Kevin Lamb (Harley draftsman) on design development, architect approval process, and cavity barrier decisions
00:00:08 good morning everyone welcome to today's hearing today we're going to hear further evidence from mr kevin lamb so would you ask mr lam to come into the
00:00:28 royalties good morning mr lam good morning are you ready to carry on certainly i am yes good thank you very much yes ms grange thank you yes good
00:00:39 much yes ms grange thank you yes good morning mr lam hi there so when we broke yesterday i had been asking you some questions about a run of documents to do with some a window approval process window detailing yes and if you recall
00:00:51 window detailing yes and if you recall it was a process where ultimately uh simon lawrence kept getting loot back in and asked for his approval
00:00:57 approval and you were right in the middle of explaining to us that that was uh not necessarily a representative example of the way it normally worked that was an exceptional case exactly yes because it was a late
00:01:08 exactly yes because it was a late addition and it had caused potential or might of course cost consequences for ryden
00:01:14 ryden is that correct that's correct yeah is there anything more you want to say on that
00:01:18 that because what i was going to do next is try and take you to perhaps something that looks more like a normal example of what happened on the project no no i don't need to answer that i think okay well let's let's look at another example let's turn
00:01:31 let's look at another example let's turn up
00:01:32 up sea three zeroes one three two two
00:01:38 one
00:01:42 this is an email
00:01:47 dated it yes if we look at the one at the bottom of the first page 29th of may 2015 and you address it to simon lawrence but address your email to neil crawford
00:02:01 you've copied in others as well including daniel anchorator jones and you say neil please find attached drawings for the crown element for approval yes yes that's right
00:02:14 and then we can see in the top that on the 12th of june neil crawford comes back to you copying in the same individuals hi kevin
00:02:25 copying in the same individuals hi kevin please find attached comments on the crown drawing so he's now commented and if we can turn to the attachment um to that email this is ryd3045
00:02:40 um to that email this is ryd3045 sorry ryd three zeros four three five four seven and i want to look at page four
00:02:55 so i think what we're looking at here correct me if i'm wrong is some detailing at the very top of the building is that that's right just under the crown yes just under the crown
00:03:06 and we can see that it had had the issued for approval stamp on there
00:03:12 on there that's the other stamp that we mentioned yesterday that's correct i can now take you to this example of it that's normal yes so that would normally come
00:03:19 come first from you yes when it was going over to the architect yes and then later you would get the approved for construction stamp that was your practice that's it following a response from the
00:03:30 that's it following a response from the architect um where it's either b or an a and there's clear comments now i think this drawing is a rev naught
00:03:41 now i think this drawing is a rev naught or a rev zero is that correct that's correct yes can you help us as to what that means or what that meant that means that's the very first issue of that drawing
00:03:49 drawing yeah so you haven't had any previous version of it yourself or through studio e no no and that was entirely your drawing was it
00:04:00 was it it's based on um neil crawford's designs yes
00:04:03 yes yeah i see
00:04:06 and we can see that neil crawford has stamped the drawing with a b conforms to design intent subject to
00:04:19 incorporation of comments revise and resubmit for category a status correct and we can see his comments in red and the bubbles yeah he wants the existing roof parapet requires to be surveyed and metal coping
00:04:32 requires to be surveyed and metal coping flashing to fit over yeah is that correct
00:04:36 now just taking this drawing um through its story um if we now turn to sca3013262
00:04:48 we can see from the bottom email on the first of july
00:04:53 you send to simon lawrence
00:04:57 you say um an email copying in neil i think we'll see in a moment you see up the page that you're copying the wrong nail to start with and then you copy in the right neil but i think you're
00:05:10 the right neil but i think you're addressing this to neil crawford is that right
00:05:12 right that's correct yeah and you say neil please find attached revised coping detail to the crown element if you could have a quick look and pass your comments we shall then reissue the whole of this element for construction based upon your previous approvals
00:05:25 based upon your previous approvals having shorter coping will allow it to run between columns being far more tidy etcetera so that was your email to him and then it is eventually copied
00:05:37 to him and then it is eventually copied if we scroll up the screen it goes to the right
00:05:39 the right neil crawford yeah [Applause] and then we see that mr crawford responds
00:05:47 responds at 1903 on the same day later that same day and he attaches another drawing if we can turn to that this is
00:05:55 this is sca 3013263
00:06:02 and here we've got the window head coping
00:06:06 coping is that right that's correct yeah it's the same drawing again yes being revised yeah
00:06:11 yeah and we've now got status a conforms to design intent
00:06:18 and
00:06:22 we've still got the issued for approval stamp at this stage
00:06:29 now then if we carry on with the story of this drawing if we now turn to har four zeros four four four three so triple four three
00:06:43 on the 26th of august 2015 1733 you send an email neil main entrance adjusted as your further comments this morning
00:06:53 morning don't worry about that because that's about the main entrance but then you say cladding drawing just with additional set out
00:06:58 set out info for the installers yeah do you see that there and we think it's that comment that is relevant to this drawing okay and it would appear that
00:07:14 um yes um so then we get neil crawford on the 28th
00:07:21 the 28th of august responding saying hi kevin no further comments as attached and if we can look at the attachment at this is sea403310
00:07:35 this is sea403310 and we need to look at page three
00:07:40 and we can now see that this has got to revision
00:07:44 revision b of this drawing yeah is that correct that's correct yeah we see that from the little box at the bottom on the left yes and we've got conforms to design intent
00:07:56 intent on that revision b of the drawing yeah so he's happy he's happy with it yes yes and it's mark status a and it would appear to us that
00:08:07 appear to us that it was that drawing that was then issued for construction right that's right so is that example more representative of the approval process that you were
00:08:19 of the approval process that you were going through on the project to get from the drawings that studio e had sent or the harley discussions you'd had at the beginning
00:08:28 beginning through the design process through to something being issued for construction totally yeah thank you that's helpful
00:08:46 who in your view had ultimate responsibility for checking and approving the drawings you were producing who did the buck stop with the architect
00:08:57 who did the buck stop with the architect right
00:08:57 right yeah and that would be consistent with what we've just looked at and your understanding of the process that's correct yes
00:09:06 can we now turn to um look at another example this is
00:09:13 har404590
00:09:19 this is an email from you to simon lawrence
00:09:23 lawrence on the 20th of october 2015 and you've copied in a number of other individuals there including daniel anchored jones mark stapley ben bailey
00:09:36 ben bailey and you write neil please find attached gf curtain wall elements for comment approval
00:09:44 approval can you help us as to what the gf means ground floor ground floor okay now one of those drawings it's in the second line of the attachments in the middle
00:09:55 attachments in the middle is c1059ga model 50 223. you see that there yeah and if we turn to that drawing this is the
00:10:09 turn to that drawing this is the sca403316
00:10:13 we can see that this does not have any red studio e stamp as mr crawford appears not yet to have reviewed it however in the bottom right hand corner we can
00:10:24 in the bottom right hand corner we can see approved for construction that's correct yes do you know can you help us as to why this drawing was marked approved for construction before studio e or ryden had looked at
00:10:35 before studio e or ryden had looked at it
00:10:36 it that was simply a clerical error a clerical error yeah yeah yeah what we tend to do is we'll when we're producing drawings we'll copy a drawing border to a clean space on the
00:10:47 a drawing border to a clean space on the drawing model put the drawing in the drawing border and in this particular instance i must have copied yeah the the incorrect stamp yeah i don't think it would have caused
00:10:58 yeah i don't think it would have caused any confusion with anyone and so should the stamp that should have been on here being the issued for approval with the dotted line on it definitely yeah now mr crawford then
00:11:11 definitely yeah now mr crawford then replies just keep following this story through your replies
00:11:15 replies to the email you sent if we turn to har 404669
00:11:23 we we see him coming back to you on the 22nd of october hi kevin please see attach comments on ground floor and he's attached some drawings and one
00:11:34 and he's attached some drawings and one of them is the one we were looking at drawing two two three if we go to har four zeros four six seven
00:11:41 seven zero at page three
00:11:46 is that the same drawing it is yeah and we can see here that mr crawford has made a number of of comments and suggestions on the drawing and he's marked at status b
00:11:59 drawing and he's marked at status b yes yes yeah
00:12:02 you then respond to mr crawford's email this is har404743
00:12:12 you respond on the 26th of november 2015
00:12:19 and you say to him neil please find attached
00:12:23 attached gf curtain wall so ground floor curtain wall drawings revised in accordance with your comments and you've given a number of
00:12:29 of notes including relating to two two three which would have been covered in the 222-228 is that correct yes
00:12:39 yes and
00:12:44 if we look in the yes and then in the attachments we can also find that drawing and it's now 223a it's the second line from the bottom um on the right hand side yeah we see
00:12:57 um on the right hand side yeah we see the 223a
00:12:58 the 223a yeah so that's revision a of drawing too that's correct yeah yeah but if we turn to har four zeros one triple nine
00:13:12 this appears to be an email of the same date as the one we just looked at 26th of november from ben bailey to someone called mike and lucy at ajf aluminium and glass
00:13:25 and lucy at ajf aluminium and glass facades limited is that right yes yes i think they're a fabricator correct and ben bailey is writing on the same
00:13:34 same day and it's the same set of drawings please see us see our construction issue drawings attached for grenfell tower
00:13:44 yeah you see that yes and the second email down in this chain is the email from you returning the revised drawings to mr
00:13:55 you returning the revised drawings to mr crawford
00:13:56 crawford with his comments on yeah but we'd see no
00:14:01 no receipt from mr crawford of an email confirming the revisions were acceptable and stamping the drawings stay to say had we
00:14:11 had we um nobody had stamped them status b yeah and does this go to the point we were discussing yesterday that in practice
00:14:22 it was common to take status b as well provided do you incorporate those comments this is approved that's correct and by the virtue of the email that um returned those drawings we were quite
00:14:33 um returned those drawings we were quite clear
00:14:33 clear in which of his comments we couldn't fulfill
00:14:38 fulfill right so there was a list of areas so when you went back with your comments yeah i see but that dialogue hasn't necessarily ended has it i don't recall but
00:14:51 i mean would you agree that it would be best practice to wait for mr crawford to return having marked the drawings of status a
00:14:57 status a i think ben was being proactive i think at this stage he was getting prices from agf
00:15:02 agf yeah so i'm sure he would have checked that we're all fully up to construction before placing the order yeah so just to be clear on your evidence would is it your evidence that
00:15:13 your evidence that um it was most common on this project to proceed to make the changes indicated by
00:15:21 by stamp b and not to send a document back for status a i was always sent back yeah um but we would actually start working um once you started
00:15:32 once you started yes yeah
00:15:35 thank you
00:15:39 now just on a topic of revisions after approval on drawings again i think you touched on this yesterday and you said that
00:15:46 said that on occasion um i think you said it was it happened on the ground that's correct yes that there would be further comments from the architect after you've got
00:15:58 after you've got what you felt was approval from them that's correct yeah and if we look at paragraph 30 of your witness statement har 30104
00:16:09 at page seven
00:16:13 i think you've explained that to us and this is where
00:16:20 about five lines down you've also explained the point about if a drawing was marked as status b that meant that fabrication could proceed taking into account the revision that's correct yeah so you explain that
00:16:32 that's correct yeah so you explain that to us in your witness statement yeah um and i want to pick it up towards the end of that paragraph two lines up from the bottom there you say once drawings were approved for construction i would then produce fabrication
00:16:43 i would then produce fabrication drawings for the specific components there were however times you can go over the page
00:16:51 the page when a drawing had been approved for construction and the architects will ride and change their mind about an aspect of the external facade such as the window configuration and you give an example and there would be further revisions to
00:17:03 and there would be further revisions to the drawings yes how common was that on the grenfell project
00:17:09 project um i think it was very rare rare so it wasn't something that was a problem no often it incurred costs and program implications so the teams would ensure that this sort of
00:17:20 the teams would ensure that this sort of thing wouldn't be it would only be an essential change
00:17:25 were there any other occasions when the process of checking and revision that you've outlined for us was not strictly followed
00:17:33 followed um not that i can think of off the top of my head
00:17:40 [Applause]
00:17:44 now in paragraph 31 in the next paragraph
00:17:48 paragraph we just read the first four lines you say as we can be seen from the drawings themselves revisions to drawings were marked up with a letter dated and described as they were made these revisions generally reflected comments from the architects
00:18:00 comments from the architects however there were revisions made later on in the process that were not submitted to the architects or ryden for their comment and you go on to give an example of that you talk about revision d of drawing c1059302
00:18:15 of drawing c1059302 and you say it was a little bit further it was in the context of drawing up the fabrication drawings for the cladding panels and it looked to you like the drawing could be improved aesthetically
00:18:27 could be improved aesthetically and you discussed this with ray bailey and it was decided to remove the return on the cladding facing the window and include an aluminium angle instead is that the aluminium angle that mr
00:18:41 is that the aluminium angle that mr bailey explained to us in his evidence no it's different is it
00:18:45 is it no it's not it was an aesthetic trim from memory can you just help us as to um what the i think it's
00:19:00 right i think it was um to do with tolerancing of the panels the panels the cladding panels returned to the window yeah and you need a nice clean edge
00:19:13 yeah and you need a nice clean edge now if there's a slight out of tolerance of the building which throws the windows slightly out of alignment then you could get gaps yeah and i believe these
00:19:24 believe these were sort of closure angles that were screwed to the window first so that any minor discrepancy would be totally hidden i think purely an aesthetic issue yeah
00:19:38 i think purely an aesthetic issue yeah so that's um you've given that as a and is that a representative example would you say of the type of change that was made which wasn't run past one
00:19:50 that was made which wasn't run past one architect
00:19:50 architect that wasn't normal and i think at this stage
00:19:55 stage because we're actually manufacturing panels to stop manufacture to run it past the architect i think ray certainly felt it was worth the risk
00:20:07 ray certainly felt it was worth the risk um that the architect wouldn't be happy but i don't see how he could be unhappy with it because it was only improving the aesthetic quality yeah that joint
00:20:19 can you help us as to whether any other category of drawings were not submitted to the architect for approval uh fabrication drawings weren't issued to him only the ga drawings
00:20:30 him only the ga drawings yeah and it was that in common with normal industry practice that's correct yes
00:20:39 did you ever have any concerns about drawings not being issued to the architects for approval on this project
00:20:48 project no no
00:20:57 [Applause] i now want to turn to a different topic which is about the um atm rayna bond cladding okay um we've touched on that a little
00:21:08 okay um we've touched on that a little bit when we talked about the the guidance in this area in adb but i want to just return to this if we pick this up in your witness statement at paragraph 20 this is har three zeros 10419 at page
00:21:22 this is har three zeros 10419 at page five
00:21:27 and we look in the sixth line down begins on the right hand side
00:21:34 actually it's a fifth line down sorry you say
00:21:38 you say it had been decided prior to my involvement in the project that the cladding was going to be cassette and the acm was the material to be used
00:21:49 that's correct you see that there yeah
00:21:53 now when you sit down to develop a design do you agree you must first understand the design to date and the materials which are going to be used
00:22:04 used um just bear in mind that my client's harley
00:22:08 harley and so i'm working under their instructions yeah so where there's departures from the architects concept they're the ones
00:22:17 ones telling me right we're not doing in this instance i think the architect's drawings originally showed um a face fixed panels and harley said to me no i want you to
00:22:28 and harley said to me no i want you to draw
00:22:30 draw cassette panels because it's been agreed over the previous period whilst working up um
00:22:35 up um the quotations yeah were you familiar with the rayna bond acm product um i was uh reasonably familiar with the
00:22:47 um i was uh reasonably familiar with the with the um product in general not necessarily raina bond i'd used a luca bond before yeah but it's a very generic product
00:22:58 were you aware at the time that the product was formed of two thin sheets of aluminium with a low density polyethylene pe core no i understood that it was it had a core and it was um faced with
00:23:11 it had a core and it was um faced with aluminium skins but i wasn't aware of the actual properties of the core and you never asked anybody on the project you know just so i know what is in the core
00:23:22 in the core you didn't ask that no all i knew was it it was to provide a lightweight composite panel um i had no reason to question it did you have any idea what
00:23:34 question it did you have any idea what type of material might be in the core for example that it was a thermoplastic would you have known that much um no i mean i assumed it was a plastic
00:23:47 i assumed it was a plastic it did make that assumption yeah yeah plastic or a resin type material but i didn't think any further than that okay
00:23:57 was it any part of your role to consider whether the acm was appropriate bearing in mind the building regulations and the associated guidance in adb no not at all
00:24:08 associated guidance in adb no not at all but if i was concerned i would have raised an issue
00:24:15 now if we turn up the harley specification this is ryd3046822
00:24:27 these are the harley specification notes yeah
00:24:32 yeah and we see at the bottom that revision a came on the 3rd of march 15 and it was revised a number of times
00:24:39 times and we'll look at this again and again in your evidence because we'll come to look at some of the other products that are on here but just panning out again looking at the whole document was this document prepared by you yes
00:24:51 was this document prepared by you yes yes
00:24:52 yes and can you just help us as to how you went about preparing these specification notes um well these are all the materials that i was instructed to use um from the harley team
00:25:06 so was there any sense in which you yourself looked at the nbs specification and then transpose that into this or is this
00:25:16 this solely the product of discussions you'd had with harley no if there was um if there was doubt from harley they might say well check the mbs i don't recall them doing that
00:25:28 the mbs i don't recall them doing that in this case i was told which materials would be used and would you be told verbally or would you be given a written instruction no verbally across the table at our design meetings our very first
00:25:39 at our design meetings our very first design meeting covered most of this so you'd take notes of what you were being told yeah and then you'd put it into this yeah that's right yeah and who at harley would you expect to check this
00:25:51 would you expect to check this um dan and or ray uh maybe mark stapley and what would you expect they would be checking for that i've put their instructions down on
00:26:02 that i've put their instructions down on the drawing correctly and checking that those materials were appropriate to use given the requirements of for example the building regulations
00:26:13 for example the building regulations um i'd been given the materials so i presume that was a process that they'd done prior to that point yeah so at the point where they're
00:26:24 yeah so at the point where they're checking my drawing drawings they're checking it against their instructions that they've given to me
00:26:30 me they're not really you know re-going over the conformance but just to be clear it was your assumption was it at the time that there would have been a process for selecting these materials within
00:26:41 for selecting these materials within harley
00:26:42 harley and checking that they were compliant with relevant requirements i don't know that that would necessarily have come from harley because there had been i don't know
00:26:53 because there had been i don't know certainly at least a year before i came on the scene they'd had many discussions with the client um the architect and whoever else i mean i don't know
00:27:04 and whoever else i mean i don't know exactly
00:27:05 exactly um so i can only assume that in those discussions someone has considered the conformance right suppose the mbs specification was silent about particular material to be used in
00:27:17 about particular material to be used in a particular location or perhaps only specified a performance specification and left the precise selection of that product
00:27:25 product to harley would you expect in those circumstances that somebody within harley would have checked before telling you what the product was that it was compliant with relevant requirements
00:27:37 compliant with relevant requirements uh yes so yes
00:27:41 now we can see also that this was issued this specification this set of specification notes was issued to studio e architects and they've marked it mr crawford has marked it conforms
00:27:53 marked it conforms to design intent there yeah status a yeah and just to be absolutely clear would you understand that men that mr crawford was satisfied that these products were appropriate to
00:28:04 that these products were appropriate to use on the building given the statutory requirements including the building regulations yes definitely definitely
00:28:16 yes definitely definitely okay we're going to come back and look at this in relation to some of the other specific
00:28:20 specific materials but for now on the acm panels we can note right at the very top left that we see system metal technology high
00:28:31 that we see system metal technology high thermally broken aluminium windows and then the rain have been rainer bond composite rain screen cassettes
00:28:38 cassettes correct yeah you see that there so this specification does record the type of acm that's to be used that's correct yeah now when you put this specification
00:28:49 now when you put this specification together and you put the rayner bond in there
00:28:53 there did you look at the bba certificate for the rayna bond panels was that any part of your role no not at all no
00:29:02 were you aware that there was a bba certificate for the rayner bond panels it never crossed my mind but a product of this
00:29:12 of this prominence you would imagine there would be one
00:29:15 be one yes
00:29:19 had you ever seen a bba certificate for those panels before on other jobs no can we just pull it up this is at bba6047
00:29:37 so it's dated um it's from 2008
00:29:43 it's number zero eight four five ten and then
00:29:46 then sorry if we can just pan out we actually see the date on the bottom of this first page date of first issue 14th of january 2008. can you see that there in the blue box
00:29:57 can you see that there in the blue box the the pale blue box yeah look at that so this certificate predated the grenfell project by some years
00:30:05 years yeah were you familiar with bba certificates generally had you ever come across them in your design work before um i knew they existed yeah um but as
00:30:16 um i knew they existed yeah um but as a subcontractor draftsman it was never really my role yeah to consider the um the contents to any degree so just to be clear it was not part of your role to
00:30:29 be clear it was not part of your role to look at that certificate check anything in it about the product before you put it on the specification notes no not at all would you have expected somebody within harley to have done that so before they told you across the table
00:30:42 so before they told you across the table the cassette panels are going to be rayna bond would you have expected somebody within harley to have looked at this bba certificate and have understood the information it was conveying
00:30:53 conveying i would expect a member of the team or members of the team would have considered this when they were working up the materials now i certainly at the time i was not aware of who
00:31:04 of who decided what materials were to be used harleys were telling me what they wanted to be used maybe they'd been told by the architect maybe they've been told by the builder i don't know that
00:31:15 don't know that yeah if we look on within section six of this um certificate under section six which is about fire performance
00:31:26 sorry it's on page page five apologies so there's a whole section on behavior in relation to pharah and i pre i appreciate your evidence that you say it wasn't part of your role to look at this
00:31:37 wasn't part of your role to look at this yeah but what becomes apparent when you do read this is that there was a something called a standard sample of the product which we now know was the pe sample of the product right and in 6.2
00:31:48 sample of the product right and in 6.2 it then talks about a fire retardant sample of the product yeah do you see that there were you aware in general terms when you were working on this project and putting together that spec
00:32:00 together that spec were you aware that there was a fire retardant version of these panels not at all so that was not something you were ever told or not something discussed
00:32:10 discussed at the meetings no i have used luca bomb products in the past and again i never knew that they had different grades you just didn't know that no
00:32:22 [Applause]
00:32:26 let's just look at the initial order of the acm
00:32:29 the acm if we can turn to cep
00:32:34 six zeros five one two this is an email you're not
00:32:47 this is an email you're not a recipient or copied into this email but what we see here is it's mark stapley on the 25th of february 2015 to jeff blades of cep copying in ben bailey and it's
00:33:00 copying in ben bailey and it's about grenfell tower acm panel requirements and he says hi jeff please find attached our cladding panel requirements for grenfell tower can you provide us with your most competitive price and also confirm lead
00:33:11 competitive price and also confirm lead times
00:33:13 times yeah i say that we've seen that
00:33:17 and we know that the acm panels had been formally signed off by planning in september 2014 can you help us as to why harley didn't begin
00:33:27 begin obtaining quotes for the fabrication of the panels until late february 2015 almost five months later um i would guess at this stage they needed um more finite um dimensions of the
00:33:41 um more finite um dimensions of the panels to get an accurate price i see and and so what they had to wait for your work to that's correct yes whether it was preliminary or i wouldn't have thought it was finalized
00:33:52 i wouldn't have thought it was finalized at this stage but uh we must have had a is that something you know about or is that just your own sort of
00:33:58 of speculation yeah to be fair is speculation it is normal yeah okay can we turn to the attachments that mr stapley included with that email this is
00:34:09 stapley included with that email this is acm panel requirements cep60513
00:34:21 so here we have the requirements that are being sent to cep um and i think if we look in the bottom right hand corner we can see this is a drawing date of the 16th of february 15
00:34:33 drawing date of the 16th of february 15 and we've got your little lamb symbol and kvl
00:34:37 and kvl yeah does that mean you drew this certainly did you put this drawing together
00:34:41 together yes this is your work
00:34:46 and then slightly to the left of that we can see
00:34:51 can see that the specification so if we can just pan out again
00:35:00 we see there in the middle at the bottom it says material rayna bond yes and then the finish smoke silver metallic duragloss correct 5000 satin so that's the
00:35:12 correct 5000 satin so that's the material
00:35:13 material you were told to put on there and you wanted to use that's correct farley wanted to use
00:35:21 and turning to page four there's a list of
00:35:25 of notional material requirements again is that something you would put together in this case i did yes yes so you put this list together
00:35:38 yes so you put this list together yes i can't remember whether it was mark stapley but um i was asked to produce an approximate list of requirements so materials could be pre-ordered or maybe it was for costing purposes
00:35:50 maybe it was for costing purposes don't recall exactly yes and what we note
00:35:54 note that is in neither case neither in the drawing nor here does it mention what the core of the acm would be
00:36:02 would be um it just says rayna bond and then we get the finish that's correct as as i understand it harley were in discussions with cep yeah
00:36:13 harley were in discussions with cep yeah they all knew the material that was going to be used would it be normal in your experience with these kind of details fabrication details
00:36:22 details not to specify the call to be used in an acm panel
00:36:27 acm panel on on these kind of drawings or specifications um
00:36:35 no i mean not necessarily i mean certainly from my point of view i wasn't aware that there were different cause no one raised that with me and
00:36:46 no one raised that with me and i would expect cep if there was any confusion
00:36:49 confusion they would say well what core do you want on this yes and and they would be keen to provide this with the most expensive core obviously
00:37:00 you began that answer with no not necessarily my question was would it be normal in your experience for these kind of details including fabrication details not to specify the core to be used in an acm panel can ask it
00:37:13 to be used in an acm panel can ask it this way
00:37:14 this way have you been involved in other projects where the call has been specified no no no i've done very little acm
00:37:23 acm um certainly as far as fabrication drawings are concerned to this degree and but no i've never specified the call but pulling it back from acm would you expect these kind of details to be very
00:37:34 expect these kind of details to be very specific
00:37:35 specific about the composition of say a composite product and exactly what was being requested
00:37:43 [Music] quite often there are elements missing on drawings which i discussed at the point of purchasing
00:37:54 purchasing certainly with harley they were very close with cep and i was well aware that there'd been many discussions between the two parties way before i was
00:38:05 between the two parties way before i was employed
00:38:06 employed um so i'd be very surprised if there was any
00:38:11 any confusion okay
00:38:15 now sticking with the acm can we now turn
00:38:19 turn um to another email this is har
00:38:25 406585
00:38:31 and this is an email that mr anchor jones sends to ray bailey it's just the two of them on this email chain so you're not a recipient and you're not copied in just to be clear
00:38:43 copied in just to be clear it's on the 27th of march 2015 and they've been discussing the requirement for fire barriers or cavity barriers
00:38:55 cavity barriers um at the tower and what the rating was and whether it was a requirement for fire stopping or for cavity barriers yes you're nodding does that mean you're
00:39:06 yes you're nodding does that mean you're familiar with this um line of emails no no no i'm agreeing with what you're saying i see yeah and then and what i want to ask about is the second line in this
00:39:17 about is the second line in this and daniel anchor james said there is no point in fire stopping as we all know the acm will be gone rather quickly in a fire exclamation mark you see that there i can see
00:39:28 can see that yes
00:39:31 now did mr anchor tell jones ever say anything similar to you about acm when the whether on the grenfell project or on other projects no not at all
00:39:45 had it been said to you would you have agreed with what was said there the acm will be gone rather quickly in a fire um not if you read it as it said literally no i wouldn't agree with that
00:39:57 literally no i wouldn't agree with that so how would you read it
00:40:01 um i mean this is um
00:40:06 should i be interpreting this
00:40:09 i take a very good question i take your point i don't think uh mr lam's an expert on these i understand that i just wanted to know if he'd ever had a conversation with anyone about
00:40:19 about the the acm and what how it would perform in a fire during the project and the answer i think is no so i'll move on
00:40:27 move on um i just want to ask now about informal meetings that you might have had
00:40:34 had with studio e and rbkc building control so mr crawford when he gave evidence the inquiry
00:40:42 inquiry stated that there were a number of informal workshops with rbkc building control where drawings were discussed now um did you ever meet any of the rbkc
00:40:53 now um did you ever meet any of the rbkc building control officers on the project no so no so that those can't have involved you no no fine
00:41:03 and it would follow therefore that you couldn't have met mr john hoban on the project or discussed with him no definitely not the materials for the project
00:41:12 project [Applause] so i now want to ask you about the insulation product that was used behind the spandrel and column rain screen panels at grenfell
00:41:26 now we've already discussed the nbs specification we know that the nbs specification featured a product called celetex fr 5000 as the insulation
00:41:38 celetex fr 5000 as the insulation product
00:41:39 product yeah were you aware of that at the time of
00:41:42 of working on the grenfell project that the product in the nbs was fr 5000. um i don't know whether i even saw that i mean i was told us at a point
00:41:55 that i mean i was told us at a point later on in the project that we were using the rs um i don't think it ever struck me that that was contrary to the fr let's just look at that briefly in the mbs specification if we go to
00:42:09 in the mbs specification if we go to sca50169 at page 73 and it's item 776.
00:42:22 so again this is part of the h 92 section
00:42:25 section the rain screen cladding section of the nbs spec and we can see um in the second bullet point down the manufacturer's celotex limited and a little bit further down is an
00:42:37 and a little bit further down is an indented
00:42:39 indented dash and it says product reference fr 5000
00:42:42 5000 yes aluminium 4 face both sides yeah does that help as to whether or not you saw that
00:42:49 saw that at the time no no i don't recall seeing it
00:42:52 it but it was unimportant because i was given the material that we were going to be used
00:42:57 be used and just to be clear you have no memory of ever being aware that the original project product specified was an fr 5000 product
00:43:08 fr 5000 product i i don't believe so i mean i might have noticed seen it on uh some of his drawings i don't know if he called it fr 5000 on
00:43:17 5000 on on his drawings i don't think we see it on the studio e drawing we don't think that
00:43:21 that it was marked as fr 5000 but no well presumably from a drawing point of view it doesn't really matter does it not at all no
00:43:33 now we we know that the product was later changed to rs 5000 and that was the insulation product used on the tower when you joined the product the project
00:43:44 when you joined the product the project in august 2014 we know your first meeting
00:43:48 meeting with ray bailey and daniel jones was on the 12th of august 2014 yes were you told at that point that the product was going to be a celetex product i don't recall if
00:44:00 product i don't recall if if they actually said it was going to be celetex i was told that it was going to be a rigid insulation yeah so i would assume a celetex or a kingspan type product
00:44:11 kingspan type product but the term thermal calculations had to be done
00:44:15 be done to determine the um the actual product who was doing those thermal calculations as i understood dan dan anchor jones yes did you ever
00:44:26 dan anchor jones yes did you ever discuss with dan angel jones that there was a new product that had come onto the market
00:44:33 market did he ever discuss that with you no that was called rs 5000 no or that there was a change that they were making from one celetex product to another
00:44:52 now looking at paragraph 49 of your witness statement this is har3010419 at page 13.
00:45:06 in the middle of that um paragraph sorry just to pick it up you've been asked the question at 4d was the exterior of the building including the cladding insulation
00:45:17 including the cladding insulation compliant with relevant building regulations fire regulations and in the middle there three lines down you say in particular the cladding was class naught the insulation was suitable for use on buildings over 18 meters
00:45:29 buildings over 18 meters according to the celatex screen cladding compliance guide do you see that there yes yeah and if we also look at paragraph 54 of your witness statement on page 14
00:45:45 if we can look at 54 and blow that up you say my involvement came after the choices had already been made about the cladding and insulation materials and i cannot comment on advice information or
00:45:57 cannot comment on advice information or assessments about these although as stated above i do recall reading the celetex rain screen cladding compliance guide yes do you see that there yeah so can you help us why would you have been
00:46:09 you help us why would you have been reading the celetex rainscreen cladding compliance guide um i had to consider the how it was going to be fixed to the building yes so i wasn't reading it to the end of
00:46:21 yes so i wasn't reading it to the end of degree i was looking for tables showing how many fixings and the types of fixings
00:46:27 fixings yeah so it was uh it was from a structural point of view to make sure it was
00:46:33 was fixed to the building properly yeah let's just pull up that guy this is
00:46:40 cel402047
00:46:52 now that's the what we think is the rain screen cladding compliance guide is that the guide that you read you were aware possibly yeah yeah i remember a pink guide with
00:47:03 yeah i remember a pink guide with using celotex over 18 meters written on the front yeah and if we go on to page two
00:47:12 at the top of the page you say this document provides guidance on complying with approved document b for external wall
00:47:19 wall provides a step-by-step guide to an alternative route to compliance for adb b2
00:47:23 b2 through meeting the performance criteria set out in br135 through testing to bs 8414. do you see that there yes i do now is your evidence that you simply wouldn't have been reading it
00:47:35 wouldn't have been reading it i wasn't checking for compliance for that kind of information not at all no
00:47:44 did you ever have any discussions with anybody within harley about anything that was said in this compliance guide in terms of compliance and not so nice
00:48:01 kingspan k15 if we look at paragraph 42 of your witness statement this is um on page 11 of your statement
00:48:13 paragraph 42 you say the insulation was celatex rs 5000 rigid slabs and was cut to suit on site however i am aware that some kingspan was used because of an interruption in
00:48:25 was used because of an interruption in supply of the celetex you see that there i do yes when you say you were aware were you aware at the time that you were working on the project that some kingspan was used because of
00:48:37 that some kingspan was used because of an interruption in the supply yes can you help us as to when you became aware of that i think there was a point where i happened to be
00:48:48 there was a point where i happened to be in the office at harley and ben was quite unhappy because his supplier had just told him at that point that they couldn't provide him the seller tax
00:49:00 seller tax because of some kind of um
00:49:03 interruption supply yeah and can you help us as to when that might have been on the project i know it's difficult because it was a long time ago but any idea well you would have to check
00:49:15 any idea well you would have to check through the purchase orders and it would be days before he ordered the kingspan i would imagine yeah it wasn't i don't think it was a long time in advance he obviously got
00:49:26 long time in advance he obviously got he found that out because he was trying to order
00:49:29 to order the seller takes to go to site so yeah i mean we've checked and i believe i'm right in saying there was a purchase order in may 2015 and then um some indication in one of the ryden
00:49:41 um some indication in one of the ryden statements that some k-15 was authorized later that year as well in october right 2015.
00:49:48 2015. um sounds right so we're still a little bit unclear about the history of this was it your understanding that k-15 had to be ordered on more than one occasion
00:50:00 ordered on more than one occasion because of an interruption with the celetex supply chain i could tell you no more than i've just told you okay when ben was saying he was really unhappy and that he wasn't going to get
00:50:12 unhappy and that he wasn't going to get the celetex was anybody else in the office at the same time
00:50:17 same time it was a relatively open office yeah i couldn't
00:50:21 couldn't honestly say who was there but it wasn't just me and ben can you help us as to whether any assessments or investigations happened at that point about the compliance of
00:50:32 at that point about the compliance of the k-15 for use on the grenfell project i wouldn't know about that you can't help us with that
00:50:44 we know that and we saw earlier that rockwool duo slab mineral wool insulation product had been used on previous harley projects including
00:50:54 including ferrier point were you ever involved in any discussions about um rockwool and why a different insulation product was being used for mineral wool on the grenfell project um
00:51:07 on the grenfell project um i think at the time when dan was doing the thermal calculations um it may have been mentioned that rockport wouldn't be used um because of the um the maximum zone we
00:51:19 um because of the um the maximum zone we had to
00:51:20 had to um fill um so which is why we were going with the um rigid insulation i see but that was the only time that came up as far as you were aware
00:51:31 as far as you were aware yeah and it's only a comment in passing yeah
00:51:34 yeah can we go back now to the harley specification for the product for the project sorry ryd3046822 which we looked at not that long ago
00:51:53 and we can see that um this document we saw earlier the document was revised a number of times and and when we get to the window infill panels we'll look at some of the revisions
00:52:07 can you help us as to why the insulation behind the rain screen cassettes is never outlined in these specification notes
00:52:17 notes right well that's clearly an oversight but i think the reason it didn't go on there in the first place is because um thermal calculations were still being done yeah so the final thickness and
00:52:29 yeah so the final thickness and composition had not been agreed and then i obviously produced this and it it slipped under the net it never ended up on the drawing i see so you think it was an oversight rather than a deliberate decision
00:52:41 rather than a deliberate decision not to include it in this oh basically yeah definitely an oversight and i don't think anyone was unclear as to the material that was being used
00:52:50 whose responsibility would it have been to have picked up that the insulation wasn't
00:52:56 wasn't in these specification notes do you think
00:53:01 think um it was my responsibility to put it on there
00:53:04 there um and then you would expect the team to pick it up and maybe even the architect
00:53:11 but as i said as it was an oversight and everyone knew the material that was being used i don't think there was any uh
00:53:19 uh any concerns there yeah you see when this
00:53:22 this document is is used subsequently and i appreciate you weren't involved in this for example sent to building control right wouldn't have told them what the insulation product was no but i
00:53:35 what the insulation product was no but i would guess um data sheets would have been issued would they not well i think you're guessing at that yeah stop there can you also help us if you go um
00:53:47 can you also help us if you go um within the same document to some of the drawings that are attached to it if we look for example at page four um where you've drawn the insulation
00:54:00 um where you've drawn the insulation you've used that wriggly line yeah um do you agree that that is known in some quarters as a symbol
00:54:11 quarters as a symbol for mineral wool insulation no it's a generic um a generic hatch pattern for insulin insulation so you don't agree that we don't accept that that's telling
00:54:24 that we don't accept that that's telling you a bit more than that that it's telling you it's a mineral wool insulation no no i don't think anyone read that assuming that was mineral
00:54:36 if we look at a drawing from ferrier point if we can go to sca402678
00:54:50 this is a drawing from ferrier point sorry it's on its side ah that's great yeah so this is a previous harley project
00:55:04 um we know you sent some details of this project right at the very beginning the point i want to discuss with you is here on this drawing which is a pretty detailed
00:55:16 drawing which is a pretty detailed drawing and it's a one in two drawing yes yeah we do get the the the type of insulation labeled on the drawing two layers of 100 millimeter rockwool duo slab rigid insulation
00:55:28 rockwool duo slab rigid insulation that's correct yeah now can you help us as to why for example we see that on the farrier point drawings
00:55:35 drawings but we can't see in any of the harley drawings for grenfell any label identifying the insulation by name
00:55:45 the materials would all be listed on the drawing 100.
00:55:51 on the drawing 100 yeah the specification drawing we were looking at just before this but i think you accepted that the insulation wasn't there was it as an oversight yeah that's an oversight
00:56:02 oversight yeah that's an oversight i see so but but not only do we not see it listed in the specification notes we we can't ever see any labels in any of the grenfell drawings correct me if i'm
00:56:14 the grenfell drawings correct me if i'm wrong
00:56:15 wrong where you have indicated in a label what the nature of the insulation was yeah now quite often on well on virtually every job actually we tend to label as little as possible
00:56:29 we tend to label as little as possible um because if there are changes then you have to change every single drawing rather than change one drawing so if if the architect says okay we're not using celotex we're using kingspan
00:56:41 not using celotex we're using kingspan yeah i would have to change every single drawing i see as opposed to just one drawing yeah i see so what you're saying is it's that key it's that specification list that tells you for example it's
00:56:53 list that tells you for example it's rainable
00:56:54 rainable panels and it should have told us that it was rs 5000 celatex insulation that's your guide to the rest of the drawing that's correct yeah
00:57:06 and you can't help us as to why someone's done something different here at ferrier point by actually labeling the insulation different draftsmen different ways they work yeah
00:57:17 cavity barriers we can move to that subject now okay
00:57:23 at the time of the grenfell project were you aware of building regulation functional requirement b34 that the building should be designed and constructed so that the unseen
00:57:34 and constructed so that the unseen spread of fire and smoke within concealed spaces in its structure and fabric is inhibited were you aware of that
00:57:40 that that's correct yeah yeah
00:57:43 what was your understanding of the distinction between a cavity barrier and a fire stop a fire stop goes on the inside of the building the cavity barrier goes in the external cavity
00:57:54 external cavity right
00:57:58 if we can look at um approved document b this is clg-50224 and pick it up on page 82.
00:58:11 here we've got oh sorry
00:58:28 so this is section nine and we looked before at section 12 of adb but um we see cavity barriers are dealt with
00:58:37 with in detail in section nine is that correct agb were you aware of that at the time of the grenfell project yes yeah and we see in 9.1 that there's a general warning about
00:58:49 that there's a general warning about concealed spaces and cavities and in the final sentence it says as any spread is concealed it presents a greater danger than would a more obvious weakness in the fabric of the building
00:59:00 the fabric of the building yes yeah and then it says provisions for cavity barriers are given below for specified locations and we get diagram
00:59:07 diagram 33 of adb
00:59:12 33 of adb can we just have a look at that there do you agree with me that diagram 33 is clear that window openings should be closed with cavity barriers
00:59:25 should be closed with cavity barriers in this instance it is yes when you say in this instance it is what does that mean well this is a multi-purpose diagram yeah i think when you first read this as
00:59:36 yeah i think when you first read this as it's in
00:59:36 it's in section b3 that applies to internal flow spread of flame so i would look at that and see that as being a cavity washing
00:59:47 and see that as being a cavity washing cavity barriers required between the skins of brickwork right okay when you get to b4 it does refer back to this
00:59:58 it does refer back to this this diagram yes and i think the diagram could be far clearer if it's really to apply to external spread
01:00:09 i see but why can't we extrapolate i appreciate this seems to be a standard masonry wool type construction in this diagram but why can't we extrapolate out from this into a rain screen construction
01:00:22 into a rain screen construction and just looking at the window detailing
01:00:26 isn't it quite easy to transpose those little gray cavity barrier lines below and above the window into the cavity
01:00:35 cavity we have in a rain screen yes yeah yeah
01:00:43 did you consider at the time of your work on the grenfell project that diagram
01:00:46 diagram 33 would have some application to the work you were doing um yes to a degree yes yeah and if we can look at
01:00:57 can look at um paragraph 9.3 of adb which i think is on the next page 83
01:01:06 at the top of that page under junctions and cavity closures it says at 9.3 cavity barriers should be provided to close the edges of cavities including around openings do
01:01:18 cavities including around openings do you see that there yes yeah again i put this to mr anchor james i want to put it to you it couldn't be clearer could it certainly in this part that cavity barriers needed to be provided around openings
01:01:29 around openings that's correct yeah yeah
01:01:35 prior to starting on the grenfell project was that your understanding i understood the basic position that cavity barriers should be provided around window openings yes there's one route to compliance yes
01:01:48 yes there's one route to compliance yes when you say as one route to compliance what does that mean there are many routes to compliance
01:01:54 does that mean that you could get a fire engineered solution by a fire engineer which designs your external wall in a way that's different to adb but
01:02:05 in a way that's different to adb but still meets the functional requirements of the building regulations definitely yeah
01:02:10 yeah on the grenfell project
01:02:14 did you think that you were following approved document b and the main guidance that you had or did you think there had been a holistic fire engineered approach to
01:02:25 a holistic fire engineered approach to that external wall i didn't give it a vast amount of thought
01:02:30 thought but i did know that the architect was was backed up with a fire engineer i see so are you saying that you we followed the architect's advice yes i
01:02:42 we followed the architect's advice yes i appreciate that but are you saying that you did
01:02:44 you did think that there might well be a fire engineered approach for grenfell yes we'll look at it in a minute we know that when you
01:02:55 that when you talk about in paragraph 50 of your statement
01:02:59 statement the research you did on cavity barriers when you were looking for assistance about their rating yes you did consult adb yes would suggest to you that that might
01:03:10 would suggest to you that that might indicate that you did think adb was applicable and that there wasn't a special fire engineered solution i was getting very little feedback from the rest of the team and
01:03:21 feedback from the rest of the team and that is my only real point of um point of call to research from the adb yeah were you ever told in terms
01:03:33 yeah were you ever told in terms by the way we're not following adb we've got our own design here it's different don't worry about it were you ever told that no no i was always told to follow the architect's drawings
01:03:45 architect's drawings i see
01:03:48 did you think that there might be any difficulties complying with diagram 33 and section 9 on cavity barriers on the grenfell project
01:03:59 project um any difficulties in what way we'll take windows yes did you ever consider that what you were doing at grenfell made it difficult for you to
01:04:11 grenfell made it difficult for you to comply with the requirement for cavity barriers around windows yes because of the shape of the cladding wasn't a simple way of sealing the perimeter adequately
01:04:25 way of sealing the perimeter adequately was it your objective to seal the perimeter of the windows is that what you set out to do no not at all because the architect's drawings didn't show that right so it's quite clear because of the
01:04:37 right so it's quite clear because of the design of the building it wasn't a simple solution so one would imagine that the architect had taken steps to consider another solution this may well have been a fire engineered solution
01:04:48 a fire engineered solution right did you ever query expressly with the architect and say can you just help us are we putting cavity barriers around the windows and if so where did you ever have that conversation with them
01:04:59 conversation with them not specifically no no but it was raised internally and we did start various email trials on that
01:05:09 that now let's look at what studio e's drawings
01:05:14 drawings showed in terms of cavity barriers um just before we do that i just want to look at paragraph 19 of your witness statement
01:05:23 har3010419 at page four
01:05:28 in paragraph 19 you say in terms of the studio e drawings i was sent i believe i would have paid most attention to the following drawings and you list out a number of drawings
01:05:39 you list out a number of drawings yes and at h we see detail section sheet 10127906 1200 yeah and at n over the page
01:05:53 n over the page we get
01:05:56 their proposed typical bay plans section and elevation it's a drawing we will go to and we've looked at a number of times one two seven
01:06:04 seven nine zero six one one oh zero zero yeah um
01:06:10 yeah um and you go on to say in paragraph 20 that the key aspects of the external facade design came from studio e drawing one two seven
01:06:21 came from studio e drawing one two seven nine zero
01:06:21 nine zero six one one oh revision zero zero so the one you've got in item m yes
01:06:29 so that was a pretty important drawing wasn't it intentionally seriously 110 and 120 i remember them yeah yeah yeah and you pay particular attention to those drawings when you were doing your work
01:06:41 drawings when you were doing your work yes yeah
01:06:46 yes yeah can we then turn to the drawing 110 this is at
01:06:51 is at sca402499 and we will need the offline
01:06:58 version
01:07:22 great yes that's it and i want to look at the proposed section in the right hand top corner first the proposed section typical bay
01:07:33 if we can zoom in on that yes that's can you read that okay yes yes and if we look four labels down on the right we see ensure horizontal and
01:07:44 right we see ensure horizontal and vertical cavity barriers meet tightly and it's referring back p10 435 that'll be a reference back to the mbs specification won't it yes yeah yeah and we can see
01:07:55 yes yeah yeah and we can see a little hatched rectangle and it's immediately at the head of the window isn't it
01:07:59 isn't it that's correct yeah yeah
01:08:03 and we can also see that replicated at the bottom of that section as well one label up yeah so the head of the next window down at the head of the next window exactly and then if we go if we now pan out
01:08:17 and then if we go if we now pan out and i want to go
01:08:20 to the proposed plan window level at the bottom left
01:08:30 yes it actually doesn't matter whether you take which test sketch you take because i think that the sill level and window level we get the same detail what we see here on the very left is a detailing for the column
01:08:42 detailing for the column and the very bottom label cavity fire barrier in line with compartment wall structure leave no gap to cladding correct we've got a hatched rectangle kind of in the middle of that
01:08:53 kind of in the middle of that part of the column
01:08:57 um so you were clear that you needed a cavity barrier there yes that's right yeah
01:09:01 yeah but then right at the jamb of the window where the column meets the the window jam do you see that there is a
01:09:09 is a another little hatched area yeah it's not a a rectangle it's a more irregular shape yeah now
01:09:21 yeah now my question is when you looked at these drawings did you interpret that to be a cavity barrier down the window jams
01:09:29 jams not at all why not it's shown on the detail
01:09:33 detail above and that's not beside window
01:09:39 if you look at detail one above yeah it pays down a little bit yeah so we go you mean to go to the sill level
01:09:47 level that's right yeah let's go up to that
01:09:55 do we not see an area of hatching at that point as well yes but if it was a cavity barrier to go around the perimeter of the window yeah there is no window in that detail
01:10:07 yeah there is no window in that detail is that yeah when our expert looked at this drawing he was not clear whether a cavity barrier was marked there um did you ever think to go back to the architect and
01:10:18 architect and check and query and ask whether at that window jam position there ought to be a cavity barrier no we did discuss it at harley
01:10:29 did discuss it at harley in one of our round table meetings but if it was to go around the window then he would have shown another one at the base of the window as well so what did you think it showed i think
01:10:41 so what did you think it showed i think it's just him showing that there's another type of insulation pushed right into the the groove where the um the concrete spandrel panel comes across couldn't that have been compressible
01:10:52 couldn't that have been compressible insulation in gaps potentially mineral wool
01:10:56 wool which was intended to act as a cavity barrier in that location um he seems to have labeled everything else i don't uh if it was something different from everything else i would expect
01:11:08 everything else i would expect that that labeled do you agree there does seem to be different size hatching in that area so something
01:11:16 something seems to be a little bit different in that area from what's shown in the spandrels and on the column more generally
01:11:25 generally um yes yeah now you said you did discuss that in harley
01:11:32 harley but you concluded that if the architect had wanted cavity barriers around the window they would have shown it at sil level yes right yes who did you have that discussion with um
01:11:44 who did you have that discussion with um certainly with ray maybe ben i don't know if dan was in that one
01:11:53 and can you help us as to when how far into the project was it that you had that discussion
01:12:01 um it was at the point that we were laying out the cavity barriers so that was a little bit later march 2015 we see some discussion about maybe
01:12:12 we see some discussion about maybe yeah maybe a little yeah probably a little bit before then but so yeah i see and had many conversations before we started these email trials and did nobody say during that
01:12:23 and did nobody say during that discussion well why don't we check with the architects why don't we raise this expressly with them and and get them to confirm harley are my client and i was taking instructions from harley yeah that wasn't my question
01:12:37 yeah that wasn't my question did nobody say during that discussion why don't we check with the architects was that not raised as a possible way of resolving this uh i don't recall what was said but it wouldn't have been my place to actually
01:12:48 wouldn't have been my place to actually do that anyway did you get the impression i'm sorry you say that but um you were uh translating the architect's drawings
01:13:00 translating the architect's drawings into fabrication drawings correct those terms so you needed to understand yourself what was shown on the architect's drawings didn't you correct correct but um obviously everything that
01:13:12 correct but um obviously everything that harley told me to do would supersede that i mean by the same argument you could say these drawings actually show uh face fitted panels
01:13:23 fitted panels um which we didn't do there was obviously a certain level of agreements between harley ryden architect yeah but i'm sorry to press you on this but i mean it sounds from what you've
01:13:34 but i mean it sounds from what you've told us already that there was some debate within harley to which you were a party as to what these drawings did actually show yeah and uh you didn't think it
01:13:47 yeah and uh you didn't think it appropriate to say well i i really need to hear from the architect so i can do the right sort of drawing um no no i didn't i was i was happy with advice from harley even though they
01:14:00 with advice from harley even though they hadn't done the drawings yes yeah they were cladding specialists they obviously felt that it wasn't necessary
01:14:10 necessary yeah or they'd had discussions i don't know yeah all right thank you yes it's strange
01:14:18 you knew though didn't you i think you've confirmed that in general terms you knew there's a requirement for cavity barriers around windows you knew that
01:14:24 that that's for the project and you've also confirmed
01:14:27 confirmed and i took you to lots of the guidance that
01:14:31 that you knew how important cavity barriers were
01:14:34 were in terms of preventing unseen fast bread correct yeah they're not they're not an insignificant detail are they they're not an aesthetic point
01:14:44 point they are potentially relevant to life safety correct yeah
01:14:50 did you get the impression at the meeting during the discussion that it was more convenient for harley not to install cavity barriers around the windows because actually it was quite a fiddly
01:15:01 quite a fiddly difficult thing to get right and that they were looking for a way of deciding that they didn't have to provide them around the windows
01:15:12 provide them around the windows no that's not definitely not the way they would operate so give us a sense of the the nature of the discussion how did it go can you
01:15:23 go can you help us anymore
01:15:28 it's an awful long time ago
01:15:34 was anybody within harley advocating for cavity barriers around the window was there an actual debate and a difference of view or was everybody agreed that simply because they weren't shown at sil level
01:15:45 they weren't shown at sil level you could conclude that they weren't required around the windows now i think they're not um if they were required around the windows we would have two cavity barriers or
01:15:57 we would have two cavity barriers or we'd have three cavity barriers in each of those voids and the architect only shows one sorry on the vertical section these are the plan sections
01:16:09 sorry just explain that again if they were quite around the windows if you move to the right hand at the drawing yeah
01:16:21 at the drawing yeah and if we can go uh that's it so that the top detail section three yes yeah shows only one cavity barrier in each of the um cladding zones
01:16:34 in each of the um cladding zones yes but that's a section it's not clear that that's a section which interfaces with a column is it that could be a section anywhere across the window and what that's telling you is in that
01:16:46 and what that's telling you is in that location you need one at the head but why does that tell you anything about i appreciate that tells you something about the sill yeah why does that tell you anything about the jam
01:16:57 about the jam because this is all interrelated isn't it the window is the full width between columns
01:17:04 so that cavity barrier hits the column but you've got a label ensure horizontal and vertical cavity barriers meet tightly so you know there's a vertical cavity barrier
01:17:16 there's a vertical cavity barrier needed to meet tightly with that one yes and it shows it on the on the other two details going up on the slant
01:17:23 slant up the side of the column but how did you know that the other little irregular hatched area might not be a vertical cavity barrier which was meant to meet tightly with the one at the head of the window
01:17:38 but it goes against if the architect was considering cavity barriers to go around the windows and cavity barriers in the voids
01:17:49 and cavity barriers in the voids as shown on diagram 33 we should be looking at three cavity barriers
01:17:57 barriers on this drawing
01:18:01 we're not i see i wouldn't expect the architect to expect you to have cavity barriers up the sides
01:18:10 the sides yeah and not across the the bottom and middle of the zone but just going back to the discussion you had within harley was nobody saying yes but we know from adb and we know
01:18:23 yes but we know from adb and we know from other guidance there's lots of guidance out there it's all very clear that cavity barriers are required around windows so let's go back to the architect and check that because we know these are really important
01:18:34 important well i mean by virtue of following his drawings we produced our drawings and he's approved them you can expect that he's um he's happy that there is conformance
01:18:47 he's happy that there is conformance but for a detail that's that important it's important in terms of life safety external fire spread internal fast spread
01:18:56 spread breaking out into the cavities why wouldn't you want that expressly flagged and considered carefully by all the design team
01:19:08 my superior my my client gave me confidence to do exactly what i did
01:19:15 did which was to follow the architect's drawings did harley tell you in terms that you did not need to provide cavity barriers around the windows
01:19:24 windows no they didn't no no they said follow the architect's drawings
01:19:30 so was it in fact your interpretation of the studio e drawings that we ended up with or was it an instruction you were provided
01:19:39 provided via the harley meeting it's a combination of the two as i keep saying you know this this still shows items that aren't um weren't translated to the building such
01:19:51 weren't translated to the building such as face fixed um zinc rain screen panels
01:19:57 mr chairman this is a long topic um and i think this is as good as any moment for a break yes are you doing quite well yes i am um i am doing well should we say 20 to 12
01:20:08 i am doing well should we say 20 to 12 then
01:20:09 then yes thank you all right we're going to have a break there mr lam we'll come back at 20 to 12. usual rules apply please no talking to anyone
01:20:19 thank you very much
01:20:27 good thank you 2012 please
01:40:14 yes would you ask mr lam to come back in
01:40:20 please
01:40:27 all right mr lamb yep continue yes it's grange
01:40:31 grange yes can we have back on the screen that studio e
01:40:34 studio e drawing set of drawings that we were looking at sca402499 in the native
01:40:48 version
01:40:55 yes and i want to put to your number of points about this would you agree that when you look at this and the level of detail we have here that it was obvious that these are very early drawings done
01:41:07 that these are very early drawings done by an architect giving an indication of the external wall they're not detailed drawings and that it would have been obvious to you and to harley that your job was to be developing this
01:41:19 that your job was to be developing this design to take it to the next stage and that that might well include developing the design of the cavity barriers
01:41:27 barriers i don't think i agree with that i think they are quite detailed as far as an architect's drawing is concerned they may not be at a suitable scale
01:41:38 they may not be at a suitable scale but with um being able to zoom in electronically i think it tells you most things that are required so we know that the nbs specification identified say the cwct
01:41:49 cwct standard yes had to be complied with we know that there's reference to fire breaks in accordance with the building regulations can you help us as to why you and harley
01:42:01 can you help us as to why you and harley didn't understand that in terms of the cavity barrier strategy your job was to take this but to take it to the next level develop the design
01:42:12 design and develop it in a way that was compliant
01:42:15 compliant with approved document b and other industry guidance at the time all of which was clear that cavity barriers were required around the windows it wasn't my understanding that that was what we were doing
01:42:26 what we were doing and how did you attain that understanding that that wasn't what you were doing because i was told to follow these drawings and follow the arc the advice from harley
01:42:39 the the hatched solid the hatched area on these drawings down the side if we can zoom into that again at the proposed plan sill level or indeed the proposed plan window level
01:42:59 would you agree that the kind of hatching that you have there the type of hatching
01:43:03 hatching is indicative of a solid material in that location is that telling you it's it's the same hatching as the insulation that goes around the front of
01:43:14 insulation that goes around the front of the column
01:43:17 but it's not is it it's tighter it's smaller
01:43:20 smaller and it's in a different orientation yes yeah yeah
01:43:25 yeah yeah and the point i'm putting to you is that that would have indicated to you that potentially down that um interface between the column and the spandrel down the sides of the windows there should have been a solid down that
01:43:37 there should have been a solid down that side
01:43:38 side well i don't understand what the architect is showing there i don't think it's obvious that it's a cavity barrier to go around the windows because the other details don't um
01:43:49 because the other details don't um don't back that story up um so maybe it needed more clarity okay can i just ask you this um because it goes to the question of
01:44:00 um because it goes to the question of how detailed the drawings are yes if you look at the um what we currently got on the screen the bottom left-hand drawing you can see what i think is a cavity barrier on the right-hand side of the column
01:44:12 on the right-hand side of the column that's right yeah now um did you understand that a cavity barrier
01:44:17 barrier was also to be introduced on the hand side
01:44:20 side so they matched no right so let's go over to the next column yeah there are no cavity barriers in the comparable position on that column no is it your understanding that there
01:44:31 no is it your understanding that there weren't to be any cavity barriers around that column um as long as the distance between cavity barriers didn't exceed um i can't recall the 10 or 20 minimum
01:44:42 um i can't recall the 10 or 20 minimum meter minimum requirement so you might expect there to be one on the third column that's not on the picture in the picture possibly if you look at the column on the left this is clearly a
01:44:54 the column on the left this is clearly a party wall column yes but the column on the right looks to me like an internal wall column exactly i think that might be the explanation to repair to mr lam i think that uh what we see on the left
01:45:09 i think that uh what we see on the left is a cavity barrier where there's a compartment wall yes it's shown vertically there and there's not one on the right and i think from memory thinking back to dr lane's report from phase 1 well the explanation
01:45:20 report from phase 1 well the explanation then
01:45:21 then um i think that wasn't something she was criticizing the lack of vertical cavity barriers
01:45:26 barriers down that column but what we are seeing on both columns mr lamb either side of the window is a more intense area of smaller hatching and
01:45:37 area of smaller hatching and um we'll keep coming back to this but um my point to you is that shouldn't that at least have prompted a line of inquiry back to
01:45:48 have prompted a line of inquiry back to the architects as to what they intended i discussed the element of cavity barriers with the technical team at harley you were told to draw as
01:46:00 you were told to draw as as we've just discussed with one vertical carry a cavity barrier and uh and a horizontal cavity barrier as shown in the other detail
01:46:09 detail and is it right that is it your evidence that at the time you had those discussions you were aware that this was a departure from the guidance given an approved document b which requires cavity
01:46:20 document b which requires cavity barriers around window openings loosely but i was also aware that there are other routes to compliance fire engineered solution if you were even loosely
01:46:31 even loosely aware that this was a departure from approved document b wasn't the common sense approach to ask for a clear instruction either from harley or from studio e or
01:46:42 either from harley or from studio e or both
01:46:43 both uh making clear whether or not cavity barriers were required around the windows
01:46:48 windows i asked harley what to do and i did exactly what they told me to do okay let's keep going um i now want to turn to the other drawing
01:47:00 i now want to turn to the other drawing that you said in your witness statement was a key drawing that you were interpreting and turning into your more detailed drawings this is drawing 120 and if we go
01:47:11 120 and if we go har three zeros 104 to four yeah
01:47:21 and if we look on the right hand side
01:47:27 we can see um this is before between floors 19 and 20. yeah do you see that there and this also shows a hatched cavity
01:47:40 and this also shows a hatched cavity barrier immediately above the head of the window correct do you see that there
01:47:46 and i believe if we pan out
01:47:54 so on the left hand side we believe we found some hatching [Music]
01:48:12 so right at the top of the page yeah horizontal cavity barrier to seal both rain screen cavity and cavity between cm board and existing concrete
01:48:23 between cm board and existing concrete structure do you see that there yes what location is that in there can you help us can we just see the top of the entire top of the drawing
01:48:35 i mean that's at the walkway level yeah which
01:48:38 which um would be is that second floor first or second floor
01:48:46 floor and we can see a hatching immediately above the
01:48:49 above the the head of the window yes on that one yes yeah
01:48:53 yeah now if you were merely transposing across
01:49:05 if you were merely transposing across what was shown in these drawings over to your drawings yes do you accept that you would have maintained the positioning of these cavity barriers as shown in these drawings
01:49:17 shown in these drawings um as close as possible yes i see okay we'll look at that in a moment when we come to your drawings um let's look at your witness statement at this point
01:49:28 at this point if we go har10419
01:49:34 page 12 paragraph 44 you tell us there that the cavity barriers were ciderised lamitham
01:49:47 barriers were ciderised lamitham the vertical cavity barriers were cylorized lamithm rvg supplied in stock slabs and cut suit on site
01:49:54 site the horizontal cavity barriers were sideways lamitham rh 25g ventilated intumescent character cavity barriers and were cut pre-cut
01:50:05 cavity barriers and were cut pre-cut oversized by sideres and trimmed to suit on site did you see that there yes and who was it that specified the cider eyes lambeth product as appropriate cavity barriers
01:50:17 product as appropriate cavity barriers for this project can you help us on that yes i was told by harley that that was a product we'd be using did you or to your knowledge anybody else within harley
01:50:28 anybody else within harley ever make any investigations with siderise as to whether these cavity barriers
01:50:31 barriers had been tested in a rain screen system no or not certainly from my point of view i didn't i don't know if anyone else had that was not something that occurred to you to
01:50:43 not something that occurred to you to check
01:50:43 check no
01:50:50 and the horizontal clarity barriers had an intumescent strip is that correct that's correct what was your understanding of the purpose of the intumescent strip um the intermediate strip would expand
01:51:02 um the intermediate strip would expand when heat
01:51:03 when heat was in the cavity to close the the compartment off so flame and air could not travel and your understanding was that that would work it with a aluminium composite
01:51:14 would work it with a aluminium composite material
01:51:15 material panel on the outside of the barrier i wasn't considering the material on the outside
01:51:21 outside but certainly i was aware this is how cavity barriers works yes yeah now
01:51:28 yeah now i want to look at what was being said during the project about cavity barriers let's
01:51:33 let's turn to sca 3011703
01:51:45 this is where daniel anchored jones on the 17th of september 2014 raises an rfi which did you understand that to me in a request for information
01:51:56 that to me in a request for information yes yes um with simon lawrence simon o'connor neil crawford bruce soon so with ryden and and studio e c seeing you in your cc'd
01:52:09 and studio e c seeing you in your cc'd at this point and he says please find attached rfi zero zero one which relates to requirement of fire breaks this may be something that has already been decided or may need confirmation from the local fire officer as the
01:52:21 from the local fire officer as the the opinion tends to vary do you see that there yeah can you recall what prompted daniel at this point to raise this question at this point many points through the project we discussed cavity
01:52:33 through the project we discussed cavity barriers
01:52:34 barriers um and it may have been one of those discussions that prompted him to um seek clarification so just to be clear you had many discussions with mr anchorator jones about cavity barriers
01:52:45 anchorator jones about cavity barriers generally
01:52:46 generally general members of the team including mr anchored closing down yes yeah
01:52:52 yeah let's look at the rfi itself
01:52:56 two nine exo401291
01:53:15 so here we can see the rfi date of the 17th of september 2014. query
01:53:22 query please may you confirm the required extent of the horizontal fire breaks within the cladding areas we believe that they will be required at every floor level on the vertical columns
01:53:33 columns but not in the area of cladding between windows this is because there's no chimney effect here and therefore the cladding will not add to the spread of fire
01:53:40 fire do you see that there yes so just to be absolutely clear am i right that this request was a specific request about the extent of horizontal
01:53:51 about the extent of horizontal fire breaks on the columns yeah and not specifically at the columns we believe we required every floor on
01:54:02 we believe we required every floor on the vertical columns but not in the area is what's being said that we think that on the columns we need to put horizontal fire breaks at floor level but we don't
01:54:14 fire breaks at floor level but we don't need to put horizontal fire breaks across the columns in the areas between windows because there's no chimney effect there that's how it reads yes
01:54:27 can you help us with what your understanding was at the time of the query that was being raised i wouldn't have read the signal i would have paid little store to the suggested solution
01:54:37 solution i would be waiting for a a confirmation from the
01:54:41 from the architect um or in this case ryden's it looks like would you agree with me that the question isn't do we have to put cavity barriers around windows at the
01:54:52 cavity barriers around windows at the head sill and jam of the windows correct yeah
01:54:59 do you remember whether there'd been any consideration by you or within harley of the relevant guidance you've referred we know at paragraph 50 of your witness
01:55:10 know at paragraph 50 of your witness statement to a number of pieces of guidance including adb and cwct guidance that you consulted at the time of wanting help um on the rating of the cavity barriers
01:55:23 um on the rating of the cavity barriers um do you recall whether at this stage this is earlier 17 september 2014 there had been any consideration of the the guidance at this point
01:55:35 this point um certainly not from myself yeah and you weren't aware that anyone else within harley had had a look at the relevant guidance i wouldn't know
01:55:49 when he talks about the risk of a chimney effect in the columns no no chimney effect here he's not talking about the chimney effect in the columns i think he's talking about
01:56:00 columns i think he's talking about it between the windows isn't he is that how you interpret this well miss grange i did wonder whether this um
01:56:08 this um whether the question in the box-headed query isn't directed to cladding areas in general so that he's saying that we've got to put them in at every floor level of the
01:56:19 put them in at every floor level of the vertical columns but not in the area of the spandrels that is
01:56:24 that is that is possible can you help us with that mr lam well i agree exactly with what you say yes right
01:56:32 so you're saying there's no chimney effect there because i'm not it's not on the column sorry he's saying that yeah so are you saying that this hadn't this wasn't a discussion you had with mr
01:56:43 wasn't a discussion you had with mr anchoral jones which then led to this rfi no no so it didn't come from you okay
01:56:54 now can we turn now to har408902
01:57:12 this is a column front nose detail yeah do you agree yes yes um we can see it went through a number of revisions and we can see that on the 25th of march 2015.
01:57:25 of march 2015. sorry i apologize we actually see it revision a on the 22nd of august 2014 at the bottom of there that the fire break was added is that right no
01:57:36 fire break was added is that right no no front bracket added we've then got firebreak increase at revision d if we can pan out
01:57:49 if we can just pan out and see the whole section
01:57:52 section so does that mean you've changed the dimension of the cavity barrier in revision d that's correct different ratings of cavity barrier will have different thicknesses
01:58:04 have different thicknesses yeah so at this point i must have been informed
01:58:07 informed that we'll be using whatever rating and i've um yeah on the drawing accordingly and we can see you've got that cavity barrier down the right hand side of the column correct nothing on the left-hand side
01:58:19 correct nothing on the left-hand side side
01:58:20 side did anyone ever give any consideration to whether a cavity barrier might be necessary
01:58:26 necessary on that very front nose joint was that ever discussed not at all and that wasn't something that occurred to you in terms of a potential chimney
01:58:37 to you in terms of a potential chimney effect
01:58:37 effect up that column nose no you wouldn't normally put cavity barriers behind the um the joints or else we'd have them on every single joint on the cladding
01:58:48 joint on the cladding well i think we're talking about that specific gap that we see at the front um between the two returns of the panels at the bottom whether there should have been a cavity
01:58:59 whether there should have been a cavity barrier in there or at least thought given to a cavity barrier in there given the potential for fire to propagate up that gap um not in my experience you wouldn't
01:59:10 gap um not in my experience you wouldn't normally
01:59:12 [Applause] okay
01:59:17 okay and just to be clear the guidance that you say you specifically considered on cavity barriers did that come later in 2015 when there was a separate
01:59:28 in 2015 when there was a separate discussion about rating of cavity barriers
01:59:31 barriers yeah someone said so yeah and far stopping versus cavity barriers yes are you clear that you weren't consulting the guidance at this point in september 14. don't forget i was only consulting the guidance for a little bit of help
01:59:43 guidance for a little bit of help which wasn't forthcoming right yeah
01:59:56 can we now turn to har40s 3638
02:00:12 can we now turn to har40s 3638 and this is an email chain between neil crawford of studio e and terry ashton at x over into which you and a number of other professionals were copied arising out of
02:00:24 professionals were copied arising out of that rfi
02:00:26 that rfi and i want to look at on page four on the on the 18th of september 2014 at 1108
02:00:37 there the rfi is sent to terry ashton by neil crawford we can see that and then if we go up to page three at the foot of page three
02:00:51 terry ashton responds at 11 33
02:00:56 and requests further details do you see he says neil i've never seen details of what you're doing to the external walls do you have any cross-sections elevations yeah and then we can see these are sent
02:01:09 yeah and then we can see these are sent to him by neil crawford at 12 18 in the middle of page three please see us attached our sections and the initial drawing set we have had from
02:01:20 the initial drawing set we have had from harley's the initial drawings from harley's are fairly limited but they attempt to establish the basic approach
02:01:29 now is it right that at this time so this is september 14 the thinking behind cavity barriers was relatively undeveloped within harley um i'd have to consult those particular
02:01:41 um i'd have to consult those particular drawings but um okay well we might we might come back to that you say in your witness statement if we can look
02:01:52 in your witness statement if we can look at this paragraph 33 this is har3010419 at page nine
02:02:03 you say this at the top of that paragraph in relation to the cavity barriers they were not items that needed to be dealt with immediately as they did not have lengthy lead-in times as the shelf angles sill
02:02:14 lead-in times as the shelf angles sill and head details and cladding panels did you see that there yes and i think you alluded to it this yesterday is it fair to say that the cavity barriers were not the design priority because in terms of the supply
02:02:27 priority because in terms of the supply chain
02:02:27 chain they were going to take less time to obtain correct yes
02:02:34 were cavity barriers added as an afterthought on this project no not at all
02:02:41 how early in the design process do you think you were considering cavity barriers with harley um early early in 15. early in 15 yeah yeah february i guess
02:02:54 early in 15 yeah yeah february i guess because you just said that you don't think that rfi was something you were directly involved in no no so from your point of view it was in early 2015 that you began to discuss the cavity barriers with them i guess yes yeah
02:03:07 now returning to that email chain we were looking at har403638 page three and if we go the very bottom of page two and on to
02:03:19 the very bottom of page two and on to page three
02:03:22 we get a reply from mr ashton we can see the
02:03:25 the start of that at the very bottom of the page after he's been provided with details and he says this at the top of the next page neil if the insulation and the cavities
02:03:36 neil if the insulation and the cavities behind the rain screen cladding is combustible you will need to provide cavity barriers as shown on your drawing number one two seven nine zero six one twenty in order to prevent fire from spreading
02:03:47 order to prevent fire from spreading from one flat to the one above even if there isn't a continuous cavity from the top to the bottom of the building okay do you see that there yeah
02:03:58 and then one email up this advice gets forwarded to you from mr crawford at 15 50. yeah you're there
02:04:10 50. yeah you're there he's he's his main email is there to daniel anchored or james but you are copied in
02:04:14 copied in yes please be the correspondence relating to this and we can see mr anchor jones's response
02:04:22 response above that and he says neil thank you for your response the insulation is class naught therefore reading
02:04:29 reading after reading the correspondence below i believe that the fiber area in these locations will not be necessary can you confirm that this is acceptable kind regards daniel you see that there yeah and he also attached at this time
02:04:42 yeah and he also attached at this time the celetex rs 5000 data sheet okay
02:04:49 did you read that comment by mr anchor jones as meaning that because the insulation was class naught it was non-combustible i didn't have any
02:05:00 it was non-combustible i didn't have any um
02:05:01 um any thoughts on his discussion regards insulation however i didn't believe that there was no requirement for fire barriers i always believed that there should be a
02:05:12 i always believed that there should be a fire barrier in that zone what zone are you talking about there he's talking about um what does he say really i believe that the fire barrier in these locations will not be necessary
02:05:25 in these locations will not be necessary so i don't believe that statement yeah that it was necessary in the spandrel zones is that what you're saying
02:05:32 yes did you ever um think about that advice that was being given the insulation is class naught no not the time that wasn't something
02:05:44 no not the time that wasn't something that struck you as odd or something that ought to be checked
02:05:49 checked no no you didn't ever query whether mr anthony jones understanding was correct no no it wasn't my place to do that not unless i was concerned did you think at the time that class
02:06:00 did you think at the time that class naught was relevant to the choice of insulation product uh again no i mean i wouldn't expect flammable materials but i wasn't considering the class of
02:06:12 i wasn't considering the class of insulation there no but my question was at the time did you think that class naught was relevant to the choice of an insulation product well it should certainly be class 0 or
02:06:23 well it should certainly be class 0 or better
02:06:26 when you read diagram 40 in adb4 it's quite clear we should be using classo products
02:06:33 products as we looked at yesterday there is a difference between national class naught and
02:06:37 and a concept of limited combustibility that's correct were you aware at the time that there was a difference between class naught and limited combustibility i wasn't considering that in this case
02:06:48 i wasn't considering that in this case but were you aware at the time that there was a difference between national class naught and limited combustibility yes you were yeah what did you think that difference was um i didn't consider the difference to
02:06:59 um i didn't consider the difference to be honest as far as i was concerned class o
02:07:03 class o is a suitable material but i think you said yesterday am i right that your understanding of limited combustibility was that it was a description of a limited type of combustibility yes
02:07:15 of a limited type of combustibility yes you weren't aware that it had a very specific
02:07:17 specific technical definition by reference to specific tests no no because normally that would be prefixed by a class or a rating that's a
02:07:28 prefixed by a class or a rating that's a bit of a vague term
02:07:34 if we turn back um or if we okay we're carrying on actually with this email string and we go to a different email har four zeros sorry it is the same
02:07:45 har four zeros sorry it is the same email um if we look at the bottom of page one
02:07:50 page one of this string we get a response by mr ashton where he says a material which
02:08:01 ashton where he says a material which has a class naught rating is not necessarily non-combustible although the reverse is invariably true some class naught products will burn when exposed to a fully developed fire
02:08:12 when exposed to a fully developed fire do you see that there yes do you remember
02:08:15 remember seeing that at the time of the grenfell project um i don't know this wasn't directed at me but um i'm
02:08:26 this wasn't directed at me but um i'm sure it wasn't a historic trial um i don't think this was sent to you um but does it follow from your evidence
02:08:37 but does it follow from your evidence that you weren't made aware that this was the advice mr ashton was giving i think he's arguing with dan about the um
02:08:45 um requirement for cavity barriers yes there's
02:08:52 irrelevant point we all know we should be putting cavity barriers at every level
02:08:57 level i see i think he's trying to say to dan of course we need cavity barriers right but were you made aware of the advice that mr ashton was giving on this issue
02:09:08 that mr ashton was giving on this issue at the time not specific when you relate it to the class o
02:09:13 class o is not necessarily non-combustible did you ever
02:09:22 raise any concerns about this line of thinking at the time not at the time no but we certainly by the time we got to february march it was getting to a point
02:09:35 february march it was getting to a point where
02:09:35 where we had to get this product on the wall and it was a case of guys what on earth are we doing this sort of a document is vague we need proper clarity
02:09:49 vague we need proper clarity mr ashton in the end at the end of that paragraph is saying what isn't clear from the information to hand is whether or not there is a continuous cavity from top to bottom in any part of the cladding
02:09:58 cladding apart from around the column casings irrespective of the type of insulation do you see that there yes yeah
02:10:06 do you remember whether you were ever asked to help respond to that request for information about whether there might be a column in other parts of the cladding no
02:10:17 column in other parts of the cladding no not so dan was clearly dealing with that wasn't it
02:10:20 wasn't it so you didn't get involved in that no can we just look up to the top of this
02:10:26 chain
02:10:32 we see that mr crawford goes back to mr ashton
02:10:38 ashton and you are copied in there yeah hi terry thank you and then a question is asked of daniel can you confirm your position in relation to terry's comment below regarding combustibility and continuous
02:10:50 regarding combustibility and continuous cavity paths having just finished several weeks of fire stopping checks on the kensington aldridge academy where john hoban crawled into almost every conceivable cavity possible with a torch
02:11:00 torch including nearly falling through a suspended ceiling we need to be clear on our position before going to building control
02:11:06 control do you see that there yes now we can't find
02:11:09 find any response by daniel um confirming his position about the combustibility and continuous cavity paths do you remember ever discussing that with mr anchor jones
02:11:21 that with mr anchor jones not at all no definitely not so is your evidence that you simply didn't get involved in this discussion no i didn't or have an opinion on the points they were discussing no
02:11:36 if we go then to sca3011759
02:11:53 if we go then to sca3011759 this is an email from you a few days later
02:11:56 later after this discussion has occurred from you to simon lawrence copying in daniel ancatel jones neil crawford bruce soons so it's on the 22nd of september 2014
02:12:07 so it's on the 22nd of september 2014 yeah
02:12:08 yeah and you attach a set of drawings simon please find attached drawings as raised an issue for final approval based on the architect's comments and discussions at our last meeting
02:12:19 our last meeting yeah we shall shortly issue further details for consideration you see that there yeah and if we turn to the attached drawings themselves this is ryd50431
02:12:44 yes so there's a number of drawings in this pack and we can just scan through them here's an elevation drawing yeah do you agree with me there's no cavity barriers shown anywhere on this
02:12:56 cavity barriers shown anywhere on this elevation
02:12:57 elevation correct they tend to be shown in details and if we go down this pack i think if we just scan down
02:13:05 there's no cavity barrier there at sil level
02:13:08 level no keep go if we can keep going it's the head of the window no cavity barrier there no
02:13:17 there no that's the join with the column no cavity barrier there correct and there's no cavity barrier either sorry if we go back to that drawing
02:13:25 drawing no cavity barrier either at the interface between the window frame and the
02:13:29 the the column or or indeed in the location which you were pointing out shown on the studio e drawings further
02:13:37 further along the column that's right yes so can you just help us as to why these drawings at this stage weren't showing even though we have got some detailed drawings why were they not
02:13:49 detailed drawings why were they not showing any cavity barriers but this is only what a week or two after the
02:13:54 after the project started and we were trying to get approvals for the cladding arrangement and the windows
02:14:02 so it's envisaged at this stage was it that cavity-bearing cavity barrier detailing would be provided later correct yes
02:14:13 provided later correct yes maybe we should have said that on the email but uh but we didn't so you agree what we're seeing here is design development you're taking the studio e drawings
02:14:25 the studio e drawings which we know and we know we never got any even one in five drawings from studio e and you're turning them into something much more detailed here yes yeah
02:14:34 yeah this is a one in two drawing yes now if we can now
02:14:45 now if we can now move forward in time if we go to ryd three zeros two seven six nine two
02:15:02 you sent an email on the 14th of january to simon lawrence and other members of the design team daniel anchored jones neil at studio e neil crawford
02:15:15 neil crawford and this is i think you say in the email please find attached a full set of drawings related to the upper 20 floors of windows all now construction issue and to be manufactured accordingly
02:15:26 manufactured accordingly yeah and you say clearly the design has varied much but now all as we agreed prior to christmas and there's a large number of drawings there now had anybody from harley
02:15:38 harley such as ray bailey or daniel angel jones check those drawings before you issued them
02:15:45 them no that wasn't normal normally we would have a round table to discuss concept these drawings were all revisions so they would have been sent out to all parties to comment upon
02:15:57 parties to comment upon or consider at the same time yeah now i think what we can see is that none of these drawings contain cavity barriers let's just look at an example
02:16:08 at an example if we go to ryd3027697
02:16:28 so that's very similar to what we were just looking at isn't it yes from a drawing back in september so we're now in january 13th of january 2015
02:16:39 in january 13th of january 2015 and it's marked construction in the little table on the bottom left yeah and it's also headed um it's stamped sorry approved for construction
02:16:51 construction yeah yeah
02:16:56 and can you help us as to why there are no cavity barriers shown in these drawings including in this drawing here
02:17:08 this drawing here is the cavity barrier not off the screen on the next drawing let's have a look would it be in the next one in the run
02:17:24 is there another page to this no there isn't okay we might have to we'll check that okay um i mean we were obviously looking at it earlier won't we yeah
02:17:35 yeah we can see from the harley drawing register from the transfer the transcript the reference is ryd30656 that this drawing was never revised after the 14th of january 2015.
02:17:50 and it's right isn't it that cavity barriers were never included in that location in the middle of that page
02:17:57 page where the the side of the window meets the column yeah not in that location [Applause]
02:18:06 now despite these drawings saying approved for construction two days later on the 16th of january neil crawford emailed his comments
02:18:17 neil crawford emailed his comments um that email is sca3012531
02:18:34 s e a three zeros one two five three one yep so here neil crawford's going back to you on the 16th of january 2015
02:18:47 16th of january 2015 with others copied in hi kevin in line with our discussion over the phone comments
02:18:51 comments on drawings and if we can turn to the comments this is
02:19:04 sca403040
02:19:10 we can see so this is an elevation drawing where we've got lots of comments in red by mr crawford yeah would you agree with me that there's no mention of cavity barriers in his annotations
02:19:23 cavity barriers in his annotations correct yeah and he's circled it b conforms to design intent subject to incorporation of comments we can see that from the stamp on the right hand side yes
02:19:34 side yes now did you ever have any discussions directly with mr crawford about the location of cavity barriers in the design scheme
02:19:45 i don't know to be honest was it something you were doing on the project sometimes having discussions with mr crawford yes sometimes yeah yeah certainly at the
02:19:56 yes sometimes yeah yeah certainly at the design team meetings yeah you can't help us as to whether you ever had a discussion with mr crawford about
02:20:03 about the where cavity barriers ought to be located oh there definitely was um but um to what degree i don't recall
02:20:13 do you recall anything about those discussions what the what the topic of those discussions was when you were discussing cavity barriers with mr crawford
02:20:21 crawford no no not in depth at all i had so many discussions about cavity barriers can you recall whether you ever had a discussion with him about what the requirements were of approved document b
02:20:32 requirements were of approved document b and diagram 33 and whether that could be applied to grenfell no we would never have that sort of a
02:20:42 conversation now if we now turn on to an email from siderise so this is an har404013
02:20:55 an har404013 date of the third of march 2015
02:21:08 [Applause]
02:21:13 so this is um if you look at the top of the page an email from barnaby j carrick at siderise to you copying in mark stapley and sue shepard
02:21:24 shepard who's sue shepard uh i think she might have been at um siderise as well yeah okay and he says hi kevin we've reviewed the details you've kindly supplied and can
02:21:36 details you've kindly supplied and can confirm that they follow our recommendations as the void is less than 325 millimeter and 25 millimeter air gap is present the cavity barrier size falls within our
02:21:47 the cavity barrier size falls within our standard test data and then regarding the rvg 3030 as shown in a particular detail this also follows our recommendations
02:21:58 this also follows our recommendations the brackets for the vertical cavity barrier only need to penetrate two-thirds to three-quarters of the cavity barrier i hope this is of assistance should you have any queries please do not hesitate to contact us
02:22:09 to contact us you see that there yes so you've obviously had
02:22:14 um a conversation with um siderise by this point is that right this follows um it sounds to me like it follows
02:22:25 follows my um checking the material availability from their catalogue and i seem to recall their test data goes up to a certain void depth yeah
02:22:38 goes up to a certain void depth yeah um and i think it might be along the lines of
02:22:43 lines of um the void was actually 350 millimeters in their catalogue it says it's for 325 but it wasn't clear that it was 325
02:22:55 but it wasn't clear that it was 325 millimeter for the void rather than the product itself yeah because there's an air gap so yeah just clarification of that i see yeah i think it's clear that you'd had some discussions with him if you go to the email at the bottom of this page
02:23:07 to the email at the bottom of this page one
02:23:11 where you say to him in the previous email further to our discussions please find attached details for rain screen cladding using your rh 25g yeah rv so those are the two different types of cavity barriers
02:23:23 types of cavity barriers horizontal and vertical aren't they yes that's right
02:23:28 so um your conversation with with mr carrick
02:23:33 carrick was it solely about the the the void depth and the testing that you've just referred to or did you ask siderise any for any further advice at this stage about the cavity barriers no it was all
02:23:46 about the cavity barriers no it was all it was all prompted from how this was fixed to the wall
02:23:51 and they had at the time they didn't have any details of both products whether it was a new product to them or or what i don't know but they had limited data
02:24:04 and you say please find attached details for rain screen cladding yeah dry that do you mean the drawings yeah it would have been a couple of typical drawings did anyone from siderise um
02:24:17 did anyone from siderise um comment on the positioning of the cavity barriers in those drawings um i don't believe so and i wouldn't have expected them to unless we'd specifically ask them right
02:24:32 can we turn now to an email sent from you to simon lawrence copying in the design team on the same day so this is sea three zeros one two eight five zero
02:24:59 so this is you on the 3rd of march 2015 to simon lawrence copying in others including daniel anchorator jones neil crawford mark stapley yeah
02:25:10 mark stapley yeah ben bailey is also copied in there we see
02:25:13 see and you say simon please find attached drawings now showing the fire breaks both horizontal and vertical we assume a requirement of 90 min integrity and 30 minute insulation is
02:25:25 integrity and 30 minute insulation is sufficient if not please advise and then you say this the vertical brakes are not on all columns just party walls i think that's the point we were discussing with the chairman exactly yeah whether some columns didn't have a vertical cavity barrier correct
02:25:37 have a vertical cavity barrier correct it wasn't a longer party wall yes
02:25:44 what was it that had prompted you to include cavity barriers on these drawings
02:25:48 drawings at this stage can you remember so this is the 3rd of march 2015. i think what was prompted as we were getting close to the point of which we were going to start installing things on site
02:25:59 on site so this had to be cleared up we couldn't start hanging cladding on the building without the cavity barriers being finalized yeah so it become time critical
02:26:08 critical yes yeah
02:26:11 had you discussed cavity barriers around this time with harley had you had a round table meeting with them yes certainly before
02:26:23 and who do you remember discussing cavity barriers with before this point um earlier on would have been dan but certainly ben and ray
02:26:35 certainly ben and ray would it be fair to say that cavity barriers at this point were being included as a late amendment to drawings not at all we always knew that we were going to get to this point yeah so you wouldn't accept that this
02:26:46 yeah so you wouldn't accept that this was a relatively late stage to be adding the cavity barriers after the window design was completed and work on site had begun no not at all
02:26:56 and had you had a discussion about precisely where to put the cavity barriers before producing these documents
02:27:04 documents um well we had discussed it in the office and these were issued for for their comment and again sorry i keep trying to
02:27:11 trying to bring you down i know it's the typical round table um yeah that i would i would attend the office
02:27:17 office once a week or a fortnight and who was at that round robin discussion would vary but tim
02:27:29 had you consulted the guidance that you referred to at paragraph 50 of your witness statement adb cwct guidance had you consulted that by this stage on the project yes
02:27:41 by this stage on the project yes definitely you had
02:27:46 what did you consulted it in relation to what were you just to find clarity and there was no clarity
02:27:54 clarity i see so you're confident that before this point you've looked at it to find clarity on what the
02:28:01 what the rating of the barriers should be is that right yes i believe so yes and specifically for that purpose only yeah yeah
02:28:14 now you'd issued several drawings for the windows in january 2015 and we can see that you reissued only some of them again in march 2015. can you help us as to why you didn't
02:28:26 can you help us as to why you didn't revise all of the drawings showing windows at that point to add cavity barriers um maybe they didn't need it
02:28:36 what we see from the attachments to the email you can see them listed there is that you revised drawings 200 201 202 301 and 305. does that sound right
02:28:49 301 and 305. does that sound right um yeah that is only a couple of
02:28:55 and then i would guess that that covers the 20 floors of windows does it not well let's look at drawing this is drawing 200 sca403156
02:29:13 so here we see the elevation and now what we can see is there's dotted lines on the columns and on the spandrels
02:29:24 on the columns and on the spandrels with the label fire break yes is that correct yes that's right and those are the cavity barriers is that right
02:29:32 right is that right yeah yeah that's a generic term for cavity barriers or fire stops and we can see at the bottom in the in the table that these were added fire breaks added on the third of march 2015
02:29:43 breaks added on the third of march 2015 yeah you see that there yeah
02:29:47 why did you use the word fire break when you were referring to cavity barriers in this elevation drawing it's just a generic generic term that we often
02:29:58 generic term that we often would use would you ever use the term cavity barrier um up before grenfell i would probably not
02:30:09 up before grenfell i would probably not no no and was that because you were predominantly a curtain walling and glazing specialist so your experience prior to grenfell might have been on fire stopping but not cavity barriers
02:30:20 cavity barriers um well i don't think i would have called them fire stops either so would you have called both a fire break yes
02:30:29 break yes generically yeah and you didn't think that it was appropriate to distinguish between whether you were talking about a fire
02:30:36 fire a some fire stopping or a cavity barrier no because um i don't think there's any confusion you couldn't put a fire stop in those
02:30:47 in those locations
02:30:51 and i think it's clear to see that what we don't see if we can pan out again is we don't see cavity barriers around the sides of the windows do we no
02:31:02 the sides of the windows do we no they're at some distance away from the windows a little way yeah
02:31:08 and they're not we don't see cavity barriers specifically around the head sill or jams of the windows themselves do we no
02:31:15 do we no no we've got the one single compartment as shown on the architect's drawings do you agree that that positioning and location of cavity barriers would not prevent
02:31:25 prevent fire spreading into the cavity immediately adjacent to the windows uh not immediately adjacent though
02:31:35 so we'll look at it on the one in two drawings shortly but we've got cavities haven't we take the head of the window there there's going to be a cavity immediately above that window that's right yeah where there's a return
02:31:46 that's right yeah where there's a return of the panel immediately above it and then the fire break is now coming some distance above the head of the window yes you just want to bear in mind that this is um the location of these on this drawing is
02:31:57 the location of these on this drawing is a little bit indicative when you look at the details they're a bit close at the top of the window but just for um visual ease they've been moved away from the window slightly
02:32:09 moved away from the window slightly and i want to put it to you again why did you not when doing this drawing include cavity barriers around the window
02:32:16 window as well as any other cavity barriers in the system more generally this was the annual requirement
02:32:23 any requirement from who from harley and the architect's drawings
02:32:31 now
02:32:34 this configuration differs at the head of the window from what was shown on the studio e
02:32:40 studio e drawings doesn't it uh it does a little bit yes
02:32:44 bit yes a little bit the one we saw earlier at the head of the window by studio was immediately at the head of the window wasn't it correct yes and this is raised up
02:32:56 and this is raised up to come some way into the spandrel yeah it's as if you if you can throw up the detail above the window yeah you'll see it's close to the window without any interruptions
02:33:10 when you say close to the detail without any interruptions what do you mean without any interruptions above the window is it possible to find that drawing that shows the detail of that cavity
02:33:21 that shows the detail of that cavity barrier our drawing above the um we'll check um
02:33:28 it will make explanation far easier next one yeah it's the next drawing we're going to come to brilliant um yes let's let's do that now then yeah
02:33:37 then yeah ryd five zeroes two two oh
02:33:48 ryd five zeroes two two oh yes so this is the head of the window is that
02:33:51 that is that right that's correct yes and we can see you've added the the honeycomb cavity barrier that's right
02:33:58 right yeah into into the spandrel section yeah of this configuration and it's not immediately at the head as shown on the studio e drawings is it
02:34:09 studio e drawings is it that's correct yeah would you agree with me that that's a worsening of the cavity barrier strategy because fire sorry let me just finish my question because fire
02:34:20 question because fire has the potential to go up and into the return of the panel and into that gap before the cavity barrier um not necessarily
02:34:31 necessarily not necessarily what do you mean by that well the architect shows the position of the cavity barrier tight on top of the window yes but the window hangs down below the
02:34:42 yes but the window hangs down below the structure
02:34:44 structure so you wouldn't expect to put a cavity barrier where it can't be backed up by the concrete structure so for one you would have to put it at least at the bottom of that concrete floor
02:34:57 at the bottom of that concrete floor slab
02:34:59 slab the second thing as this is a refurbishment the concrete isn't crisp and flat and straight as it's shown on that drawing
02:35:10 drawing it's quite a deflection so the aluminium this special profile at the head of the window
02:35:16 window there would be gaps between that and the concrete
02:35:21 concrete so if it was mounted on the aluminium profile
02:35:25 profile fire could get behind the cavity barrier and you would also have to contend with the cavity barrier sealing over all the um the fixings so that appeared to be the cleanest
02:35:38 so that appeared to be the cleanest safest position why couldn't you have used compressible mineral wool in that location to create a cavity barrier at the head of the window
02:35:49 window i'm sure lots of options would be available but this this is the option that was proposed and accepted
02:35:57 i'm going to show you um a diagram from mr hyatt's report at this stage if we go to phyr 603 at page 66
02:36:13 and if we can blow up that figure
02:36:18 now what mr hyatt's done is take your drawing yeah yeah and he's indicated where in his opinion and he'll be asked about this in due course
02:36:29 about this in due course where the cavity barrier should have been if following approved document b section 9 paragraph 9.3
02:36:38 9.3 and he's put it immediately at the head of the window frame lower than where you've put it do you agree yeah that's what you're showing yes and do you agree that that was a
02:36:49 do you agree that that was a perfectly um possible thing to have done that it was buildable in in that way well as i say i think he's he's shown it too low and he's assuming
02:37:00 he's shown it too low and he's assuming um that the substrate that aluminium angle is bolted to is flat which it clearly wouldn't be just break that down why is he showing it too
02:37:11 that down why is he showing it too low i don't think he should be hanging below
02:37:15 below the concrete because the fire protection the rating of the product relies on a suitable substrate behind it but you're trying to protect the cavity
02:37:27 but you're trying to protect the cavity the
02:37:27 the the fire from entering the cavity so um
02:37:33 why wouldn't you try and put the cavity barrier immediately at the head so that the cavity is protected the fire fire in the flat can attack the back of that cavity barrier
02:37:44 that cavity barrier and i don't think they're designed to resist at that point they're designed to resist at the front or the sides so are you saying that you don't think
02:37:56 so are you saying that you don't think it would have been possible to put a cavity barrier in that location in that way as shown by mr hyde i think lifting it up very slightly would be better and then another solution would have to be added to that
02:38:07 be added to that to protect between the aluminium bracket and the concrete also let's see okay well i'm putting it to you that you should have had it lower
02:38:18 should have had it lower you should have had it immediately at the head
02:38:21 the head per the guidance around openings to help prevent fire from coming out of the window and getting into the rain screen cavity
02:38:33 well a solution was offered and it was accepted
02:38:37 just because are you disagreeing with me that it would have been possible to do what mr hyatt's saying it'd be possible to do exactly what he's shown yes yeah and that would have been in accordance
02:38:48 and that would have been in accordance with the guidance given an approved document b wouldn't it i don't believe so why don't you believe that's in accordance with the guidance because i think they've not considered the rear
02:38:58 the rear effect that cavity barrier is below the substrate so you're worried that fire might go up behind that but then it's going to hit the concrete
02:39:09 but then it's going to hit the concrete isn't it but this is what i'm saying there's a gap between the concrete and the aluminium angle
02:39:15 angle but what i'm what i'm getting at is that the product is being attacked from behind it's coming along that back edge which i don't think is appropriate why
02:39:28 which i don't think is appropriate why not
02:39:29 not it's a i mean these are mineral wool kind of blocks aren't they with an intermediate and the thickness the thickness of the um the product defines its rating yes now if that's
02:39:40 defines its rating yes now if that's hanging down in free space by 50 of its thickness yeah
02:39:45 yeah it's not exhibiting the same properties as a full thickness you mean because it would be insecure that it's not properly fixed back to the concrete no not at all not at
02:39:55 not at all the flame is attacking that barrier halfway up the back edge yes but it's an inert material that's the point it blocks the fire and it blocks the smoke
02:40:06 blocks the fire and it blocks the smoke that's what it's there to do your implication is that any any size of material
02:40:11 material that is inert would be adequate and it's clearly not because they come in different thicknesses to give different resistances but if you were worried about gaps at the back isn't it possible around windows and
02:40:23 isn't it possible around windows and we'll look at an example of this later to use compressible mineral wool and pack it into gaps isn't that
02:40:30 that sometimes a solution that's adopted when putting cavity barriers it would still have to be a fire product you couldn't just pack it with a mineral wall no but yeah fine you say but it wouldn't have to be
02:40:43 fine you say but it wouldn't have to be an engineered you couldn't just say oh we've got a gap so we'll pack some fire insulation in there that would have to be referred to fire engineers to approve that see maybe that's what was required on
02:40:55 maybe that's what was required on grenfell but what you've done here is just raise it up because yes i've offered a more robust solution for comment did you ever check with
02:41:07 for comment did you ever check with anybody that that was more robust in terms of fire spread oh we're offering it to the professional team the architect and his fire engineers
02:41:19 engineers so you you expected them to check that that was an appropriate solution that's correct all the drawings were issued to the team for compliance
02:41:33 i see and this if we look at paragraph 34 of your witness statement har 3 0's 10419 page 9 this is where i think you've just
02:41:44 this is where i think you've just explained in your statement what you were referring to in terms of the location of the cavity barriers on the spandrels
02:41:50 spandrels this was drawn above the aluminium fixings at the head of the window as it was thought it was more effective to have them above these fixings directly against the concrete and located within the span of the concrete floor slab you see that there
02:42:02 floor slab you see that there yes yes now who thought it was more effective to have them in that location can you help us yeah it was discussed at one of our meetings across the table at harley and can you remember who was part
02:42:13 harley and can you remember who was part of that
02:42:14 of that discussion about moving that cavity barrier up well ray would definitely have been
02:42:21 did you think it was more effective in that location definitely and ray bailey thought it was more effective in that location yes i agreed with him yeah what about daniel anchor jones was he part of that decision
02:42:35 did you ever expressly flag this with the architects and and say to them listen looking at your drawings and drafting the drawings
02:42:46 the drawings we've decided to move this this is why we've moved it this is why we think it's still effective what do you think did you ever do that
02:42:54 do that no no
02:42:58 and why not why would you not do that because the whole issue of um providing drawings for him to comment is that in itself we don't ask him to
02:43:10 is that in itself we don't ask him to check every item on the drawing that is the process that he's checking every item on the drawing i see your evidence to it so far has been that
02:43:19 been that what you were doing was simply translating you were just drafting translating what the architect wanted into a drawing that's correct do you accept if you were doing that you would
02:43:30 accept if you were doing that you would have put the cavity barrier at the head of the window there's there's areas where what the architect is shown are impractical and you might
02:43:41 are impractical and you might make minor variations which is the whole point of
02:43:45 point of us sending the drawings back to him if we were if we were copying his drawings exactly
02:43:50 exactly there would be no need to send any drawings back to him yeah so there is a design development going on at harley's end isn't there and you're part of that process that's right to make things fit the
02:44:01 that's right to make things fit the building yes
02:44:06 now just looking back at the drawing
02:44:16 ryd50220
02:44:23 this is the drawing produced on the 3rd of march
02:44:27 of march and i just want to look at what the annotations say in that top left label if we could zoom into that where you have put the cavity barrier you've put fire break cut
02:44:39 cavity barrier you've put fire break cut around cladding rails do you see that there yeah yeah now so was that a specific instruction that um
02:44:47 um you were adding to these drawings about cutting
02:44:51 cutting fire breaks around cladding rails um it was
02:44:54 was as we as i understood they would be installed
02:44:58 installed because the cladding rails come into the zone so they weren't going to come as a pre-cut item they would begin to cut on site accordingly did you ever consider how the integrity of the cavity barrier would maintain if it was going to be cut
02:45:11 would maintain if it was going to be cut around the cladding rail um no because i guess this is sealing the inside but the cla the cladding rail the um the area of the cladding rather that
02:45:22 the area of the cladding rather that you're implying is on the outside of the building
02:45:26 building no it's not it's on the inside it's it's underneath the rain screen cladding but it's also on the outside because it's an open air gap well let's focus on the inside what you
02:45:37 well let's focus on the inside what you had was a concrete face and an interval you had a a cavity barrier coming across um complete it wasn't interval and then where there was a cladding rail that
02:45:49 where there was a cladding rail that came up the spandrel the cavity barrier was cut
02:45:51 was cut so that the rail went right through the cavity barrier it's right yeah it was cut tight
02:45:57 cut tight yes but you've still got the break in the cavity barrier where the rail goes do you agree yes but the rails are continuous so you there's no alternative
02:46:08 there's no alternative now you've said to us earlier that you were concerned about gaps at the head of the window and the fire attacking the back of the cavity barrier if it was lower yeah why didn't you ever give any
02:46:20 yeah why didn't you ever give any consideration to the gaps that would be created by the crowd cladding rails as they went through the cavity barriers there were no gaps
02:46:29 no gaps it was cut tight to the cladding rails yes but the cladding rail itself was a channel through which the cavity barrier
02:46:38 barrier did not fit does that make sense it didn't go through the middle from the front is yes i'll say i will come and i'll show you some pictures and
02:46:49 come and i'll show you some pictures and i think in paul hyatt's report we get i mean this is normal practice it's normal practice to cut around the cladding rail is that what you're saying that's right as long as it's tight on the inside you can do no more
02:47:00 tight on the inside you can do no more on the outside because it is a cladding as a continuous joint it wouldn't have been possible to put the cavity barrier or put a piece of cavity barrier inside the shape of the cladding rail that
02:47:11 the shape of the cladding rail that the u-shape of the cladding rail so that you have a continuous cavity barrier along the spandrel but that would be exposed to the outside world then no it was inside the rain
02:47:22 world then no it was inside the rain screen
02:47:23 screen okay i think we need to have a look at a detail yeah we can do that um before we leave this drawing yes i confess to be not very good at reading drawings but can you can you with your practice side tell me
02:47:35 can you with your practice side tell me how far
02:47:36 how far up this shows the cavity barrier above the head of the window it's well it was discussed it was as tight as possible yeah but to the um what's the dimension as far as you can
02:47:48 what's the dimension as far as you can yeah i would say that was about because this is a scale drawing i would say that was about 175 to 200
02:48:00 millimeters so it was actually a quite a small zone i think we'll have we'll have a look over the lunch break see if we can thank you very much a dimension for that i think i'm just
02:48:12 a dimension for that i think i'm just interested to get a feel for the dimensions i find it quite hard to get that just yeah i think we might have some good photographs and dimensions in barbara lane's first report so we'll we'll do that thank you
02:48:26 [Applause] now if we
02:48:31 now if we go on in the chronology if we turn to sca50252
02:48:38 we can see if we look at the email at the top of that page that on the 6th of march 2015.
02:48:49 that page that on the 6th of march 2015. so your email of the 3rd of march has prompted neil crawford to send an email on the 6th of march to paul hanson at rbkc building control
02:49:00 to paul hanson at rbkc building control and you're copied in amongst others do you see that on the cc list yes yes and he says hi paul following our conversation this afternoon this reminded me of another issue
02:49:12 reminded me of another issue where we are where we are over cladding what fire rating do we need to allow for within the wall build up between apartments see below and attached do you see that
02:49:23 see below and attached do you see that there yeah so he's asking about the fire rating yeah can you explain to us exactly what the issue was he was raising there
02:49:38 um
02:49:44 was it about the you've put the 90 minutes integrity in 30 minutes insulation is sufficient in your evening no no no i think this is referring to an architectural detail
02:49:55 referring to an architectural detail this reminds him of another issue where we're over cladding what fire rating do we need to allow within the wall build up
02:50:03 up between apartments so i think that's that's referring to the internal um of the building no i think he's asking
02:50:13 asking and i think we'll see it as we keep going within the cavity the rain screen cavity
02:50:19 cavity what fire rating do we need to allow for in the locations between apartments so the horizontal cavity barriers what rating should they be all right is that not right
02:50:32 but that's exactly what i've asked below so why is it another issue unless he's referring to his conversation
02:50:40 that may be right it may be that you've raised it and he's said that reminds me but in fact you're talking about the same issue possibly yeah now we can see you're copied into this
02:50:52 now we can see you're copied into this email string um was it as a result of this exchange that prompted you to look at approved document b no i think i
02:51:04 approved document b no i think i probably looked at it before i mean very close to this time i mean this is only three days after my email i think it was around literally around that time probably before the third of
02:51:15 that time probably before the third of march but
02:51:16 march but did you think to look at table a2 of adb which gives advice on the rating of cavity barriers i don't recall it appears that you rang cider eyes and
02:51:28 it appears that you rang cider eyes and spoke with sue shepard at this point we can see that if we go to har four zeros three triple
02:51:44 nine
02:51:48 so if we look at the email at the bottom of that page on the 11th of march you are emailing barnaby carrick
02:51:59 and you say this barnaby further to your recent help with horizontal and vertical fire breaks within our rain screen cladding we wonder if you could assist with what would be the normal fire rating required and then you explain about the building
02:52:10 and then you explain about the building domestic block internal party walls will be 120 minutes in your experience what would the rating be for horizontal and vertical brakes this would help us to propose hopefully
02:52:21 this would help us to propose hopefully the correct product for building control to approve yeah you see that there and then if we look at the top of that page
02:52:36 sue shepard says hi kevin thank you for sending across following our conversation i've just spoken with barnaby and he should be responding to you shortly do you see that there yes yes
02:52:48 now you're asking for advice from sider eyes on the rating of the barriers at this point yeah again my question is did you take any advice at this point from
02:53:00 take any advice at this point from siderise about where to put the vertical and horizontal barriers no not at all
02:53:07 that was because you were clear in your mind where you where they were going to go
02:53:10 go yeah they were as as close to the position shown in the architect's drawings
02:53:14 drawings and they complied with the discussions with harley right
02:53:20 and shortly after that on the 12th of march 2015 mr mort siderizer's technical officer responds if we could go to
02:53:36 bsd401779
02:53:43 so this is mr mort to you and he says hi kevin we would confirm that to meet the requirements of approved document b the area between compartment wall and
02:53:54 the area between compartment wall and outer cladding needs only to be a cavity barrier
02:53:57 barrier 30 minutes integrity and 15 minutes insulation which would mean that our open state cavity barrier system would be suitable if you need me to comment on a specific detail
02:54:08 comment on a specific detail the please forward over and i will respond immediately apollo apologize for the delay and he says please see diagram 33 below can you see that he's actually cut and paste it into your
02:54:20 paste it into your um email
02:54:24 um email [Applause] could we just page up a little bit
02:54:30 go page up yeah i say yeah yeah so he's he's made specific
02:54:38 specific um comment to that being rain screen yes and about whether or not their product would be suitable yeah now at this point you're having diagram 33 brought to your attention
02:54:49 diagram 33 brought to your attention do you recall noticing that diagram 33 marks
02:54:54 marks cavity barriers around the windows yes yes
02:54:57 yes but you were still comfortable where you despite that with the arrangement that you were
02:55:01 you were showing on your drawings we were still discussing it at this stage yes when you say still discussing it at this stage well you'll see this email trial goes on
02:55:11 goes on quite a while and is picked up by ben i appreciate you're still discussing the rating of the cavity barriers but is it your evidence that you were
02:55:22 but is it your evidence that you were still discussing the location where to put the cavity barriers the whole subject of cavity barriers yes right
02:55:29 right so even though we saw you'd issued those drawings on the 3rd of march showing cavity barriers you felt in your mind did you that the issue was still up for grabs
02:55:38 for grabs as to how you ended up on that issue i felt we needed someone to say this is all okay i see
02:55:49 now it appears that mr hoban had concerns at this point regarding the fire integrity of the cavity barriers if we go rbk3048734
02:56:04 on the 20th of march so this is an email from john hoban and
02:56:16 so this is an email from john hoban and it's to neil crawford and paul hanson at neil crawford studio e paul hanson at rbkc building control and you're copied in
02:56:25 in and john hoban is referring to the building regulations and he says to neil crawford further to my conversation with you today i would confirm that the fire time for new
02:56:37 confirm that the fire time for new elements of structure ingredient for tower is 120 minutes as specified in and he's talking about table a2 yes over approved document b which i just referred to just a moment ago i would draw your
02:56:50 just a moment ago i would draw your attention i would also draw your attention to diagram 33 of approved document b and highlight the detail between compartment flaws and external cladding in the meantime should you wish to discuss any other aspects of the project
02:57:02 discuss any other aspects of the project neil then please do not hesitate to call me
02:57:05 me so at this point john hoban is saying his view is it needs to be 120 minutes no no he's saying the new elements of the structure we were just talking about the existing
02:57:17 we were just talking about the existing elements of the structure where the boxing club was there was new elements of the structure being being constructed and that was a different
02:57:26 different zone as far as fire rating was concerned isn't it right that what mr hoban's referring to as new elements of structure is the cladding the over cladding on the whole
02:57:38 cladding the over cladding on the whole building
02:57:39 building new columns being sections of compartment floor not at all you can have a look at the architect's fire strategy plans which clearly shows the lower levels of having a greater
02:57:51 having a greater fire rating harley harley provided some new walls where there were no concrete walls they provided an sfs construction in these areas
02:58:02 these areas this was the new structure i see so your evidence is that this wasn't concerned with levels 4 to 23 of grenfell tower i don't believe so this was concerned with the lower levels
02:58:13 this was concerned with the lower levels this definitely mr chairman i wonder if that's an appropriate moment again i'm midway through this topic but it goes on and
02:58:24 through this topic but it goes on and that's as good a moment as anything that suits you that's i think yeah the rest of us as well good thank you very much well mr lam we're going to have a break now for some lunch so please remember not to talk to anyone
02:58:35 please remember not to talk to anyone about your evidence while you're out of the room
02:58:37 the room and we'll resume at two o'clock please okay thank you very much
02:58:49 right thank you two o'clock please okay
02:59:55 you