the emails
00:16:06 emails so i could put it into the you know document file was just so it was ready for um might be my job to actually price so i had the information there
00:16:17 information there already i see um shortly before this email um
00:16:25 we we know that mark harris had prepared an outline budget for studio e following a meeting that he'd attended with ray bailey and i just want to show that to you if i can it's at sea402275
00:16:41 this is dated the 18th of october 2013. just have a a look at it if you would mr alveston
00:16:47 alveston just looking at it there on the screen do you remember this document do you remember whether you had any involvement in preparing it um no i didn't you didn't um when was the
00:17:04 no i didn't you didn't um when was the first time to the best of your recollection that you saw this document um it was probably around the time of receiving the tenders it would have been late november early december
00:17:18 late november early december i i see now mark harris told the inquiry that mr alberston you drew this up uh in october 2013
00:17:30 you drew this up uh in october 2013 is that wrong um yes i believe it is i said i didn't have any involvement in grenfell tower before december right can you explain how without your help mr um well
00:17:43 how without your help mr um well let me ask it's again slightly different way do do you know from your own knowledge
00:17:48 knowledge who drew this document up if it wasn't you it was probably mark harris and ray bailey between them right you say probably how sure are you about that probably 100 right and do you know
00:18:01 probably 100 right and do you know where they would have got the figures from in respect of for example the first item down this reino bond zinc cassette rain screen probably from um cep or um alcoa
00:18:14 probably from um cep or um alcoa right okay do you know from your own knowledge
00:18:18 knowledge looking down the first page there why renault bond products were being proposed
00:18:22 proposed and no other products at that stage i don't know i'm afraid are you able to explain why although prices include insulation there's no insulation product
00:18:34 insulation product uh referred to um i think really insulation there are different products available which can be obviously used so i think there was nothing special at that time
00:18:47 i see but you are you able to identify even now what insulation product formed the basis or was included in any of these numbers where insulation is
00:18:59 any of these numbers where insulation is referred to um i don't know because you know it just says insulation so what product was actually used there right
00:19:09 if you go to page two i just want to try one thing out with you if i can you'll see under exclusions uh towards the bottom of page two four
00:19:20 uh towards the bottom of page two four entries up from the bottom no allowance for fire rated products um when you did first see this document what do you understand that to be referring to so
00:19:33 right that's probably referring to um windows and curtain wall in so there's no sort of fire rated product so that
00:19:42 so that i see um can i ask you to look at har four zeros five four six one please
00:19:58 now um this is an email date of the fourth of october from bruce zones of studio e to mark harris copy to ray bailey now you're not copied in on it um possibly because you've only just arrived
00:20:10 you've only just arrived uh at um
00:20:13 uh at um this time uh in the third paragraph done it it says the client's response to your budget
00:20:20 budget was what about aluminium we haven't had samples or cost back from ned zinc but this could be ideal if it eliminates the need for fabricated trays and is true zinc and then there's a reference to the
00:20:30 to the nedsync website um and and then it goes on to say would it be possible to come back with budget costs or
00:20:39 costs or what would the material cost uplift b for a nova composite versus a metallic fo zinc rainer bond panel i know you're not copied in on this and you had i think just arrived at um at harley at the time but
00:20:51 at harley at the time but were you made aware uh either of this email specifically or all the discussion at the time about nedsync um no i can't recall any particular discussion about it
00:21:02 discussion about it right did mr harris ever ask you to source
00:21:06 source quotes for a ned zinc panel i don't believe he did no are you do you know why the october 2013 budget that i've just shown you only
00:21:18 budget that i've just shown you only contained rayna bond options when as we can see from this document two weeks earlier the the architects had made it plain that they had wanted to investigate the ned zinc option i don't know you don't
00:21:33 do you know why the detailed budget spreadsheet dated the 18th of october so after you had arrived was drawn up without your involvement um because it was a budget stage and i
00:21:45 um because it was a budget stage and i was working on other projects that time so i couldn't actually devote my time to doing that budget and as i said i only just arrived so really mark and ray knew budgets
00:21:57 mark and ray knew budgets that they want to put out for these projects
00:22:02 can we look at h.a.r.405444 please this is an email from mark harris to thomas wreck of studio e
00:22:13 thomas wreck of studio e on the 7th of november 2013 as you can see copy to ray bailey and also to you mr alveston do you see that yes good morning thomas a response has been received
00:22:24 been received at last from kme although i'm not sure it tells us a great deal all that has been provided is a base square meter rate for panel only
00:22:33 only x works that must have taken all of 10 minutes to think about so quite why it's taken them two weeks to provide it is a mystery to me now the um the kme panel
00:22:44 now the um the kme panel that's referred to there was a proteus panel i think wasn't it that's right yes yes and in fact you can see that a little bit lower down the email
00:22:53 email do you know why it was um that mr harris was obtaining quotes from kme for the proteus sync panel rather than you as the estimator um again really just
00:23:05 as the estimator um again really just um time scales um i was tied up with actually doing other projects pricing those so mark was doing these right um why were you copied in on this email then if you
00:23:17 you copied in on this email then if you were because of my future involvement with grenfell actually doing the actual tenders i see
00:23:28 now he goes on to say under the reference to proteus hr composite quite what this finish sorry quite what finish this is based on i have no idea due to lack of information i have to say from a highly selfish
00:23:39 i have to say from a highly selfish point of view our preference would be to use acm
00:23:42 use acm it's tried and tested on many harley projects and we are confident in the cost base
00:23:48 cost base uh
00:23:52 did that uh well what impact did that view of mr harris's have on you at this time um in what way sorry well let me ask it
00:24:04 in what way sorry well let me ask it more specifically when you came eventually to to price the harley work or harley job for grenfell were you influenced in in your pricing as a result of harley's preference here as expressed for acm
00:24:17 preference here as expressed for acm um no because the nbs was specifying the proteus
00:24:23 proteus and i think there's options for acm but um i was just pricing as a specification document can we go to is sea409 please
00:24:35 here we can see that two or so weeks later on the 21st of november mark harris sends an email to bruce sohn's copy to you and ray bailey you see that yes i do and um that again
00:24:48 you see that yes i do and um that again uh relates to rayner bond pricing and we can see a little bit lower down in the email um that he says acm current standard you see at the
00:24:59 acm current standard you see at the bottom
00:25:00 bottom standard rate phase fixed on the wall 187
00:25:04 187 pound 50 per square meter etc an acm standard rate cassette on the wall 232 pound 50 per square meter
00:25:12 meter etc um had rayna bond to your knowledge provided prices for the grenfell project for you to build up these prices quoted to the client um i hadn't seen any prices but again i
00:25:23 um i hadn't seen any prices but again i was not
00:25:23 was not putting the prices together so i wouldn't have seen possibly writing them and again was the reason that you were copied into this email really in readiness
00:25:31 readiness that's right yes jumping onto the grenfell job to do the estimation work for that i see can i show you another another email same day
00:25:41 same day 5512 please
00:25:47 this is an email from debbie french to mark harris as i say of the same day 21st of november 2013 and it responds to an email i think from
00:25:58 and it responds to an email i think from you
00:26:06 if we go um
00:26:12 i'm sorry from mark from mark harris um of the 8th of november
00:26:18 so looking at mark harris's email of the 8th of november to her morning depth you see halfway down yes bruce at studio he has been talking with us about options for the cladding he asked
00:26:28 asked us for guide rates on the following and you can see there are four rayno bond finishes there how much more per square meter would these colors be over and above your standard
00:26:38 standard range now you're i think copied in on that as well which is why i asked it was it was an email to you it was actually to deborah french copy to you do you remember seeing this email at the time
00:26:49 remember seeing this email at the time um i would have done yes and again why was
00:26:53 was why were you being copied in on this was it because you were being readied for the
00:26:56 the that's right yes for the eventual mbs spec
00:26:59 spec and then we see the response from deborah french back to mark harris not copy to you highmark is disgusting sorry for the delay for the colors shown below we would offer an approx rate to our approved fabricators of 32 to 35 pounds per
00:27:12 fabricators of 32 to 35 pounds per square meter let me know if you need any other details
00:27:16 details um do you know and i know you didn't well first of all did you see this email at the time or did you discuss it with mr harris at the time do you think um i wasn't copied in it may have been something i might have been forwarded or
00:27:28 something i might have been forwarded or a printed copy may have been given over to me right does it ring a bell with you um i'm afraid i'd okay do you know why uh these quotations have been obtained by
00:27:40 these quotations have been obtained by mr harris
00:27:41 mr harris at this stage now with three quarters of the way through november and not by you as the estimator um because i was again pricing other projects at the time right
00:27:54 okay
00:27:57 so how much positive involvement did you have we've seen you receiving a number of emails
00:28:02 of emails but how much proactive involvement did you have on material choice at this stage
00:28:08 stage no involvement at all um just rather than just i just received emails copied in and said i didn't actually properly look at grenfell tower until december on what you could see
00:28:21 december on what you could see is it fair to say that even before the nbs specification was received as part of the tender package harley was already giving input into the products
00:28:29 products that should be specified particularly in relation to the rain screen um i think there are after options and different rain screen products so that's
00:28:40 different rain screen products so that's what they're responding to right was it your impression that harley and particularly mr harris was aiming to get reyno bond acm
00:28:53 to get reyno bond acm included in the nbs specification um i don't think so no
00:29:00 were you aware that an fr core was available
00:29:03 available for rayner bond acm products no you won't
00:29:11 can we go back to your statement paragraph nine please page three and i want to look a little bit more closely with you please at the obtaining of quotes uh by you
00:29:22 the obtaining of quotes uh by you and you say a paragraph nine my work on the project began in december in 2013 when the tenders were received from a number of potential main contractors i reviewed
00:29:34 potential main contractors i reviewed and assessed the tender documents and built up a cost estimate based on the specification and drawings we looked at that earlier on would you agree that you needed to ensure that the information was appropriately
00:29:47 the information was appropriately extracted from the drawings and the specification in order to be able to price the project reliably that's right yes yes and you would need to
00:29:56 to raise queries regarding specific elements or to clarify uh anything if there was anything that you didn't understand that's right yes and if if that was so
00:30:07 that's right yes and if if that was so who would you go to who would be your your first port of call um i'd say probably ray bailey or uh daniel tell jones being a technical manager
00:30:18 manager i see daniel anchored jones was he involved
00:30:22 involved on this project by the time you came to uh be
00:30:25 uh be involved more closely in december 2013. i believe he had a obviously a brief input into it but not in in a full-on role at that stage right i see
00:30:39 now we can see that you began asking for quotations or seeking quotations for various products in the nbs specification on the 11th of december 2013. can you look at sig 50139
00:30:52 can you look at sig 50139 please this is an email from you mr albiston to matthew irving uh and he is sig isn't he that's right yes he was um
00:31:05 that's right yes he was um i'm so sorry i think in fact he is at kme
00:31:08 kme actually sorry i've put that to you wrong he's kia kme is that right um that's the yeah protest collagen isn't it yes yes um and was this email
00:31:20 yes yes um and was this email the first um email sent out by the first message sent out by you from harley in order to see quotations for could be looking at the date yes right
00:31:35 now if mr harris had already obtained a budget price from kme as we've seen he did
00:31:41 did on or before the 7th of november 2013 we saw that email earlier on do you know why you were sending this request again um because we had um the drawings
00:31:52 um because we had um the drawings and an nbs specification now and i just thought i'd put it out there again just to make sure that it was all as the drawing is unspecified i see and indeed in the second paragraph you say
00:32:03 indeed in the second paragraph you say previously you've given budget prices to mark harris in order for you to provide a firm quotation for the rain screen what do you need from us i've attached elevation drawings on the nbs specification for now and we see that you do attach those documents
00:32:15 you do attach those documents so was this you seeking a firm quotation as opposed to really an estimate that's right yes i see
00:32:25 see uh and did you need the um did you need to to get t kme to see the technical data
00:32:35 data in order to be able to to um get a firm quote
00:32:39 quote from them that's right yes right and that meant did it that you yourself needed to understand the technical data um not myself no no right
00:32:52 now we can see you approaching kme here directly
00:32:56 directly um for a quotation rather than going via a fabricator um is that is that right first of all um i believe kme
00:33:06 kme actually fabricated as well so the prices cladding will come straight from them
00:33:10 them i see i was going to ask you um when look when considering the proteus hr panel
00:33:17 hr panel is that something that actually needed fabrication um i believe it did yes it was a similar sort of
00:33:23 sort of cladding panel i see but i think you're telling us that kme supplied them ready fabricated that's right yes let's see and did they've to supply them ready fabricated in in both cassette and face fixed form
00:33:34 fixed form um i can't recall right um if we look at the quotation for the proteus panel this is at sig
00:33:46 for the proteus panel this is at sig 6042 please
00:33:57 um this is
00:34:02 dated the 14th of january 2014 we can see that from two places at the top of the page there
00:34:13 two places at the top of the page there and it would expire on the 14th of february 2014 when it comes to harley you're the customer contract reference you see that uh yes and if we go to page two of this
00:34:26 uh yes and if we go to page two of this document
00:34:27 document if you look at the bottom right hand corner
00:34:31 corner you can see that the total price in pounds
00:34:35 pounds for essentially a zinc system proteus was 546 264 pounds
00:34:46 264 pounds was that the price that you used to generate
00:34:50 generate harley's quotation based or so far as it was based on the proteus panels um i can't recall without actually seeing my pricing documents but um if i could just see the
00:35:01 documents but um if i could just see the previous page again yes go back to page one please if we could
00:35:08 you can see the build up here this um scope of supply zinc spandrel cladding and zinc column crown panels yeah and it's all proteus hr panels flat
00:35:19 yeah and it's all proteus hr panels flat we just move up slightly sorry move up slightly with that yeah so that's it that's fine right um i'm pretty sure it would have been based on that really i may have um
00:35:30 been based on that really i may have um just re-measured the areas but it would have been based on these uh rates it would have been okay um just just just to be clear if you go to ryd five four zeroes two six zero seven
00:35:52 this is the quotation that harley eventually gave ryden
00:36:09 now we can see it's 29th of january 2014. so
00:36:13 2014. so exactly halfway between the date of issue and the date of expiry of the kme quotation if we go to um uh page five i think it is
00:36:34 um sorry page nine we go to page nine on that uh
00:36:39 that uh in that document yes we can see the cos there's a cost summary there and we can see how you've quoted or what you've created for the zinc column cladding and crown
00:36:51 for the zinc column cladding and crown zinc rain screen cladding to spangled panels on aluminium range screen cladding generally three figures there in the middle of that cost summary um for the zinc column cladding and crown 551
00:37:02 crown 551 odd for zinc range screen cladding to spandrel panels 707 odd and aluminium rain screen clouding generally 109 odd thousand pounds each respectively
00:37:13 odd thousand pounds each respectively and that gives us a total on our calculations of about 1.2 million pounds um so we go from 546 thousand pounds quoted by kme to to
00:37:25 thousand pounds quoted by kme to to 1.2 million or thousand pounds quoted in total
00:37:29 total uh to ryden can you explain in in rough terms
00:37:33 terms um how you got from 546 odd thousand to 1.2 million in total um well basically the cladding quote was for the panels um
00:37:45 quote was for the panels um and sort of brackets but then we just had on to installation some cladding rails as well and also the installation of the product as well right plus the um overheads
00:37:56 as well right plus the um overheads a markup from harley yes on there so that would account for the extra cost i see so your price of 1.2 million odd in total for that was an on-the-wall price that's right yes right whereas the
00:38:08 that's right yes right whereas the quotation
00:38:10 quotation from kme was what they call x works but already fabricated that's right yes but just for the materials that's right now can we go back to your witness statement please page 4 paragraph 16
00:38:22 statement please page 4 paragraph 16 you say there decisions on specification changes were made by studio e and communicated to harley via ryden my instructions to provide costings for such
00:38:33 such changes would come to me from ray bailey or mark harris although ultimately we would provide alternative costings for whatever material the architects wanted to use provided that it was something that was
00:38:46 provided that it was something that was achievable and fit for the intended purpose you can see those words there that you use would you play any part in assessing whether the products were fit for their intended purpose no i
00:38:57 were fit for their intended purpose no i wouldn't
00:38:58 wouldn't did anyone at harley have that particular role um again it would have been probably ray bailey or daniel achtel jones in a technical role if mark harris or ray bailey told you to price
00:39:10 ray bailey told you to price a product with a particu to price a particular product um did you understand that uh that had been checked in order to make sure that it was suitable
00:39:21 make sure that it was suitable um yes i would have done who did you think would do that checking um either ray bailey uh offshore or daniel
00:39:29 daniel intel jones i see so did your would you was it your expectation that anything in the nbs specification would be checked by ray bailey or daniel anchored jones for its suitability
00:39:41 jones for its suitability for application on this project that's right yes
00:39:44 right yes right and by fit for intended purpose can you explain what you mean um really just
00:39:52 just it was actually a suitable for its use on
00:39:55 on a building
00:39:59 did that include fitness from a fire safety perspective um if it was that if that was the purpose for it but again if you know if it was actually for
00:40:11 again if you know if it was actually for that purpose it would obviously have to be
00:40:13 be fit for that purpose when you say if it was for that purpose can you just um if um like it was a fire exit on a building
00:40:20 building and it needed to be a fire rated screen a curtain wall screen it had to be fit for that purpose
00:40:28 was it your expectation that any particular product for for application on the project would be checked by by either ray bailey
00:40:40 would be checked by by either ray bailey or daniel anthony that's right yes it would be for fire safety um
00:40:45 safety um i suppose so yes every part of it
00:40:51 now paragraph 31 of your statement if we can go to that please uh you'll see on page eight there that you say
00:41:01 you say um i have been an estimator for over 20 years pricing projects involving curtain walling windows and cladding although i had not used these particular products before
00:41:12 particular products before i had previously worked on projects where other acm products such as a leuco bond were used when i worked for astrolyte they used a fabricator called booth murray limited and they mainly worked with the leuco
00:41:23 and they mainly worked with the leuco bond
00:41:25 bond now i think you're referring there are you or are you to rain a bond acm with a pe core when you say
00:41:32 you say these particular products um
00:41:37 that's right yes
00:41:40 are you also referring when you say these particular products to the kme proteus hr yes as well yes so you've never used that before either no i see
00:41:53 that before either no i see um what about celetex rs 5000 insulation um again i think i actually say in my statement of 33 that i can't remember if i actually worked the project that was used but again
00:42:06 the project that was used but again a tender stage or estimated stage installation is fairly generic so it would have been decided after a contract was won and actually materials ordered very well well we'll
00:42:18 materials ordered very well well we'll come back to rs 5000 shortly i think um you say that as you do here that you had worked with a luco bond products on those previous projects where you had done so were they a leukobond acm
00:42:30 done so were they a leukobond acm panels with a pe core or another kind of core
00:42:34 core um i can't recall them right were you aware
00:42:37 aware from the involvement you'd had previously with a luco bond the luca bond acm panels came with a net and fr at fire retardant core no you weren't what about a mineral core
00:42:50 no you weren't what about a mineral core were you aware that the luca bond panels came no i i just i just thought that so luca was just one um core and that was it
00:43:00 one core yeah and that was it and that was yeah it wasn't a choice between fire rated or
00:43:05 rated or or non-fire rated as such right so just pe is a that's right yeah as a single product now if as you say these products that you've identified were new to you
00:43:17 identified were new to you did it occur to you that it was even more important to familiarize yourself with them and particularly their their performance in a fire no because it wasn't my role at the company to actually
00:43:27 actually um check those items right and just again to be absolutely crystal clear whose role at the time did you think
00:43:35 you think that was it would have been again ray bailey or daniel tell jones
00:43:43 i want to ask you some questions about the regulatory requirements but these may not take long in general were you yourself familiar with schedule one to the building
00:43:54 with schedule one to the building regulations no right would it follow that you weren't therefore familiar with part b fire safety that's right
00:44:04 how do you receive any general training on fire safety within clad buildings either before or during your time at harley no
00:44:20 and do i take it also that you were not familiar with the cwct guidance uh or technical notes published by the cwct
00:44:29 cwct and similarly the bca the building control alliance yeah right um then let's turn to the built the nbs specification if you go please to sig 50139
00:44:42 if you go please to sig 50139 please
00:44:48 we can see an email from you on the 11th of december to matthew irving at kme we've looked at that before
00:45:00 and we can see in it that you forwarded to him a number of documents and one of those if we look at your email
00:45:08 email in the second paragraph and at the attachments is the nbs specification now the version then in circulation was dated the 29th of november 2013 and i don't need to go
00:45:19 of november 2013 and i don't need to go to that
00:45:20 to that but do you remember when you first saw the nbs specification prior to sending this email to mr irving um it probably would have been when we received a tender inquiries in december
00:45:33 received a tender inquiries in december i see do you remember who you received it from
00:45:39 it from um it would have been the main contractors
00:45:44 etc i see
00:45:48 so when you say the nbs specification which you're sending on to kme you don't know which particular which particular main contractor had supplied that one to you they were all
00:45:59 supplied that one to you they were all the same
00:46:00 the same no i was just extracted extracted that part of the nbs and sent it to kme i see now let's look at the nbs specification this is the one dated the 29th of november 2013.
00:46:12 november 2013. so this would have been the one current at the time of this email it's sea 50153 please
00:46:30 and we can see uh um if you look at the middle of page two that this is the version dated the 29th of november as i say you
00:46:42 dated the 29th of november as i say you see that
00:46:43 see that and if we go then on to page 64
00:46:49 we can see on 64 clause 120 types of rain screen cladding and it sets out the specification which required pricing for proteus panels supplied by kme
00:47:01 panels supplied by kme architectural solutions do you see that yes i do yeah now if we go down to page or backup page 63
00:47:09 63 clause 11 under h92 rain screen clouding information to be provided with with tender
00:47:16 tender uh you can see that it says in addition to the cladding specified in the below clauses 120 and 123 submit comparative supply and install costs per square meter
00:47:27 costs per square meter of the whole clouding system for the following alternative materials and then we can see what the alternatives are as rayno bond in three finishes aluko bond spectra
00:47:38 in three finishes aluko bond spectra sakura
00:47:39 sakura and zinc called zinc uh do you see that yeah and then in it that's in addition to the proteus panel which we saw specified at clause 120.
00:47:50 which we saw specified at clause 120. now if we go to page 63 at the top of the stay on page 63 at the top of that page you can see that it says um that one of
00:48:02 you can see that it says um that one of the matters to be read with the preliminaries in the second bullet point was that was that the manufacturers noted within the specification were indicative and then it says this
00:48:14 were indicative and then it says this and may be substituted with similar or equal alternatives when you got this document in december 2013
00:48:22 2013 did you note what it said there that the manufacturers may be substituted with similar or equal alternatives um i possibly did that was that's like a fairly standard
00:48:34 that's like a fairly standard clause in mbs documents
00:48:38 i see and what did you understand by the word indicative um it's like a guide sort of product that the architect wants to use and when it says the manufacturers noted
00:48:52 and when it says the manufacturers noted within the specification are indicative did you think that applied only to the kme proteus hr rain screen or also to the alternative the rhino bond
00:49:04 alternative the rhino bond uh the aluko bond and the zinc um i don't think i had an opinion on that at that time really i see looking at the phrase similar or equal
00:49:17 looking at the phrase similar or equal what did you understand by that that normally means that the product's going to be
00:49:22 to be of similar performance similar performance
00:49:33 so does that mean that where a product was to be substituted
00:49:42 uh it had to be of of similar or equal performance standard to what was stipulated that's right yes and where it says substituted
00:49:54 and where it says substituted what did you understand could be substituted for what sorry in what way well did you understand that uh the for example the raynaud identified
00:50:06 the for example the raynaud identified in clause 11 could be substituted for the proteus provided it was a similar or or equal performance standard um not as such because the process was the
00:50:18 not as such because the process was the main product and the renault bond was the
00:50:21 the alternative so it would be the other way around really right so to what products would the qualification to your understanding similar or equal apply to um probably from the phrasing
00:50:33 apply to um probably from the phrasing in the documents for any product really i think
00:50:35 i think so any product not within this specification at all sorry any product completely outside this specification um no it's well it's referring to the products in the
00:50:46 it's referring to the products in the specification and obviously there are um you know could be substituted by other manufacturers right can i just see if i can get your
00:50:57 can i just see if i can get your understanding of the comparative performances um as between um the zinc proteus on the one hand and the alternative rhino bond on the other and looking at the expression um may be
00:51:08 and looking at the expression um may be substituted with similar or equal alternatives did you formally view at the time as as to whether rayna bond would perform the same
00:51:16 same as uh the um kme proteus hr no i i can't comment on that because saying i've got no technical um training of those products right
00:51:27 um training of those products right in respect of all of these rain screen materials that you were being asked to cost
00:51:31 cost did you take any steps to ensure that they were suitable for the ext use in an external wall construction above 18 meters in height uh no other than just um passing on the
00:51:42 uh no other than just um passing on the document to either the manufacturers or ray bailey and danny rexell jones to actually look at a technical point of view right and again does the same apply in relation to the insulation material that's specified
00:51:54 material that's specified elsewhere in this dock that's right the whole document basically yes did you discuss these materials with anybody when costing them
00:52:04 um possibly yes do you know who um i probably either mark harris ray bailey or daniel right do you have a specific recollection of that or no
00:52:15 recollection of that or no because you know it happens on most projects so i see can you go to paragraph 22 of your statement please on page six
00:52:30 uh i think you say uh there beyond beyond that i'm unable to comment
00:52:37 comment as to the manufacturer of either rayna bond acm or celetex because my role was not a technical or design role and so i wasn't required to know the full details of the manufacture or composition of these products
00:52:49 or composition of these products um does that tell us that you weren't able to assess whether they were fit for purpose
00:52:53 purpose at least in terms of fire safety that's right because okay it wasn't my role at the company to do those checks okay um can we go back then to clause 11 of the nbs specification that we looked
00:53:04 of the nbs specification that we looked at a moment ago sca 50163 153 at page 63.
00:53:12 this is the nbs specification of the 29th of november again not the final version that came out in january that we've been looking at um most of the time in this inquiry and we can see here on on this page under clause 11
00:53:23 clause 11 uh information to be provided with tender that you were required to provide a price for brainerd metallic standard and non-standard what did you understand uh was the difference between standard
00:53:37 uh was the difference between standard and non-standard um it's basically the finish of the um of the metallic finish i understand non-standard i think they have a range of colors which are standard um
00:53:50 which are standard um colors and then you get non-standard colors which are sometimes costs for costs on those um can i ask you to look at the bba certificate for rayna bond panels this is at har450934
00:54:08 please
00:54:12 um this is the bba certificate number zero eight slash four five one zero
00:54:19 zero dated first issue 14th of january 2008. um did you see this document when considering how to quote for these panels the rayna bond acm panels
00:54:30 these panels the rayna bond acm panels uh no
00:54:31 uh no you didn't did you ever see this document during your work on the grenfell tower project um i believe it was uh provided by alcoa um on requests from the architects
00:54:43 alcoa um on requests from the architects later on that again it would just be i was just copied in on an email and the document sent on to the architect yes that's the 23rd of april 2014 um
00:54:54 that's the 23rd of april 2014 um sent by debbie french to mark harris does that ring a bell with you uh yes he does right and you say you were copied in on that did you read it when you when you received it um no you didn't what did you did what did you
00:55:06 you didn't what did you did what did you do with it i was just copied into it so i didn't actually i just filed it and said mark harris sent it on i believe or it made me myself i can't remember why did you think you were being copied in on it um because again i was the
00:55:18 in on it um because again i was the point of contact for the price in the grenfell tower so i was copied in all documents at that point did it occur to you that one of the reasons why you copied in on it is that
00:55:29 reasons why you copied in on it is that you should read it um no because again my role wasn't that the company was in a technical role so i would not have to read that document what was the point of it being sent to you if you weren't to read it again because it was a just keeping me in the loop basically
00:55:42 just keeping me in the loop basically and i
00:55:43 and i um i kept a file of all correspondence on the project
00:55:57 now i know you didn't read this document at the time as you tell us um perhaps there's not a lot of points showing this to you but the general question is were you aware even
00:56:10 were you aware even at april 2014 when this document was sent to you in copy that there were two different reynabond acm
00:56:20 acm products one with a standard pe core and one with an fr or fire retardant core no i wasn't aware right
00:56:31 right can we then look at sca402275 please
00:56:40 um this is a document we looked at earlier on this morning it was the 18th of october outlined budget
00:56:48 budget for the external envelope budget costs cassette rain screen
00:56:59 budget costs cassette rain screen at this stage you can see the cassette is being
00:57:02 is being quoted for uh do you know why cassette was stipulated at this stage
00:57:10 stage rather than face fixed or rather budgeted for rather than
00:57:15 um
00:57:19 if you go to page two we looked at the exclusion for fire rated products and you said that was for
00:57:31 rated products and you said that was for curtain walling and windows
00:57:36 did you understand from your involvement that had been an exclusion from the budget for all fire rated products in what we got what were fire rated
00:57:48 in what we got what were fire rated products in the external wall construction um i wasn't aware now you weren't okay nobody ever told you to budget or cost on the basis that fire
00:58:00 to budget or cost on the basis that fire rated products for example for the rain screen or for the insulation were not to be um not to be watched
00:58:17 can i then go to cep cep50267 and i'm going to ask you some questions about um your seeking of a quotation from cep
00:58:30 seeking of a quotation from cep um this is an email of the 21st of january 2014 from jeff blades of cep to you copy to mark harris and he provides a quote in which he provides a quotation
00:58:41 provides a quotation for the fabrication of the clanning panels
00:58:45 panels and he attaches a quote okay um uh it looks from our documents that you only approach cep for a quotation for fabrication is that right um i believe so yes
00:58:57 right um i believe so yes why is that um because cep was the fabricator early used for um the rain screen prep trading product products for rain screen cladding products is
00:59:08 for rain screen cladding products is that all rain screen product cladding products regardless of whether it was rainer bond or a luca box um i think i believe it was probably a luca bond verb
00:59:17 bond verb maybe some other clothing products right so cep was was the fabricator of choice for harley is that what you're saying that's right for those products yes for those products you say for those
00:59:28 for those products you say for those products
00:59:30 products i believe they obviously there's products they didn't actually fabricate so they couldn't actually provide prices for those
00:59:36 for those would it be normal only to approach one fabricator on a cladding job um no particularly no so why on this one um i think at that point and i was
00:59:48 um i think at that point and i was new to the company and um you rely on being told who the companies that the uh you know your employer uses so i was told that cp
00:59:59 employer uses so i was told that cp would provide a price for these so i went to i see who told you that uh would have been either ray ray bailey or mark harris okay
01:00:10 do they say why you should only you should approach cep and no really just you know you get a list of
01:00:16 of supplies that hardly used um over the years and that's the company you went to
01:00:24 and you didn't question that no because most times even in my previous employment you know you build up a um level of trust with certain suppliers they deliver on time
01:00:36 they deliver on time you know they're trustworthy in terms of you know providing a product so you just really go with those the ones you can um you know you can just basically did cep only fabricate acm panels
01:00:48 fabricate acm panels in terms of cladding or in terms of the rain screen um i'm sorry yeah when it comes to rain screen panels did cep only fabricate acm or did they do other patterns either the other pro panels might be a
01:01:00 either the other pro panels might be a sort of um kind of it might be a hpl panel i think it is but
01:01:07 it is but it's really hdm was the one we obviously got quoted on this hpl being high pressure laminate yes yes right yes and so far as zinc is concerned i think you said earlier that that that would be manufactured by kme itself that's right so they wouldn't
01:01:19 itself that's right so they wouldn't need to go to cep um i don't believe they actually did that product anyway so right so would it be right that by only approaching cep for a quote you were essentially providing a price which assumed the job
01:01:31 providing a price which assumed the job was going to be acm the rain screen for grenfell tower was
01:01:35 was going to be acm um no because the acm was a
01:01:39 was a alternative to the proteus at that point right can we look at the email chain under which you requested a quote it's cep 50267 please
01:01:51 quote it's cep 50267 please and i'd like to start at page three cep50267
01:01:55 cep50267 and if we can go down to page three we can see
01:01:58 can see that at the bottom of the chain there's an email from jeff blades to you dated 20th of december 2013 [Music]
01:02:07 [Music] morning mike following my telephone conversation with mark harris yesterday could you please forward your window and curtain wall schedule with regards the rain screen overclouding we are to offer our system
01:02:18 overclouding we are to offer our system based on a cassette tray and face fixed acm
01:02:21 acm i.e rayno bond to this could you please forward elevation drawings and any other information you feel is relevant well you were made aware of that telephone conversation on the 19th of december
01:02:33 december other than just seeing it in the email there i don't recall it do you know what mr harris said to mr blades no i don't to your knowledge did mark harris instruct jeff blades to offer a system
01:02:44 instruct jeff blades to offer a system as he says based on a cassette tray and face fixed acm ie raino bond i don't know ivan reading it in the email there did you instruct mr blaze to offer such a system um
01:02:57 a system um no because i think probably an email further on i just you just sort of scroll up
01:03:04 scroll up right um but basically he says uh cassette tray and face fix so i think that's what he offered do you know because you received this at the at the time do you know why mark harris had told
01:03:16 do you know why mark harris had told jeff blades that the acm to be used was rhinobond and not any of the other alternatives set out in the nbs specification um i don't know did it
01:03:27 nbs specification um i don't know did it strike you as odd that he had uh narrowed down the quotation that he was seeking only to that product and not
01:03:35 and not for example to include aluco bond as an alternative um not really no at that point i was saying new to the company so i think i met jeff blades i
01:03:45 blades i didn't actually know what products cp fabricated so it wouldn't have struck me as unusual um when you read the words we are to offer our system
01:03:57 offer our system did that strike you as a reference to an instruction essentially from harley to mr blades that his the quotation that was being sought was
01:04:08 sought was very specific and restricted to cassette and face fixed ie rainer bond um not really no no
01:04:20 um not really no no can we then scroll up and look at pages two and three side by side and if we look at the bottom of page two and at the top of page three
01:04:32 we've got the bottom of page two is we can see that it's an email from you dated the 6th of january 2014 back to jeff blades and over the top of page three
01:04:45 uh will you say
01:04:49 sorry i can't see i know there it is top of page three hi jeff do you see that now yes um you say hi jeff further to our telephone conversation this morning please find attached
01:05:01 please find attached schedules and nbs specifications for the curtain wall and windows i have also included the nbs specification for the rain screen and the elevation drawings i will also send you a link for further drawings in dropbox if you have any
01:05:13 drawings in dropbox if you have any further queries then please contact me
01:05:21 did you have a conversation with jeff blades on the morning of the 6th of january 2014 as appears um from this email i obviously did yeah it said an email right do you remember
01:05:32 it said an email right do you remember that conversation no i don't do you remember whether you told him or do you have a recollection specifically of telling him what to quote for in respect of the rain screen
01:05:43 respect of the rain screen no i don't remember again he said previously what he was going to be uh quoting for so i didn't really raise set with him right
01:05:52 now you'd send him the entire nbs specification and the elevation drawings and we've already seen that the nbs specification requested quotes for four
01:06:03 requested quotes for four rain screen products both proteus reyna bond luca bond and court zinc by vm zinc
01:06:11 vm zinc um so were you expecting him to provide quotations in respect of all of those or at least reynabonda luca bond and court zinc and the stage probably well whatever he
01:06:24 and the stage probably well whatever he could quote for really if he's uh he quoted from the local um sorry a renault bond it would have been that if we go then to the quote of the 21st of january 2014 which is what he responds to after a
01:06:36 which is what he responds to after a chaser from you which i think we could see
01:06:38 see on page two can we go to that uh it's uh cep50268
01:06:48 this is the formal quotation from cep addressed to you at harley dated the 21st of january 2014 and if we look at page one uh
01:06:59 and if we look at page one uh it says uh in the first paragraph thank you for your inquiry ref the above project
01:07:05 project which is grenfell tower and we have pleasure in confirming our quotation for the design fabrication and supply only of aluminium windows and rain screen over cladding is laid out below and then in the fifth paragraph down
01:07:17 and then in the fifth paragraph down rain screen over clatting do you see that
01:07:19 that i don't yes he says panels are to be manufactured utilizing four millimeter rayna bond acm
01:07:26 i just want to focus on the words are to be manufactured do you know why despite the fact that you had sent mr blades the whole of the nbs specification which had the four
01:07:38 specification which had the four products
01:07:40 products proteus and then the three alternatives in it yeah claus 11 as we've seen do you know why jeff blade only provided a quote for the rayner bond acm product i assume it's because that's the only product he
01:07:52 it's because that's the only product he actually
01:07:52 actually fabricated in terms of acm range screen is it not because he had been told to do so we as we've seen from the 20th of december email we are too um i don't know if he was
01:08:04 we are too um i don't know if he was told that or not i just assume that's what he was that's his product he fabricates you see it says here panels are to be manufactured utilizing four millimeter radar bond acm when you saw this did it not strike he
01:08:17 when you saw this did it not strike he was odd
01:08:18 was odd uh that he was under the impression that uh he was only to quote four four millimeter rhino bond acm and not any of the other products referred to in the nbs specification no it didn't
01:08:29 in the nbs specification no it didn't strike me strange it didn't strike you strange
01:08:31 strange why didn't it strike you as strange um because that's obviously the product eve only fabricates that that type of acm
01:08:44 so did you understand that he was he was limiting himself to quoting for a rainer bond acm because that was the only product he meant he fabricated that's right yes
01:08:57 did anyone tell you that um i can't remember if they did or not but that's that's that's my memory of it basically that's what the product he fabricated right did you have a
01:09:08 fabricated right did you have a just a conversation with him about his capability to fabricate other uh products it's possible such as who can't recall that
01:09:19 can't recall that right
01:09:25 but i i think we know that cep also fabricated a leuco bond did it not cross your mind that when he was restricting himself to rayna bond um that was over
01:09:37 to rayna bond um that was over restrictive and you should ask him but could you please quote for a luco bond as well um well i've you've just told me now he just quote he quotes for luca bonds that's
01:09:48 quote he quotes for luca bonds that's probably that first time i knew that anyway i see or at that time i wouldn't have known that all right
01:10:00 it looks from his wording and obviously we can ask him about this but panels are to be manufactured it looks from that as if a final decision had been made already to use rayna bond acm as the fabricated
01:10:14 to use rayna bond acm as the fabricated panels
01:10:16 panels as opposed to a luca bond or any other panels requiring fabrication does that accord with your recollection that a final decision had been made no no at that stage it was as an
01:10:27 no at that stage it was as an alternative to the process anyway it did were you asked to obtain quotations for
01:10:34 for a leukobond um i can't recall them fred
01:10:40 what about vm zinc um it's possible again i can't recall right
01:10:48 given that you didn't approach any fabricators other than cep as you've told us and given that you only asked cep or at least led cep to understand
01:11:00 cep or at least led cep to understand that it was only to quote for rayner bond does it follow that in fact there were no quotations sought from fabricators for a leukobond again i can't recall you can't recall
01:11:12 again i can't recall you can't recall and would the same apply to the vm zinc as well
01:11:14 as well that's right yes
01:11:31 from your own recollection is it fair to say that harley was pushing the rainerbond product and was seeking quotations based on its proposed use of grenfell no i don't
01:11:42 proposed use of grenfell no i don't think that at all can i ask you to look at cep 50273
01:11:58 now this is an email from mark harris to jeff blades of the 29th of january um
01:12:06 copied to you
01:12:10 and he says hi jeff just to let you know the main contractor tender return date has been further extended by another week 14th of feb so glad we pulled out all the stops to get a price back
01:12:21 get a price back were you working against a tight time scale to prepare the tender for submission um not particularly it was just about usual for
01:12:29 usual for those projects right did the
01:12:33 did you feel under pressure to get the quotations out as soon as possible um no more unusual really no no more than usual but nonetheless some degree of pressure yeah as usual yeah now let's look at harley's quotation itself please
01:12:45 harley's quotation itself please a little bit more closely um this is at har3010151 [Applause]
01:12:58 [Applause] uh this is your statement of paragraph 13 and you say here paragraph 13 on page four
01:13:12 you say a quotation
01:13:16 paragraph 13. a quotation was produced by myself and agreed with ray bailey and mark harris the quotation uh was sent to all potential main contractors ryden were ultimately awarded the contract and i assisted mark harris with
01:13:28 contract and i assisted mark harris with providing additional costings and cost analysis you see that by further you want to say by further cost analysis i mean breaking down the costs given in the quotation in further detail so that ryden could
01:13:39 in further detail so that ryden could see more clearly this could could see more detail of exactly what the costs given in the quotation consisted of but can i ask you to turn back to harley's quotation
01:13:50 we'll turn to it it's ryd402606
01:14:07 ryd402606 this is an email from you to katie bachelier of the 29th of january just a copy to simon lawrence say same day and you attach the quotation to that for grenfell
01:14:21 was this quotation in the same form as that which you provided to the other main contractors bidding for this project um yes exactly the same document i see do you know what process you've gone through to reach the final figures
01:14:32 through to reach the final figures in the tender in what way sorry it well what process that had you gone through in order to reach the final figures
01:14:39 figures in your in the criticism i would have measured all the elements on the project um obtained prices or used historic prices compiled the tender sum and controlled
01:14:51 compiled the tender sum and controlled the document as well and checked it with ray and mark harris thought it actually went out right now let's look at the quotation itself it's at ryd402607
01:15:11 itself it's at ryd402607 there it is we saw it earlier um and we'll come back to it in a bit more detail now um if we go to page two
01:15:21 this is a letter signed by you to ryden same day 29th of january 2014 and it says there that the offer in the second paragraph you see includes the for the design supply and
01:15:33 includes the for the design supply and fix of a complete envelope package all in accordance with the client's requirement documents issued by yourselves now we know that part of harley's tender as we can see was for the design of the
01:15:44 as we can see was for the design of the facade yes that's right yes if we go to page nine we can uh on in this document i think we've already seen part of this because i showed you this earlier this
01:15:55 because i showed you this earlier this morning in the middle we can see that the total figure for the project or so far as harley was concerned as potential subcontractor was
01:16:06 concerned as potential subcontractor was 3.2 odd million pounds yes that's right yes and that was on the basis of
01:16:10 basis of zinc rain screen cladding yes that's right yes yes um and that was before any alternatives by way of product or any value engineering was applied wasn't it that's right yes um looking at
01:16:22 wasn't it that's right yes um looking at the
01:16:23 the the rates there do you know where they came from
01:16:27 came from all the rates um they would have come from um
01:16:30 from um prices obtained from material suppliers and um
01:16:34 and um and built up uh internally at harley i see and you know where the measurements had come from uh for myself i see so you've done the measurements based on what the drawings those are the drawings yes i see
01:16:45 drawings yes i see and if you look at page 10 the next page alternatives and options at the top of the page there you can see that halfway down that page there's rain screen cladding there's a
01:16:56 there's rain screen cladding there's a section
01:16:57 section uh and we can see that there are uh various prices set out for as quotation and then alternatives
01:17:09 for as quotation and then alternatives um were the products that you set out there derived from the nbs specification do you think um yes the proteus
01:17:20 proteus and the cgl cladding was and obviously the the raider bomber the new yorker bond as well as the alternatives and we can see that you provided prices for both reynold bond and the leukobond rain screen cladding
01:17:31 cladding that's right with different prices for face fixed and cassette although they're identical 240 pounds per square meter for cassette and 195 pounds per square meter for four face fixed um where did you take
01:17:44 four face fixed um where did you take those prices from um from memory probably the renault would have been from
01:17:49 from jeff blade's um costs right and luca bond because the luca bond and renault bond are very similar in cost we would have put the same cost in there at that stage because there's no
01:18:00 at that stage because there's no um finishes specified at that point so we just put the same cost in i see just as a guide so you didn't actually ask a luca bond to provide a specific number no i see so so the luca bond prices
01:18:12 no i see so so the luca bond prices there
01:18:13 there were an assumption were they that's it based on historic costs harley right do you know or did you know the time who was going to fabricate the aluko bond cassettes um no
01:18:36 now we can see that there's no vm zinc product included in these options although it was listed as we've seen as one of the alternatives in the nbs specification do you know why that is um i don't recall i'm afraid was there
01:18:48 um i don't recall i'm afraid was there any do you recall any discussion with mr harris or mr bailey ray bailey about excluding the vm zinc as an alternative cost or price for the rain screen
01:18:59 rain screen i'm afraid i can't remember any discussion on it
01:19:06 do you remember whether it was our harley's aim to make sure that rayner bond acm was chosen out of all the options
01:19:12 options provided in the nbs spec um no i don't recall these discussions on there
01:19:19 there right i mean we've seen from your evidence this morning and from other evidence that the only fabricator was a who was approached was cep that that uh the only quotation from them was for reyna bond ac
01:19:30 them was for reyna bond ac m the only figures that are quoted for the alternative are based on reyna bonder's firm figures he hadn't approached the luca bond and hadn't got any prices for a liquor bond in the light of that would you
01:19:42 bond in the light of that would you accept that it is fair to say that the use of rainer bond panels was a foregone conclusion no because at that stage they were just an alternative to the proteus zinc so it wasn't they were just
01:19:54 zinc so it wasn't they were just um they were just there as a alternative system
01:19:59 system mr chairman is it a convenient moment for a break yes i think it is switzerland thank you very much mr oldest and we're going to have a break now okay we'll come back at 20 to 12 please
01:20:10 12 please while you're out of the room please don't talk to anyone about your evidence or anything related to it okay all right okay you'd like to go the usher she'll look after you
01:20:34 right 2012 thank you
01:35:51 i'll just go straight to value engineering yes would you ask mr alvison to come back in please thank you
01:36:16 all right ready to carry on thank you very good thank you yes mr mr anderson can i ask you to turn to your statement please a paragraph 35 and before i do that that's before that
01:36:28 and before i do that that's before that comes up on the screen i've been asked just to revisit something i put to you earlier which was the 18th of october budget and the authorship of that document
01:36:41 and the authorship of that document that's right yes 18th of october 2013. now i just want to put accurately to you uh what
01:36:47 uh what mr harris said about that on day 34 at page
01:36:51 page 65 line 23 and his evidence to the inquiry was that it was more likely to have been the estimator i believe and i then said what mike alveston and
01:37:03 and i then said what mike alveston and then at page 66 line one yes that's correct and then he goes on to say line five it's more likely to have been him so i couldn't absolutely
01:37:14 have been him so i couldn't absolutely categorically say it wasn't me but looking at that document that's more likely to have been him and then i
01:37:21 then i and then he says when i asked him did you have any discussions with mike alberston or any input into its creation and he says i'm sure there were discussions yeah now just looking at his evidence is what
01:37:33 now just looking at his evidence is what he says they're correct or is your recollection different no it's different i believe and i believe probably it's just the passage of time excuse me um that he probably just
01:37:45 excuse me um that he probably just doesn't remember when she started the company say it was beginning of october so at that point i was working on other projects i wasn't involved with those budgets so i think it's just really the you know it's just memory from that time
01:37:57 it's just memory from that time but obviously further on probably a year on i would have been involved in those sort of those documents yes i see can we then go to your witness statement to paragraph 35 on page 8 that i've just referred you to
01:38:16 i've just referred you to and you say here any changes to materials had to be agreed by the architect although some changes in materials were proposed or suggested by harley
01:38:27 proposed or suggested by harley these were nevertheless ultimately subject to approval by the architects who were the architects that you're referring to here studio e and once ryden was appointed
01:38:38 studio e and once ryden was appointed the main contractor did you anticipate a discussion about materials between harley and studio e in the event of any change
01:38:46 change which would lead to the ultimate approval by studio e um i believe they would have been discussed at that point yes how did you come to that understanding um because it's usual on
01:38:58 um because it's usual on these sort of projects where there are changes that you have to go through the architect
01:39:04 architect that's you say usual on these sorts of projects did you have any specific conversation with anybody within harley about what you should do where there was to be a change um sorry in what way and what did
01:39:17 um sorry in what way and what did anybody tell you did anybody add harley that is tell you that where there was to be a change in materials you should have or there should be a discussion with studio e or with writing
01:39:28 studio e or with writing no it's just industry practice really that any changes would be agreed by the architects did you in fact in the end ever have a discussion with
01:39:39 in the end ever have a discussion with studio e whereby they approved a change in material um no because after the contract was won by ryden's appointee and pointed harley i didn't
01:39:50 appointee and pointed harley i didn't actually have any discussions with studio e or writings on product changes i see do you know whether any anybody else at harley had
01:40:01 else at harley had discussions with studio e whereby they approved a change in materials i don't know they did not i see
01:40:14 can we look at ryd403315 please this is an email from mark harris to steve blake
01:40:25 steve blake of the 14th of march 2014 which attached proposed value engineering options and you can see that it was copied to you as well as to simon lawrence and
01:40:36 you as well as to simon lawrence and katy
01:40:37 katy perchelier and let's look at it it says please find
01:40:48 uh the first round of ve options attached for grenfell tower this has been presented to show the value of the compliant package with ve cost options below
01:40:59 cost options below the cladding is shown with four options for the main zinc areas and the risk of stating the obvious the cladding savings are not cumulative only one of the four options can be selected now looking at the date mr albiston this
01:41:10 now looking at the date mr albiston this was after
01:41:12 was after harley's quotation had been submitted wasn't it that's right yes some time after actually about six weeks or so yes yeah were you involved in producing the value engineering options that mr
01:41:24 the value engineering options that mr harris was referring to i was yes you were do you know who asked you to do that within harley or externally well let's start with harley um it would be mark harris right did
01:41:36 it would be mark harris right did anybody externally ask you to do it um not directly it would have been uh through mark it would have been riders who would have asked that i follow now um we'll go to the attachment in just a moment
01:41:47 attachment in just a moment before we do sticking with the email um in the
01:41:51 in the fourth paragraph down mark harris says we have included options for both faith for both face fixed as used at camden and secret fixed cassette but again would comment that the architect was
01:42:02 would comment that the architect was none too keen on face fix when discussed i would be surprised if they would accept rayner bond with the standard paint finish however we have included it as one of the options on the basis that a significant cost saving can be made
01:42:13 significant cost saving can be made although the attached state standard silver finish any of the standard acm colors would be available at the same rate hope this is sufficient for your meeting on monday
01:42:24 on monday did you yourself explore any value engineering options in respect of a zinc product mr albiston um i don't believe i did you know why is that um i wasn't asked to
01:42:35 why is that um i wasn't asked to right did it occur to you to take that up with mark harris and say well we should be looking at alternative costings for zinc um no because it wasn't um wasn't my
01:42:47 no because it wasn't um wasn't my position to actually make no suggestions right did you yourself think about going back to kme and asking for a price reduction um no i didn't
01:43:01 i take it from that answer that there was no discussion between you and mark harris or anybody else at harley about going back to kme in austin actually again i can't recall it we again we may have actually contacted kme
01:43:12 again we may have actually contacted kme about a price reduction but i can't recall
01:43:15 recall that conversation
01:43:19 at the time that acn was raised as an alternative option to zinc what assessment did you or to your knowledge anybody else at harley done to determine whether acm um
01:43:30 done to determine whether acm um complied with adb approved document b as the choice of material to provide the surface of the external wall on the building sorry can you repeat a question yes when
01:43:41 sorry can you repeat a question yes when acm was raised as an alternative to zinc did you do any assessment or did anybody hardly do any assessment for compliance with approved document b right i didn't do any assessments um
01:43:52 right i didn't do any assessments um it's possible that somebody else in a technical position would have done that right can we then look at the attached document
01:43:59 document which is at ryd403316 please
01:44:08 do you know who who created this document uh that was myself that was you um now all the proposed cladding savings which are set out here refer only to renault bond products
01:44:20 renault bond products there's no aluco bond and no vm zinc for example
01:44:23 example why was that um again i would have been told to do that by
01:44:30 by either ray bailly or mark harris that was a product we were just using on those alternatives when you say told to do that do you mean told only to look for reductions on rainerborn products
01:44:43 reductions on rainerborn products i think because at that point there was discussions with ronabond over the particular finishes like the zinc type of finish so that was the route was going down at that point
01:44:54 that point right and does that explain why there's nothing there's you didn't go back to a luco bond to say can we actually have a a a a a good price or a price that was better than what rayner bond we're
01:45:06 better than what rayner bond we're offering you right yes
01:45:10 do you remember where you got these revised prices from
01:45:14 um probably it would have it would have read up on it it would have been from um uh cp you say prop do you remember that
01:45:26 uh cp you say prop do you remember that um not exactly but that would have been the basis of those those costs i see so these costs would have included fabrication uh that's right yes yes now if you
01:45:40 uh that's right yes yes now if you go to your statement please um
01:45:46 you see that uh you say there are paragraph 31 page eight uh i've been an estimator over 20 years and we saw that earlier and we also saw this
01:45:58 and we also saw this reference earlier to boov murray is it fair to say that you were familiar with the luca bond and had used that successfully um with other companies on other buildings um yes yes did you raise any concerns with
01:46:11 yes yes did you raise any concerns with mark harris about um not using a luco bond or not seeking quotations for a luca bond as an alternative no
01:46:21 and why is that um i didn't think it was an issue
01:46:30 did you have a feel for whether when looking at value engineering a luca bond might provide even more favorable
01:46:40 favorable reductions than rhino bond it's possible but um from my experience luca bond and renabon are very similar um cost
01:46:50 um cost so there was not much to choose between them really now you said a moment ago that you might have got these revised prices from re from cep do you remember
01:47:01 from cep do you remember having a discussion with mr blades or anybody else at cep about these revised prices
01:47:07 prices um no because the i think the um the value engineering options were based on
01:47:13 on um actual measures of all the cladding areas so it would have been based on his original
01:47:18 original um quotation he provided right do you know what accounts for the reduction in each case if it helps we can look back at the document perhaps we should do that
01:47:30 document perhaps we should do that if you look at ryd403316 we'll just focus on for example um the 576
01:47:44 um the 576 000 pound odd reduction in relation to aluminium face fixed rayner bond aluminium face fix do you know
01:47:52 know how it was that that figure was arrived at
01:47:55 at um yes it would be comparing the cost for the processing cladding against the renault bond and the difference in those
01:48:06 uh yes and um given that this is value engineering can you account for the increase in saving or difference between the two
01:48:17 so it's a saving between which sorry but between
01:48:21 between the uh zinc the proteus zinc as you said a moment ago which was the comparator and the proteus was a more expensive product than the renault bond so that's the difference
01:48:33 the difference in uh in cost yes it's i'm sorry maybe we're
01:48:36 we're across purposes i'm asking you uh how these precise figures were arrived at do you know
01:48:45 you know as i said before it was based on um a cost for
01:48:48 cost for the proteus as we used in the compliant bid
01:48:52 bid and then reworked uh using runner bond prices
01:48:56 prices and that would have been the saving because uh runner bombs are a more you know a less expensive product than proteus there was a difference in cost
01:49:07 were these prices you were offering not reductions on the alt on the prices that were contained
01:49:14 contained in the highly quote january because the compliant bids of the um three million is as the uh quotation the savings are sort of more accurate
01:49:28 the savings are sort of more accurate figures because in the quotation it was just square meter rates which didn't really sort of mean a lot in this in the scheme of the job so these are more based on actual areas
01:49:39 these are more based on actual areas so these figures weren't actually given before as the options i see so
01:49:46 right um well let's just um
01:49:51 look at that we can't find any trace of any document in which you went back to cep
01:49:56 cep and asked them about revised prices before quoting these to ryden is that because you didn't need to go back to cep that's right they were simple comparators between what had previously been quoted and the zinc
01:50:08 and the zinc yes yes i follow can we go to ryd three four
01:50:13 four four zeroes four nine one six ryd four zeros
01:50:16 zeros four nine one six please this is an email from simon lawrence for the 22nd of may
01:50:21 of may 2014 to claire williams at the tmo and he says in the first paragraph good news hot off the press is that what we believe to be a more expensive acm cladding finish natural aluminium isn't going to be the
01:50:33 natural aluminium isn't going to be the manufacturers have confirmed that they are willing to supply it at the same price as the other ranges previously discussed
01:50:39 discussed therefore the savings stayed the same as per the attached 293 368 for cassette or 376
01:50:44 376 175 face fixed
01:50:47 were you aware that the ryden had not passed on to the tmo their client the full savings from using acm that you were offering no we're not aware can we look at
01:50:58 no we're not aware can we look at h.a.r.50931 please
01:51:03 this is an email a copy to you 22nd of april 2014 from mark harris to simon lawrence simon she says by far the easiest way to
01:51:14 simon she says by far the easiest way to respond is to meet afford a copy of bruce's email to deb french at alcoa the reynabond lady for comment regarding cost i'll do that straight away and then in the third paragraph he says i would prefer to try to stick with reina bond if poss
01:51:26 reina bond if poss nothing wrong with the luca bond of course but i'm not sure we can manage the cost so well if we go that route but do you know why mr harris wanted to stick with rayna bond no i don't
01:51:37 can you comment on his
01:51:41 professed reason there which is managing the cost
01:51:44 the cost um no i don't did you share his concerns that you saw in this email regarding ryden's ability to manage or rather harley's ability to manage the costs if the client selected the luca
01:51:56 costs if the client selected the luca bond product um i can't recall any sort of um anything on that obviously i saw the emails it was copied to me but i don't recall anything across my mind when i saw that now can
01:52:07 across my mind when i saw that now can we turn to cep3051297
01:52:13 this is an email from mark harris to jeff blades just two days later
01:52:20 24th of april 2014 copy to you and ray bailey
01:52:25 bailey morning jeff just to place a note on record regarding the conversations between debbie french and myself with regard to grenfell tower and he goes on to say the rates from alcoa
01:52:35 alcoa specific to the grenfell project for brushed looking effects colors as stated below
01:52:41 below the colors shown as offering maximum saving against the original natural zinc will all be supplied at the same rate as alcohol standard color range i stated this is a special for grenfell tower
01:52:51 tower and is it fair to say that the value engineering exercise that you were involved in as we've seen from the ve options
01:52:58 options spreadsheet the 14th of march focused on obtaining an appropriate raino bond product from debra french at alcoa
01:53:06 alcoa that's right yes did to the best of your recollection did harley and you particularly only consider the rainer bond product
01:53:18 only consider the rainer bond product for re for value engineering options um i think at that point because of discussions with varena bond regarding finishes
01:53:26 finishes it was very much going down the renault route at that point so i think it was sort of focuses on that because he started going down the elk and sort of the
01:53:33 the alum route his other finishes and it just puts a whole lot more different you know finishes into the mix really right so you say very much going down the rainer bond route does that really
01:53:45 the rainer bond route does that really tell us that by this stage uh although perhaps no formal decision had been made so far as harley was concerned it was going to be rainer bond it probably was yes yeah can i ask you to look at
01:53:56 to look at um har405692 this is an email two days earlier actually
01:54:05 actually uh 22nd of april 2014 from mark harris to deborah french
01:54:12 and he he makes the same point in the third paragraph he says i i need some guidance
01:54:18 guidance regarding prices we are trying to stick with what i would call standard rain upon rates and i believe we spoke about certain colors and then if you look at the bottom of that he says could if you could bond in terms of which fall within the standard
01:54:30 terms of which fall within the standard price range which fall outside rather than creating actual cost figures i can then forward it straight on to all concerned
01:54:35 concerned again you were copied in on this email um did you understand that had the email contained the actual prices mr harris would not have wanted to forward that straight on that's right yes and that's because
01:54:46 that's right yes and that's because harley wouldn't want the architect to know the actual prices that's right that's actually usual anyway right is that because the cost saving or uplift um inherent in your prices was something that you didn't want the architect to
01:54:58 that you didn't want the architect to know
01:54:59 know um it's really just obviously the build up of cost because the architect can't just buy the product from a supplier he has to obviously come through a fabricator and they install it so obviously we've got add-on costs on that
01:55:11 obviously we've got add-on costs on that as well
01:55:13 as well [Applause]
01:55:16 yes
01:55:25 now can i ask you about uh the kme proteus product if we can go to ryd404085 please
01:55:38 this is an email to you from you to simon lawrence of the 30th of april 2014
01:55:50 do you see that it's from you to simon lawrence 30th of april 2014 and you attach the proteus hr brochure among other documents the ned zinc as
01:56:03 among other documents the ned zinc as well
01:56:03 well and you say hi simon please find attached the following information from kme
01:56:08 kme for the proteus rain screen cladding and you attached uh a typical draft guarantee the new sales brochure and a cwct
01:56:17 cwct test document which in fact i think was on weather tightness wasn't it it probably was yes yes well we can see from your description of it right we can look at the document if you like but it says um it's it's about wind
01:56:28 like but it says um it's it's about wind speed and serviceability and fatigue assessments demonstrates a 50-year lifespan do you know
01:56:35 know what had prompted you to send this information and material to mr lawrence um it would have been a request from ryden's
01:56:44 ryden's simon lawrence i see was the proteus product
01:56:48 product the zinc hr proteus product still being considered at this stage 30th of april 2014. i believe it must have been yes because it would have been here as you've seen the documents it would
01:56:59 as you've seen the documents it would have been when you saw this email were you surprised that the proteus hr marine screen panel product was still a candidate after all the value engineering you've done on rayna bond acm
01:57:11 you've done on rayna bond acm no because that was still the architect's preferred cladding system at that point it was still running in the mbs right and i'd like to look next to the costing error
01:57:22 costing error that there was in the acm and uh its impact on the choice of face fixed or cassette if any it's right to think that that you made a cost error in harley's quotation for grenfell tower didn't you that's right yes now let's look at um
01:57:34 that's right yes now let's look at um ryd four zeros nine five nine six please this is an email chain between you and zach
01:57:43 zach maynard at ryden
01:57:49 and if page one if we start page one at the very bottom of page one we can see your email to zach maynard
01:58:00 we can see your email to zach maynard of the 23rd of june 2014 uh and you you say hi zach i've been through my cost error on grenfell tower and he closed the following to explain
01:58:11 and he closed the following to explain what happened and then there's some details set out there which i don't need to go to
01:58:14 to go to quite yet you you say my cost error is it fair to say that it was you who made the mistake when initially costing the project
01:58:21 project that's right yes okay and then you go on to explain if we look at the bottom of page one and over to page two how the cost
01:58:32 saving error came about if you look at page
01:58:35 page two i think the most of the detail is there
01:58:40 there and i don't want to spend time reading reading it all out to you but in essence your original cost had omitted um items uh for face fix
01:58:52 items uh for face fix including flashings smoke stops and supports for the crown whereas the zinc cost did include those that's right that's right yes and the same in relation to the cassette
01:59:03 same in relation to the cassette but the difference was a bit less that's right yes
01:59:07 right yes um is it right then that in summary because of your error the saving that harley were able to offer ryden for face fixed reyno bond pe panels was only 376
01:59:19 fixed reyno bond pe panels was only 376 000
01:59:19 000 odd pounds as opposed to 576 thousand dollars um yeah that's it figures yeah yeah and the same
01:59:27 same and in respect of cassette fix panels the new reduced savings would be 259 000 instead of 419 000. yes now let's go on a bit in time can we go to ryd409823 please
01:59:46 this is an email of the 25th of june 2014.
01:59:52 from you to mr maynard copy to mark harris
01:59:56 harris grenfell tower price build-up and and you attached a cost-saving error breakdown
02:00:02 breakdown and you can say as in the second paragraph as you see the shortfall of both face fixed and cassette is 200 380 pounds but as explained in my previous email the cost used for cassette was more
02:00:14 the cost used for cassette was more accurate than the face fix which was a bit low this would result in an additional shortfall to harley of around 37
02:00:21 around 37 850 pounds if face fix was selected is it fair to say that the cost of error was minimized by about 40 000 pounds if the cassette
02:00:32 by about 40 000 pounds if the cassette fixing was chosen um i believe that's occasionally about 160 000 pounds instead of about two hundred thousand yes so we didn't follow from that as far as
02:00:43 so we didn't follow from that as far as you were concerned from harley's financial perspective uh a cassette fix was the better option um
02:00:49 um it would have been yes yes can we look then at the attachment to this email the cost saving error breakdown it's at har3014785
02:01:12 and here it is 25th of june 2014. did you create this document uh yes i did you did
02:01:20 we can see in the first box at the top of the page that you set out the original savings for acm face fixed as originally calculated and given to ryden
02:01:31 calculated and given to ryden yes uh and compared with zinc so you could see the saving for acm there's the 576 figure and in the second box i think you set
02:01:42 and in the second box i think you set out the actual savings so we're comparing the the saving given with the
02:01:47 with the the actual is that is that right i should have got that right so we can see from that you'd omitted the additional supports of the head of columns
02:01:55 columns flashings and copings and vertical and horizontal smoke stops and for someone with your experience in pricing and estimating um would you agree
02:02:06 agree that this was quite a basic error um yes i would and at the time i was horrified by it can you explain how you came to make it um i can't because if i knew how i made
02:02:17 um i can't because if i knew how i made it i would have actually wouldn't have made it in the first place but um unfortunately it was just a case of missing
02:02:22 missing too many items and not adding back what you actually need to be added back in right you can't explain how you came to make that basic error um well as i said i added back items it
02:02:35 um well as i said i added back items it shouldn't have been added back in or vice versa
02:02:40 can we look at har 40s 5775 please
02:02:55 this is an email from mark harris to ray bailey copy to you 23rd of may 2014 and if we scroll down to the second email down it's you can see there's an
02:03:06 email down it's you can see there's an email from bruce sones of the 23rd of may also same day earlier in the day 2014 to claire williams and simon lawrence
02:03:18 lawrence copied to mark harris so we can see mark harris essentially copying that onto you and then making a comment so scrolling down we can see what mr sohn says he says under
02:03:31 says he says under the um blue heading picasa web album um which is actually a reference uh he says the brushed aluminium natural aluminium brushed h9103s looks
02:03:43 natural aluminium brushed h9103s looks very good
02:03:45 very good if the the appeal relies on the deep shadow joints and i think the vertical joints channel rainwater runoff thereby keeping the faces cleaner the natural aluminium
02:03:57 the faces cleaner the natural aluminium seems to have picked up less dirt than the painted panels it is very reflective i don't think it will get glare comments and then it goes on to say if we send
02:04:08 and then it goes on to say if we send the planners to see the example they will jump on the fact that it's clean of all face fixings with rivets mostly concealed in return faces to the joints i know you've assembled cost options to do this but i've prepared a
02:04:19 options to do this but i've prepared a sketch
02:04:19 sketch attached showing how the acm could be assembled as cassettes or perhaps as a hybrid
02:04:23 hybrid which i'm less convinced by i think the brushed aluminium cassette will be accepted by planners now scrolling up we can see that mr harris
02:04:32 harris sends this to claire williams and simon lawrence but copies in mark harris and uh you you see that yes uh and um
02:04:43 yes uh and um mark harris sends it to ray bailey and and you get this um and the comment is interesting comments from the architect this might help with our current predicament exclamation mark i've not
02:04:54 predicament exclamation mark i've not spoken with simon about cost issues as yet and i think i will keep quiet and see
02:04:58 see how this plays itself out and by our current predicament did you understand when you saw this email as you did
02:05:06 you did um that mr harris was referring to your cost estimating that's right yes i see is it fair to say that the cost error therefore came to light within harley in around may 2014
02:05:17 around may 2014 uh that's right yes and do you remember how
02:05:20 how or when you first discovered it um i can't literally when but um it was myself i discovered it i just i was just looking at costs again just for my own purposes and
02:05:31 purposes and i discovered the error were you hoping or was hardly hoping that the error would be minimized by a cassette choice without having to discuss it with ryden um it possibly was the
02:05:44 um it possibly was the opinion of harley but again i wasn't really involved in discussions on that
02:05:51 and again that's because for harley the optimum cost savings would be from choosing cassette and not face fixed as i think that's right yes that is that is that why mark harris wanted to see how it played out to your understanding i think it was yes
02:06:02 to your understanding i think it was yes yes can we go to hir 50944 please
02:06:11 this is an email of the 25th of april from mark harris to you
02:06:24 in which or under which he forwards to you an email the same day a little earlier that day from simon lawrence to uh himself to him
02:06:36 to uh himself to him mark harris and kai fabianka the studio he copied to bruce zone's afternoon kai that should say it says kia but that should say kai and he says in the second main paragraph
02:06:53 um in order to design a system that achieves the client's requested budget you see that he says we need to be making everything face fix and from flat sheet where possible
02:07:05 and from flat sheet where possible just just just on that is it right that by this stage therefore 25th of april 2014 you knew that ryden wanted face fixed for the client's budget
02:07:17 client's budget um it's possible again reading that i i can't actually remember reading that that email but that would have been the case right
02:07:28 case right okay um
02:07:33 but once you've discovered your costing error as he did in about may i think as he told us there was then was this right a desire within harley to to have cassette in its own financial
02:07:44 to have cassette in its own financial interests um possibly yes yes uh now if we look at ryd four zeros five four two five
02:07:59 this is an email from mark harris to simon lawrence 30th of may 2014 copy to you as well as ray bailey and daniel acquittal jones on the subject is grenfell rivet matched
02:08:11 on the subject is grenfell rivet matched to natural brushed alley rayno bond and
02:08:20 in the second line or second paragraph he says that said as discussed on site our preference would be for cassette for lots of reasons do you know what the lots of reasons
02:08:32 do you know what the lots of reasons were that he was referring to it possibly would have been because of the uh the cost difference yes were there any others
02:08:43 do you remember whether any consideration was given either by you or anybody else in harley that you knew of as to how the different fixings might impact or affect fire safety or fire performance
02:08:58 were you aware at this time or indeed at any other time when working on this project that grenfe that um
02:09:06 that um renault pe55 in a cassette format was significantly more combustible compared with a riveted format no i didn't know did do you know whether any bonnet harley had ever had a
02:09:17 any bonnet harley had ever had a discussion about the relative far performance of each of these different fixing systems i don't know you don't did you yourself make any investigations into how the fixing method would affect
02:09:28 into how the fixing method would affect fire performance no i didn't have any concerns about it can we then turn to the subject of insulation and go back briefly to the nbs specifications
02:09:39 specifications uh now this is the final version of january 2014 that i want to look at so not the version we were looking at before it doesn't make any difference for this for this purpose sea 50169 please
02:09:51 sea 50169 please and i'd ask you to go to page 73 this is page 73 clause 776 and we can see here under thermal insulation that what's
02:10:03 insulation that what's specified was material rigid pir manufacturer celitex and the product reference fr 5000
02:10:15 and the product reference fr 5000 aluminium foil faced both sides
02:10:21 is it right to say that the installation of the insulation was part of harley's scope of works that's right yes and would it follow from that you were required to provide a quotation which
02:10:32 required to provide a quotation which included a price for the purchase and installation in installation of the insulation product that's right yes now we don't see any alternatives set out of the nvs specification for thermal insulation that's right isn't it
02:10:45 thermal insulation that's right isn't it and i'd ask you to accept that um can we then turn to the quotation that you prepared in january 2014 at ryd4026
02:10:56 ryd4026 please
02:11:05 and there it is it's a lengthy document but if we go to page 9 again which we looked at before which is the cost build up and the total uh we don't see any uh
02:11:17 uh we don't see any uh reference in there to the product specified for insulation or indeed anywhere in this document no that's in the um descriptions for the rain screen cladding in the document so
02:11:29 rain screen cladding in the document so further back in the document the installation is referred to yes we can we can see that if we go back a little bit but my question is there's no reference to any particular product no no no and if we look at um
02:11:42 no no no and if we look at um indeed at page eight the page before
02:11:47 and look under excluded items we looked at that before um or other we looked at that elsewhere in a different document but here we see items excluded from our quotation
02:11:59 we see items excluded from our quotation [Music]
02:12:05 and uh
02:12:08 we can see that insulation it's a slight negative here but installation isn't included from the items excluded if you see what i mean
02:12:19 items excluded if you see what i mean um does that tell us that it must have been positively part of your package that's right yes what was the product that was going to be used as contemplated by this quotation
02:12:30 contemplated by this quotation um it was going to be either celetex or a similar insulation product
02:12:38 i see did you yourself consider whether the selatex specified the fr 5000 was a suitable product
02:12:46 product for use at grenfell tower no because that was my um my role at the company to check those right did you have any conversations with anyone at harley about whether fr 5000 was suitable for grenfell as i
02:12:58 fr 5000 was suitable for grenfell as i said before the mbs document would have been looked at by
02:13:02 by daniel or ray bailey
02:13:09 i think you told us earlier that you didn't go to suppliers and get specific quotations or figures for specific from from specific manufacturers particularly celetex no right is there a reason why you
02:13:20 no right is there a reason why you didn't go to celetex and ask for a price for fr5000 um because we had historic prices for installation used on previous projects it was like an item that you can
02:13:31 item that you can you know could be fairly confident in the cost base for so you can use those on most projects but but would it not have been sensible rather than just being
02:13:40 being fairly confident in the cost base just to send them an email and ask them for a price
02:13:44 price um just not usual really it's just you know usual practice just you know if we know prices unless you've got particular items like the range screen cladding all the windows curtain walling which are the larger
02:13:55 curtain walling which are the larger items on the project that they're obviously more cost-based but you know installation is very much a square meter rate using a building so we're very confident in those prices
02:14:06 confident in those prices right given that you had not or as far as you
02:14:09 as you remember you couldn't remember whether you'd worked on a project where celetex was used
02:14:14 was used or not would it not have been sensible to
02:14:17 to ask celetex for a specific price rather than remember no because i said before um hardly had used that product before so i'll just rely on on their cost um information i was given right
02:14:30 cost um information i was given right you say harley had used that product before
02:14:34 before do you know on what projects harley had used
02:14:38 used fr 5000 before i don't know afraid how have you come to understand that harley had used fr 5000 on previous projects
02:14:46 projects um i can't call exactly but again it would have just been through discussions with
02:14:50 with you know ray or mark do you remember specifically or even if not specifically generally actually being told that fr 5000 had been used by harley on
02:15:01 that fr 5000 had been used by harley on previous projects um i can't recall that i'm afraid i can't recall but that was the impression you say that's the impression you were given from discussions that's right it wasn't it wasn't the case of when the envious
02:15:10 envious document looked like this is unusual this is something we haven't used before so you know it was just something that we were happy to use do you know whether anyone had hardly
02:15:21 do you know whether anyone had hardly ever made any specific inquiries about whether fr 5000 would be suitable to use a grenfell i don't know now um we we know that the r the
02:15:35 we we know that the r the rs 5000 celotex product was launched on the 5th of august 2014 were you aware of its uh of that launch of that product at that time
02:15:46 of that product at that time were you aware that it was then specified for use on the grenfell tower project
02:15:51 project shortly after that launch um i wasn't aware
02:15:54 aware no well you were aware that there had been a change of material from the fr 5000
02:15:59 5000 as specified in the nba specification to rs 5000 in around august 2014 no do you know whether
02:16:10 no do you know whether that change was the subject of discussion within harley no sorry what what time the year was that 2014 august august so i think by that point i was actually not on the project anymore anyway so
02:16:21 anyway so right okay uh well let's let's look at a document can you go to cel 4000 sorry four zeros nine nine seven
02:16:32 4000 sorry four zeros nine nine seven three please
02:16:37 now this is a document created by celetex
02:16:44 called a sales force entry in a database um are you familiar with this document or with this kind of document um no i've never seen it before there's
02:16:55 um no i've never seen it before there's no reason why you should be given an it's an internal celetex document but let's look at page two of it
02:17:05 now this is a a list of meetings and communications between celetex is salesforce
02:17:17 celetex is salesforce or others at celetex and those at harley
02:17:24 if you look at the entry for the 24th of november 2014 up just below halfway down you'll see that there are a number of items
02:17:35 that there are a number of items for that date the dates on the right-hand corner right hand column and you can see that the second item down against the date of the 24th of november
02:17:46 of november is a meeting uh with you on the subject of premier house yes do you remember that meeting no
02:18:04 you don't um can we go to five cel four five two then please
02:18:24 five cel four five two then please these are uh meeting notes taken by jonathan room of celetex
02:18:32 celetex after a meeting that he'd had at harley's offices on the 24th of november and if you quickly flip to page two you can see that mr room has put an email signature on that document
02:18:45 email signature on that document now if we just go back to page one please um you can see a heading uh
02:18:59 you can see a heading mic under chartwell house it's been cut off at the bottom of the screen yeah um but um if we can just scroll up a little there we can see chartwell house
02:19:11 there we can see chartwell house south end tender windows and cladding refurb dt zo client architect mike was that you um i believe it was yes right
02:19:20 right okay uh and we can see uh under grenfell tower m.c ryden's misspelt and various other things
02:19:32 things um but do you remember a meeting with celetex in relation to chartwell house on the 24th of november um i
02:19:43 um i don't remember although i'm looking at that um
02:19:47 that um i think it's actually not referring to me at charlevoix i think it's one below okay it's um premier house is the project
02:19:54 project right you're you're interpreting this yeah as i am done a better job yes i understand um so you're talking to okay fine so this and that would be consistent with the salesforce entry we looked at earlier where you were having
02:20:05 earlier where you were having a a meeting or discussion with jonathan room at celetex on the subject of premier inn on the 24th of november 2014. do you remember what was discussed with mr room
02:20:16 with mr room oh that means i'm afraid um
02:20:23 if we go to cel 6018 please
02:20:32 this is an email the same date late at night 24th of november 2014 from jonathan room to him to others i
02:20:43 from jonathan room to him to others i think but certainly to daniel ankurtall jones re celetech's project review
02:20:48 review hi dan i spoke with mark and the team regarding a few projects and you can see the projects set out there grenfell tower premier house chartwell house south end in terminal 4 heathrow mike had a new
02:21:00 in terminal 4 heathrow mike had a new project review um we can see from the top that certainly under grenfell tower that rs
02:21:10 rs 5000 was discussed in the context of that project do you remember having any discussion at all
02:21:18 all on that date with jonathan room at harley house about rs 5000 in relation to grenfell tower or in relation to any project um i can't recall i'm afraid right
02:21:32 do you remember whether and there were any discussions in harley either at or after this meeting about rs 5000
02:21:41 5000 um not that i was involved in that right do you remember whether you saw a brochure relating to rs 5000 or any other sales literature not like remember no
02:21:56 do you remember mr roon being provided with any drawings or other documents in relation to the grenfell tower project um again i
02:22:07 um again i i wasn't involved in the job particularly then so i wouldn't have been involved in that discussion
02:22:16 all right can i ask you to go to paragraph 30 of your statement please page seven
02:22:26 and we can see under that paragraph you are providing a response to a question at paragraph four i and the question was was specific
02:22:38 i and the question was was specific consideration given to the combination of the exterior components eg cladding insulation windows and methods of fixing and the fire safety fire retardancy and compliance with safety standards of the same
02:22:49 same and your answer was i was not involved in this area of work but i would expect that this would have been looked at by the architects and the highly designed team
02:22:56 team with advice from the project manufacturers um and you say harley design team and then you go on a paragraph 40 at page
02:23:09 then you go on a paragraph 40 at page nine i just want to show you that first before i ask you the questions about it page 9 pair of 40.
02:23:17 40. and the question there that you're addressing is what was the chain of decision-making communication and responsibility about the cladding insulation windows and fixings
02:23:26 fixings and a paragraph 40 you say four lines down
02:23:29 down someone in a technical position at harley would also have been looking to determine whether any given product was suitable and they would be reliant on the supplier the question is what particular which
02:23:41 the question is what particular which particular person that harley did you have in mind when you referred to the design team the harley design team um it would have been either ray bailey or daniel tell jones i see um
02:23:53 tell jones i see um what about kevin lam as well um yes probably him as well because he was um designing the job under i mean under daniel i see and when you refer to someone in a technical
02:24:05 you refer to someone in a technical position
02:24:05 position again same question who are you referring to say i have either a or daniel and anybody else um possibly kevin but
02:24:16 and anybody else um possibly kevin but again
02:24:17 again um not being in that department um it was there you know i'm not aware of what their system was for checking products so you have to speak to them really i'm afraid
02:24:28 to them really i'm afraid now at the end of that paragraph you say the supplier would be told what the product in question was going to be used for and would be sent the relevant mbs specification and drawings dealing
02:24:39 mbs specification and drawings dealing with that part of the building the ultimate decision would rest with the architect in relation to all design matters do you remember whether alcoa who made reyno bond at the time
02:24:50 who made reyno bond at the time was sent the nba specification um i don't know as the mbs was sent to cep but i don't know whether it's forwarded on to alcoa do you remember whether celetex was sent the nba specification for
02:25:02 was sent the nba specification for grenfell
02:25:03 grenfell um i didn't send it myself but it may have been since um later on
02:25:11 later on can we turn to h a r four zeros one zero one eight please
02:25:21 this is an email from you to
02:25:26 jason bethel j bethel at ryden of the 23rd of july 2014
02:25:33 and you say there further to our telephone conversation please finding close the following information within our works package there is approximately 4076 square meters of insulation on the
02:25:45 4076 square meters of insulation on the project
02:25:46 project the value of the insulation material only is 50 945 pounds uh now as we can see from that this email followed a telephone conversation that you'd had do you remember do you remember that
02:25:58 do you remember do you remember that telephone conversation i don't i'm afraid
02:26:00 afraid do you remember what it was about whether roughly what it was about or we just
02:26:07 um do you know why ryden didn't know how much insulation was in their work package that they had sent harley in terms of cost or the in terms of um measurement square meters um area
02:26:21 um measurement square meters um area i don't believe it was actually put in the uh
02:26:25 the uh quotation document yeah the actual meterage no so so how did so do you know why it was that
02:26:32 that ryden didn't themselves know what the area of insulation was that was required for an entire project was this even because they didn't measure it from the drawing and say relied on um hardies to actually do that i see
02:26:44 um hardies to actually do that i see do you know how you came to the value of 50 945 pounds for the insulation um i don't without seeing the pricing documents but it would have been
02:26:55 documents but it would have been what what the cost was for insulation in the uh
02:26:59 the uh in the quotation it's 12 i i work that out as 12 pound 40 for nine p per square meter now assuming my arithmetic is right does that ring a bell with you um no i'm afraid it doesn't but you can't help us
02:27:11 afraid it doesn't but you can't help us as to where you got that figure from it's a long time ago i'm afraid we've seen my pricing documents you know i've tried so many projects since then trying to recall something from six seven years ago
02:27:22 seven years ago was was ryden inquiring do you remember as to the cost of the insulation or were you simply volunteering that information um i think that was the request because i've said obviously referred to the conversation
02:27:34 referred to the conversation and they've requested that at the cost and the square meter ridge did it strike you as odd that it was only asking about the cost of the insulation at this stage in the project
02:27:46 insulation at this stage in the project mid july late july 2014. um i can't remember why she thought it at the time but just having seen other documents
02:27:54 documents recently i believe it's to do with possibly changing the insulation over to a different product there was a definitely wondering how much cost was in there for that and the area
02:28:04 area right again i'm just relying on information i've seen recently do you know when you first priced up the celertex fr 5000 the product originally stipulated in the mbs specification
02:28:15 in the mbs specification um what the actual product itself or just a cost space cost for grenfell um it would have been back in
02:28:22 back in december january i see so not in this email no i see
02:28:31 can we then turn to a different document which is a document generated in january 2015
02:28:37 2015 called the harley spec or harley specification this is ryd3046822 please
02:28:56 um this uh is a document which looks as if it was generated initially by kevin lamb on the 15th of january 2015 if you look at the bottom
02:29:07 at the bottom right hand corner and it went through a number of different revisions through to the middle of july 2015 as you can see from the revision box at the bottom
02:29:21 were you involved in any way in compiling this document no not at all
02:29:27 did you ever see this document during your involvement on the grenfell tower project um i might have seen in passing but by
02:29:38 um i might have seen in passing but by 2015 i was not involved in the project right
02:29:46 we were you involved in pricing the uh items that p1 and p2 on the left-hand side there the glazing p1 panels and the glazing p2
02:29:58 the glazing p1 panels and the glazing p2 panels
02:29:59 panels so i can't see the uh i i you can't i'm so sorry can you be shown the left-hand side you'll see glazing p1 where
02:30:10 you'll see glazing p1 where okay the p1 panels have a core of styrofoam
02:30:14 styrofoam and the glazing p2 which have a core of 25 millimeter kingspan tp10 rigid insulation do you remember
02:30:22 remember quoting for those um yes they would have been in the original quotation yes
02:30:30 uh um
02:30:35 are you able to shed any light on uh any changes to those specifications later or were you just not involved in the project by
02:30:46 the project by by and later that's right now he's changing by this stage and later yeah now we can see earlier that you were present at a meeting on the 24th of november
02:30:54 november when um rs 5000 was discussed it appears do you know why rs 5000
02:31:05 rs 5000 or fr 5000 either of those but i think by this stage rs 5000 was omitted from this specification no i don't know would it be usual to
02:31:17 no i don't know would it be usual to omit
02:31:17 omit the insulation specification when designing a facade system it's possible it may change once the project had been won and it's actually reached a design stage
02:31:29 and it's actually reached a design stage things do change but it all goes through to approval from the architect
02:31:34 architect any changes i see does it does this tell us that you yourself can't shed any light on why either
02:31:41 either fr 5000 or rs 5000 were not referred to specifically in this specification that's right i was involved so i don't know
02:31:51 very good well mr albertson mr chairman i've come to the end of my questions that i've prepared that i may have skipped over um in my keynotes to get to this point
02:32:02 um in my keynotes to get to this point well if we had uh ten minutes or so that would be that should enough that should be enough yes yes well miss alveston council thinks he's reached the end of the questions but it needs an opportunity to take stock
02:32:14 it needs an opportunity to take stock and check there aren't things he ought to have asked you so we're going to take a short break now we'll come back at 10 to 1 please and then see if there are any more questions okay right yes and again please don't talk to
02:32:26 right yes and again please don't talk to anyone about your evidence when they're out of the room okay okay you get the usher please thank
02:32:36 you
02:32:46 right turn to one
02:45:57 yes would you ask mr ogleston to come back please
02:46:15 right mrs robles and we'll see mr miller do you have some more questions i have one
02:46:18 one mrs robinson and it arises out of um an answer that you gave me in your evidence very shortly before we finished when i was asking you
02:46:29 was asking you about celetex and this is today day 35 at page 81 line eight i'll just show this to you
02:46:40 line eight i'll just show this to you my question at line six on page 81 it was what was the product that was going to be used as contemplated by this quotation
02:46:50 quotation and it was a quotation that we um looked at
02:46:54 at earlier and your answer was it was either
02:46:57 either going to be either celetex or a similar insulation product what did you mean or what were you referring to by a similar insulation product
02:47:06 product well a insulation product would actually give a similar performance to celetex and in your mind at the time what was that um i didn't have a opinion at the time of that but
02:47:17 of that but again it would have been a technical point built up by a technical team on harley and when you say
02:47:27 a similar performance similar in what respect um in terms of what the defer more properties of it or if there's any fire properties or whatever
02:47:38 there's any fire properties or whatever so you would include fire safety performance um i think it probably would be yeah
02:47:43 be yeah anything if it was particular for that product yes i see
02:47:50 does that tell us that at the time you didn't see any distinction between the between different products different insulation products as regards fire performance um no i didn't
02:48:01 fire performance um no i didn't right okay thank you very much uh mr alvison i have no further questions for you i just wish to say a thank you to you for coming to the inquiry and assisting us with our investigations so thank you very much
02:48:12 investigations so thank you very much yes well we're very grateful to you mr alviston for coming along it's very helpful to have had your evidence and now you're free to go okay thank you thank you very much you'd like to give the r show shield look up
02:48:23 the r show shield look up thank you
02:48:38 oh mr millet it would probably be convenient to adjourn at this point and start our next witness at two o'clock very good mr chairman thank you very much two o'clock please thank you
02:48:59 much two o'clock please thank you you