Continued evidence from Daniel Anketell-Jones of Harley Facades examining insulation selection, fire safety testing, and technical communications with Celotex about RS5000 product.
00:00:13 yes would you ask the witness to come back in please thank you
00:00:30 back in please thank you right the stranger phil jones ready to continue yes good thank you very much yes ms grange yes thank you yes um can we turn so i'm staying with the story of the insulation and your contact with celatex
00:00:43 insulation and your contact with celatex can we turn to a document cel409974
00:01:00 so this is from the celetex salesforce database and it shows that you had
00:01:09 you had what seems to be known as a contact profile within their database do you see that there so it's got your name at the top do you see that yes and um details about your
00:01:20 yes and um details about your job and your role below that do you see that there yes um were you aware that you were seen as a contact profile for celetex
00:01:31 contact profile for celetex at the time
00:01:35 not as a person but as a company would have thought i see yeah so harley would
00:01:44 would certainly in your mind have been seen as a key contact for celetex as a contact yeah yeah did you ever have any role in the marketing or promotion of celetex
00:01:56 marketing or promotion of celetex products
00:01:57 products no did harley ever get involved in helping celetex to market its range of products
00:02:06 no um now following on in the chronology i now want to pick up where we are in january 2015. if we can look at cel6019
00:02:24 and i want to start on page two to an email that you send there we go at the bottom of that page if we zoom in on the bottom
00:02:35 the bottom you send this email on the 16th of january 2015 and the subject is headed rs 5000 it's the jonathan room at celetex do you see that there yes now we looked at this very briefly when we first
00:02:47 at this very briefly when we first started off your evidence but i now want to ask you some more detail about it so we can see there you say good morning john
00:02:56 john sorry but got a headache for you we are being asked by one of our clients to see the test results and certificates for the rs 5000 insulation they want to know exactly how
00:03:07 insulation they want to know exactly how it was installed when tested to bs 84142 2005 who carried out the testing how it was fixed what it was covered with what cladding was used what support structure etc and most importantly
00:03:20 structure etc and most importantly the results drawings and or photos of the test setup would help show how it was installed but i imagine these form part of the test results anyway they also want to see the
00:03:31 anyway they also want to see the certificate and results for the test to bs
00:03:33 bs 476 part 7 fire class rating showing the index rating achieved during the test could you sort this out for us please we are hoping to put this forward on most of the cladding jobs
00:03:44 most of the cladding jobs so having this information to hand would be most useful do you see that there yes now the first question
00:03:52 question um is um in relation to what project were you inquiring about you say there in the second line we are being asked by one of our clients to see the test results for the rs 5000.
00:04:06 to see the test results for the rs 5000. can you remember what project that was no i mean at the beginning of 2015 i started to help out more with the front end of the building
00:04:17 more with the front end of the building of the company with estimating so it was probably to do with one of those projects that was being estimated right um are you able to help us as to
00:04:30 right um are you able to help us as to whether it might have been the grenfell project i mean we know that grenfell project was ongoing at this time and we know that you had involvement in it could it have been grantful you were inquiring in relation to i would have thought it was more likely
00:04:42 i would have thought it was more likely one of the jobs that was being estimated and trying to be won at that time
00:04:48 that time and when you say one of our clients what kind of
00:04:52 kind of body are we thinking of there i mean what does that say to you in terms of who was asking um probably would have come through either a main contractor or an architect
00:05:05 yeah now if it was a different project did you have any concerns that this or similar information was not being asked for
00:05:15 for by the professionals on the grenfell project
00:05:19 project i would have well looking back on it i would have expected that this had already been done on the grenfell project and who would you have expected to have done that the architect and building
00:05:31 done that the architect and building control
00:05:33 control so not harley no i see
00:05:41 i would imagine that this was probably to do with one of the projects which had a performance specification rather than a prescriptive specification probably that we were being asked to put forward a
00:05:52 being asked to put forward a installation that would meet the new value requirements we'll look at what happens and you do get sent some information back from mr room eventually um but can i just check did you ever
00:06:05 um but can i just check did you ever think at the time to refer this kind of information on to designers either in harley or say studio e at the time of the grenfell project no because looking back on it i would
00:06:17 no because looking back on it i would have expected this work to have already been done this was for a new project i think that that hadn't been done on yet
00:06:28 i'm sorry you say that this might have been somebody interested in new values but none of this is concerned with you values is it no but this is the only reason that we'd be
00:06:38 be putting forward an insulation is because we were trying to hit a performance related specification rather than a prescriptive one if it was brisket prescriptive then it
00:06:49 if it was brisket prescriptive then it would be that this was already in that specification for that job
00:06:56 but this is all about fire testing isn't it fire testing of the rs 5000 insulation yeah so if there was a performance specification
00:07:07 if there was a performance specification yeah
00:07:08 yeah that had a high performance requirement we would have known that the only way we could probably achieve it was with one of these in high performance installations and so we'd have to put this forward to
00:07:20 and so we'd have to put this forward to that client to see if they believed it was compliant or not isn't it more likely that one of your clients has realized that it's
00:07:30 that it's important to know the test results and and details of the testing for the bs 8414 tests that were done on rs 5000.
00:07:45 rs 5000. i think that it's basically the same thing that we were putting forward a product to meet a performance requirement and they'd probably come back saying that they needed to see this information
00:07:57 that they needed to see this information to be able to approve that product yes isn't it likely that they looked at the rs 5000
00:08:04 rs 5000 information following the launch of that product and realized that they needed to know
00:08:10 know more about exactly how it was installed what it was covered with what cladding was used
00:08:16 was used etc in order to decide whether it might be suitable for another project
00:08:22 i think we're saying the same thing aren't we i'm not sure we are but i'm saying that we'd probably got a performance required specification in
00:08:34 specification in we knew it was a high performance requirement so we would have put this forward to them and they may it would appear that they came back asking for additional information yeah but does
00:08:47 additional information yeah but does that mean you would have put it forward without
00:08:49 without satisfying yourself that it met the fire safety
00:08:52 safety requirements again because i wasn't educated in fire safety or had any training in it i wouldn't have been able to do more than look over the information
00:09:04 than look over the information and pass it on to the people who did did you think about reading the information that jonathan room had already sent you we know you got that zip file in august 14 with all that pack
00:09:15 zip file in august 14 with all that pack of information which would have answered some of these questions wouldn't it like what cladding was used
00:09:21 was used support structure etcetera and how it was fixed
00:09:25 was fixed some of that was in the pack of information that we looked at this morning wasn't it yeah but i wouldn't have just i wasn't trained in those areas i wouldn't have known
00:09:36 wouldn't have known to look back at that because they didn't stand out to me in the same way as things like eurocodes would why did you say in the first line sorry but got a headache for you
00:09:49 but got a headache for you why did you consider it would be a headache for celetex to provide this information i can't remember if you didn't know this area
00:09:59 area and you didn't know even the basics about fire testing how would you know that it would be difficult
00:10:06 difficult because that's what a headache implies isn't it difficult how would you know it would be difficult for celetex to be providing this information i'd only be guessing at why i was saying
00:10:18 i'd only be guessing at why i was saying that
00:10:21 were you aware at the time that there might be difficulties for mr boom in disclosing the documents i think looking back at his response to this there must have been
00:10:34 there must have been some sort of conversations at the time that betrayed that but only from looking back at that i can't i have no memory of it if we look at what you say at the end of that first detailed paragraph
00:10:46 that first detailed paragraph three three paragraphs down you say drawings and or photos of the test setup would help show how it was installed but i imagine these form part of the test results anyway now if you didn't know the basics
00:11:00 anyway now if you didn't know the basics about the fire testing how could you be speculating here that you imagine that they do form part of the test results anyway probably from speaking to the person who is asking for them
00:11:12 is asking for them i see so you're saying you've got all of this and you're merely a conduit is that what you're saying between the client that's asking and sell attendance yes
00:11:23 were you aware at the time i want to put this to you directly that just because celetex
00:11:28 celetex had passed one eight four one four test that did not mean that it would be suitable for all range screen applications i was aware at the time that if it was
00:11:39 i was aware at the time that if it was accepted on one job it wouldn't necessarily mean it was be accepted on another job so it was done on a job-by-job basis but i didn't understand what grounds that was on so you didn't understand that it was important to check the
00:11:51 that it was important to check the system
00:11:52 system that was proposed to be used and whether it was
00:11:56 it was the same as the system that had been tested no to be honest i thought it just came down to the particular fire consultant or building control officer who was reviewing the information
00:12:07 reviewing the information and how they interpreted it were you aware that the celetex was not compliant in certain circumstances and that was why the provision of this information might be difficult for mr room
00:12:20 might be difficult for mr room i wasn't aware that it wasn't compliant i was just aware that some people might not accept it so you weren't aware that if following the guidance the the the guidance in say paragraph 12.7 of
00:12:31 the guidance in say paragraph 12.7 of adb
00:12:32 adb that this product wouldn't meet the limited combustibility requirements you weren't aware of that no
00:12:45 so can you help us as to why it would be a headache for jonathan room to provide this information i can only just draw an assumption based on his response
00:12:56 draw an assumption based on his response to this email where he says about it being unlikely that any information would be given for parts of it and we must have had a conversation i assume that we had a
00:13:08 conversation i assume that we had a conversation along those lines at some point
00:13:10 point previously did you anticipate that celetex would be reluctant to disclose these documents i can't remember but by by that start and the response
00:13:21 and the response i can guess that that must have been along those lines
00:13:31 would you agree that you must have known at the time that the precise details of the system tested was important otherwise why be asking celetex for these details
00:13:47 because i think i was passing on information i wouldn't have known from my own knowledge but i i probably would have been told that it was important and that was why to ask for it
00:13:58 to ask for it by the client i see so you didn't um ask yourself whether or not this was important enough to trouble sell a text with before you just passed on the information no i just passed on the information
00:14:12 i would suggest you that on reading this email it does suggest that you did appreciate how important the exact details of the system that had been tested were
00:14:23 tested were because i was being asked by somebody who has been very specific in what they required
00:14:30 required was it your understanding that the way in which the test was set up was critical to its reliability no only from what was being asked here i could have
00:14:42 what was being asked here i could have drawn that conclusion but i didn't know it
00:14:45 it did this request from your client cause you to reconsider the suitability of celetex rs 5000 for use on the grenfell project no because it
00:14:56 because it was my understanding that these sort of checks had been already carried out by the architect and building control but you had no communications did you from studio e or building control which
00:15:07 from studio e or building control which said those checks had been carried out no because i wasn't the designer on that project
00:15:16 and did you know what the bs 476 part 7 testing was relevant to no you didn't know that that might be relevant to national class north no
00:15:29 did you know why that additional information might be relevant to the use of an insulation product no now finally you say we are hoping to
00:15:40 no now finally you say we are hoping to put this forward on most of the cladding jobs
00:15:43 jobs so having this information to hand would be most useful would you agree that that suggests that you did recognize at the time how important that information
00:15:55 how important that information was likely to be that would be most useful
00:16:01 i knew that the eu values for jobs were becoming
00:16:05 becoming more and more difficult to hit and i knew that celetex was offering a product that could be used over 18 meters and was a high performance insulation
00:16:16 and was a high performance insulation that could meet those requirements and for projects that were coming up which were you know showing high performance requirements the only way to satisfy them was
00:16:28 satisfy them was to use a high performance insulation but this is nothing to do with u-values is it it's to do with the fire performance of this insulation product yeah but to the
00:16:40 yeah but to the the reason why it was going to be put forward on most cladding jobs was because it was able to satisfy those high performance requirements and that on those jobs
00:16:52 requirements and that on those jobs it would be the same process that we would go through on every project where you submitted the information to the design team for its approval so if you actually had that on file you'd be able to
00:17:03 you'd be able to do it on every job again i would suggest you that a more natural reading of this email is that you did appreciate that these kind of details were important
00:17:14 important to its compliance and its selection on cladding
00:17:17 cladding projects no i think it is that it would be
00:17:21 be useful for getting it signed off on other projects now if we scroll up we can see that mr rheem responds on the 19th of january at 10 57 immediately sorry yeah i'll ask
00:17:33 at 10 57 immediately sorry yeah i'll ask you a question um you've spoken more than once about recommending high performance insulation products for other projects did you have any training or
00:17:44 projects did you have any training or education in thermal performance or calculation of you values and so on no i didn't i was able to carry out calculations to cross
00:17:56 calculations to cross check what had been put on there and so you could quickly ascertain whether one installation was going to meet those requirements or not but you didn't feel able to
00:18:08 form views about uh fire performance no because
00:18:12 because one is a very simple mathematical formula
00:18:16 formula the other one is a very complex set of regulations all right yes thank you
00:18:23 you yes yes sorry sorry before i go to mr room's response just one further question um why were you hoping to put rs 5000 forward on most of your cladding jobs
00:18:35 forward on most of your cladding jobs to what benefit for the reason i mentioned before that the the jobs that started to come in had very high performance requirements from the
00:18:46 requirements from the envelope and most of the jobs that could only be achieved using a high performance installation and celetex was saying that theirs was acceptable for use above 18 meters
00:19:01 but if this information was going to be a headache for mr room why were you hoping to put that forward on all of your cladding projects i think from his reply well
00:19:14 i think from his reply well because he was saying that it could be used above 18 meters it was the only one that would satisfy those u-values and be acceptable for use over 18 meters
00:19:25 and be acceptable for use over 18 meters right now if we scroll up and look now we see his response is morning dan hope you had a good weekend i will check regarding test reports and what we are allowed to send out i will
00:19:37 what we are allowed to send out i will get back to you soon do you see that there yeah did it concern you that he might not be allowed to send out certain test reports relevant to the fire performance of this
00:19:48 relevant to the fire performance of this product
00:19:50 product no at that time my understanding of how test reports were written and what they showed was actually none because i was a structural engineer
00:20:02 structural engineer and so i just assumed that there was some sort of privacy rules on it but the information that he would be allowed to send would be enough to satisfy the consultant
00:20:13 be enough to satisfy the consultant but were you not concerned that this was relevant to life safety and therefore there was details that you needed to see they ought to be provided was that not your attitude yeah i
00:20:25 was that not your attitude yeah i thought that they would be allowed to send out
00:20:26 send out enough to satisfy those requirements and to
00:20:31 to give the consultants enough information to be able to sign them off i wasn't worried that the stuff that he wasn't allowed to send would impede that in any way
00:20:43 would impede that in any way right and then we see your response to that at the bottom of page one and on to page two
00:20:51 page two on the 20th of january 2015 and then if we go over to the top you say fingers crossed you can get this for us
00:20:59 us i am worried that if this can't be cleared up then we will have to change to rockwell duo slab as this has the necessary backup to appease the specialist do you see that there yes now can you
00:21:12 do you see that there yes now can you help us understand this comment um what do you mean that rock wool duo slab had the necessary backup to appease the specialists
00:21:24 to appease the specialists that whatever we had submitted to the consultants had been approved for the rockwool duo slab
00:21:34 and did you understand that that would be about the fire performance of the rockwool duo duo slab that it had the necessary backup to appease the specialists it would be either that it could only
00:21:45 it would be either that it could only really be the
00:21:49 it could be a range of things but it'd probably be the fire performance of thermal performance and whether it was suitable for behind a range screen for its longevity
00:22:00 longevity and durability well i'd suggest to you it was almost certainly about the fire performance because that was the sole topic of your email to mr room
00:22:11 the sole topic of your email to mr room was fire performance wasn't it likely that the fire performance of the rockwool dues lab had had satisfied the specialists in that job and you were needing more
00:22:22 in that job and you were needing more information from celetex to persuade them that that rs 5000 product was satis was satisfactory from a fire safety perspective isn't that what was happening
00:22:32 happening i think that the rockwool duo slab you know often takes up twice as much room as the high performance installations and if
00:22:43 high performance installations and if this job had been drawn with high performance it would have meant going back and completely changing the design would you agree with me that a natural reading is of this is that you did
00:22:54 reading is of this is that you did understand at the time that rockwool duo slab
00:22:58 slab had the necessary backup in terms of fire performance to appease the specialists
00:23:06 i wouldn't have known why they were happy with it but i think i would have known that they were happy with it why did you put the word specialist in inverted commerce
00:23:22 inverted commerce because i think even then i was aware of how broadly people interpreted a lot of this information and how on one job it might
00:23:33 information and how on one job it might be accepted and on one job it might not yeah and i think i found that
00:23:41 being a structural engineer it was always very black and white there was no there was no gray in being a structural engineer i found it very hard to align myself with people who
00:23:52 hard to align myself with people who called themselves specialists but couldn't agree on something right who are you referring to there are you referring to architects or fire engineers can you help us i'd say architects fire engineers
00:24:03 i'd say architects fire engineers building control thermal consultants were you skeptical of their specialisms
00:24:13 i think generally across the board i was why why were you skeptical because you couldn't
00:24:22 couldn't ever get the same answer twice it felt like
00:24:25 like yeah you could be working in one part of london
00:24:29 london and they wanted one done one way and you could be working in another part of london
00:24:33 london and they want it done in another way i personally failed to see how that makes sense
00:24:41 sense did the specialist ever explain to you why this information was required and was necessary for them
00:24:54 i can't remember it would have been that they were
00:24:57 they were they wanted to approve the product or we wanted them to approve the product i can't remember any conversations about it did you know that the reason this information was being requested by the specialist was because
00:25:08 specialist was because 8414 tests applied only to the system as tested no i did not know that so you didn't think that was why the specialists were seeking this information
00:25:22 i just thought that they wanted all the information that they could get to be able to sign it up
00:25:32 so you've commented there that if the information can't be provided hardly would have to change to rockwool duo slab that's the phrase you've used
00:25:43 duo slab that's the phrase you've used then we will have to change to rockwell duo's lab
00:25:46 duo's lab doesn't that suggest that you had positively suggested rs 5000 and it was being queried by specialists on a project i can't remember a time where we ever
00:26:00 you know started the requirements usually the architect knew roughly what he wanted and he'd know that he wanted a high performance insulation or a rockwell
00:26:12 performance insulation or a rockwell insulation and then we'd go away to come back with a proposal of which one so is your evidence that it was never harley suggesting that rs 5000
00:26:24 harley suggesting that rs 5000 was a suitable insulation product for buildings above 18 meters is that your evidence
00:26:28 evidence yes
00:26:32 now we can see from the email at the top of that page that on the 21st of january 2015 on top of page one
00:26:40 page one mr roon provided you
00:26:44 with a number of things he says this hi dan i've attached the 12 page bs 8414 part 2 report showing the build-up and components used in addition i'm sending you the thermocouple graphs showing the
00:26:55 thermocouple graphs showing the temperatures at each level of the test i'm not able to send you the bs476 test document as this is confidential i would be surprised if you were able to get this or any other report from the
00:27:06 get this or any other report from the manufacturer to be honest in lieu of this i've attached the data sheet showing confirmation of the products
00:27:12 products having bs476 parts six and seven which gives it
00:27:15 gives it class naught performance in addition to the bs8414 test i would ask that these documents are not shared outside of the network of you and your specialist advisor for this project
00:27:26 advisor for this project please give me a call when you have a moment to discuss do you see that yes now did you read those documents when you
00:27:32 when you were provided with them no you didn't so you simply passed them on to mr ditzeri to the specialists on the project
00:27:41 project yeah i just at that point i wouldn't have known what they're about i just don't imagine that i would have read them so that didn't prompt you to look at
00:27:52 so that didn't prompt you to look at those documents and then consider whether the rs 5000 product
00:27:57 product was suitable for use on grenfell tower no because as far as i was concerned grenfell tower the insulation had already been specified and approved by the architect and building control
00:28:09 and building control did you think that what you ought to do is send this information to other members of the the grenfell project including
00:28:20 the grenfell project including kevin lam studio e ryden so that they were aware of it and could use it in making an assessment as to whether they should be using rs 5000 did you think about that
00:28:31 5000 did you think about that no because i thought it had already been done
00:28:35 done well it hadn't had it this is january 2015
00:28:39 2015 yeah but as far as i was aware that the product was already specified
00:28:48 well before i even looked at the the first time i saw the nbs spec it was what was in there i think but it's not the same product as the mbs specification we've looked at that the product in the mbs specification was
00:29:00 product in the mbs specification was fr 5000. this is rs 5000 isn't it yes so rs 5000 hadn't been specified long before had it no but it was it's just my recollection
00:29:11 no but it was it's just my recollection of it i can't remember looking at this and having any thoughts as to whether there was any doubt
00:29:21 doubt by the design team as to the use of this on grenfell i was under the impression that it was already approved does that mean that you kept this information to yourself within harley did you share it with anybody else in
00:29:33 did you share it with anybody else in harley
00:29:34 harley i don't know you don't know
00:29:39 did it concern you that mr room said he was unable to provide the bs 476 test document
00:29:45 document it's we see that in the second paragraph where he says it's confidential did that concern you at all no i would have
00:29:53 have sent this on and if it had been a concern for the people who understood it i would have gone back to him
00:29:59 him when he says confidential what did you understand to me confidential to who
00:30:06 at the time i was under the impression that celetex and kingspan were sort of both um competing
00:30:17 both um competing to get a product that could be used over 18 meters
00:30:21 18 meters i assumed that it was in relation to not letting them see how they were you know what was their special way of meeting the requirement
00:30:35 i see so you think mr roon was concerned that you what you might pass this information on to kingspan yeah to sell a texas competitor or that they may
00:30:44 they may somehow get side of it did you ever clarify that with him and say ask him well why is this confidential confidential to who did you ever ask that no all i can remember is
00:30:57 remember is the conversations with him at the time about how they were the first one to get insulation a high performance insulation that could be used above 18 meters
00:31:08 that could be used above 18 meters and that kingspan didn't have one did this this this not sharing the 476 test document with you cause you to reconsider whether or not
00:31:19 cause you to reconsider whether or not rs 5000 ought to be used at grenfell no i think if if whoever i'd sent this on to
00:31:26 on to i suppose if they'd come back and said that
00:31:29 that it was an issue it might raise something but i don't i don't remember it causing any concern
00:31:40 i don't remember it causing any concern so are you saying when you got this email you were you were 100 confident that
00:31:44 that rs 5000 was an appropriate insulation product to use on buildings above 18 meters
00:31:55 i wasn't educated in that to be able to draw that conclusion i was i obviously sent this on to someone else to check whether it could be if you
00:32:07 to check whether it could be if you weren't educated in that why was it you having these conversations with mr roon why was it you being the person to ask for this information i think because i'd moved over to help
00:32:18 i think because i'd moved over to help mark harris out with the estimating we were just it was just somebody to do it did it concern you that at the end of the email
00:32:29 concern you that at the end of the email he said that he's asking that these documents are not shared outside of the network of you and your specialist advisor for this project did that concern you that you wouldn't be able to use that information
00:32:40 be able to use that information for any other project where rs 5000 was specified
00:32:44 specified no it didn't i thought this was just to do with the the the competition with um kingspan did that not ring any alarm bells for you no
00:32:56 bells for you no [Applause] and can you help us as to what you then did with this information when you received it i would imagine i've passed it on to the client that was asking for it
00:33:07 client that was asking for it and that was all yeah
00:33:13 so um then if we look at another email in this chain this is
00:33:22 cel6023
00:33:26 we can see at the bottom of page one on 21st of january at 909 you go back to mr room you say morning
00:33:38 you go back to mr room you say morning john thanks for this sorry i didn't call back yesterday we didn't finish till 6. i will look through it and try and give you a call back kind regards dan do you see that there yes
00:33:48 yes so that does suggest that you intended to look through these documents not merely pass them on doesn't it no i think
00:33:55 think honestly i wouldn't have been able to look through them without that training and knowledge so it would have been to look through it just to compare whether he'd sent what had been asked for and
00:34:07 he'd sent what had been asked for and whether i could send it on or not i see well i would suggest to you that a natural reading of this is that you were intending to look through it and and look at what information you'd been provided with to make at least some
00:34:19 been provided with to make at least some assessment of it no i wouldn't have been able to make an assessment i had no training in this at all so all i could have done is look through it and see if the information had been asked for
00:34:30 asked for had been sent do you know whether you called him back you say i'll try and give you a call back do you remember calling him back no i don't or anything about your conversation no
00:34:41 and we we've checked and we think the first order of rs 5000 insulation right from celatex three through
00:34:49 through other suppliers like sig is actually the 25th of
00:34:52 25th of march 2015. so after this so it was not too late on grenfell at this point
00:35:03 too late on grenfell at this point to notify people about this information was it
00:35:06 was it if that's right
00:35:11 but as far as i was aware that had already been you know signed off by the architect and building control on that project
00:35:22 building control on that project okay um
00:35:26 okay um if we go forward in time sticking with the insulation and mr room we've already seen that he sent you the building control alliance technical guidance note 18 on the 8th of april
00:35:37 guidance note 18 on the 8th of april 2015. can we go back to that
00:35:42 cel403628
00:35:49 so this is april 2015. mr room to you hi dan thanks for your time today to get an update on projects and family let me know when you have
00:36:00 and family let me know when you have time to go through the specs for premier house
00:36:03 house i've attached the building control guidance notes for installation products above 18 meters which seem to be doing the rounds at the moment if you do find that you are entering into conversations regarding this
00:36:14 into conversations regarding this subject please let me know what is being said and by whom do you see that there yes and it would appear that this again followed a call with him because he says thanks for your time today to get an
00:36:25 thanks for your time today to get an update or maybe you saw him in person can you recall how you'd had contact with him
00:36:33 with him at that point did you discuss technical guidance note 18 with him in that conversation do you think i don't think so i don't think so
00:36:48 i think you told us yesterday that you didn't read that technical guidance note 18 is that right no i wasn't familiar with it
00:36:57 um and he says we've just seen if you do find that you're entering into conversations regarding this subject please let me know what's being said and by whom
00:37:07 would you agree that reading that he appears to be expecting that you might be entering into conversations about the subject do you see that yes and is it possible that that's
00:37:18 yes and is it possible that that's because
00:37:19 because that guidance made it clear that if the insulation wasn't limited combustibility it shouldn't be used unless it followed alternative compliance routes
00:37:32 that's a conclusion that you could draw now but at the time i didn't understand or had been trained in that to understand that
00:37:44 understand that were you aware that there was something in that technical guidance note that mr roon was unhappy with no
00:37:52 so why would he be saying to you if you're entering into conversations regarding this subject please let me know what's being said and by whom why was he so keen to know what was being said about that technical guidance
00:38:03 being said about that technical guidance note
00:38:04 note and by whom i'd only be guessing afraid i don't know whether it would be something that he was positive within that building control guidance note or something he was negative about in it
00:38:16 something he was negative about in it did you ever inform him about conversations you were aware of regarding this subject not that i'm aware of
00:38:27 and it would appear from his email that the documentation was doing the rounds he says
00:38:33 he says seems to be doing the rounds at the moment just to be clear had you received that guidance document or heard about it from anybody else no i think that it may well be doing the rounds
00:38:43 rounds for people who are trained in that way and had an understanding of fire performance but i certainly hadn't been aware of it
00:38:54 but i certainly hadn't been aware of it doing the rounds was there a continuing relationship between mr room and harley after this time
00:39:03 i believe so yes between you and mr room he i believe he kept coming into the office
00:39:12 yeah i don't remember it changing was it the case that due to your relationship with mr room harley promoted celetex rs 5000 as an appropriate product for use on
00:39:23 as an appropriate product for use on grenfell tower no i think it was my understanding that celatex had already been specified on the project project
00:39:35 was harley proposing celetex rs 5000 on a number of other projects at this time i don't think we were proposing on a number of projects
00:39:44 projects i think that a number of projects had high performance installations on them and we were trying to find find products that could meet those
00:39:55 find products that could meet those requirements did harley ever received any financial incentive
00:40:00 incentive um to promote or propose rs 5000 for its projects
00:40:06 i wouldn't have known or been involved in those kind of conversations or any other form of incentive to be promoting celetex no can we go then to another email this
00:40:17 no can we go then to another email this is ceo408582
00:40:22 this is an email in relation to a different project
00:40:28 and it's going back in time actually to july 2013
00:40:34 july 2013 from mr room to you and um it's about ice's house fire break visit do you see that there yes he says dan hope you had a lovely
00:40:46 yes he says dan hope you had a lovely weekend i've asked one of my colleagues to get in touch i forgot to ask who is our competition on the resin and rods for isis do you see that there yep what's he referring to there that's a project called isis house
00:41:00 that's a project called isis house and then at the end of that he says once i have the competitor info i can review with my boss and raise a credit for the price difference that we settle upon do you see that there yes so what's he referring to there
00:41:12 we were buying resin and rods for that project and he was offering to match their price yeah
00:41:23 match their price yeah and harley would receive that credit is that right if you went with celetex for those products no this is not selling oh i beg your pardon you're right this is with it when he's with hilty
00:41:33 hilty is that correct that's correct sorry i should correct that this is when jonathan room is at the hilti company
00:41:44 while we're with this email can we look at the email below that dated the 12th of july 2013 at 1637 at the bottom of this page
00:41:55 the bottom of this page um so you this is your email to him about isis house fire break visit you say
00:42:00 say john taff mark osborne needs some help on site with the installation of fire breaks to make sure it's being done right and discuss and resolve any problems he may be having
00:42:13 resolve any problems he may be having can you just help us as to why is that is that osborne berry you're referring to there uh yes yeah can you ask us as to why they were needing help from
00:42:25 needing help from mr room when he was at hilty with the installation of fire breaks on isis house
00:42:32 house i think it would be it was always normal to
00:42:36 to get the supplier to visit site and check the installation was being done correctly
00:42:41 correctly i see how do you often ask mr roone for help
00:42:45 help with installation on site um we've structural issues asked him for site testing and fixings um
00:42:58 site testing and fixings um i i don't think he was
00:43:02 necessarily the specialist for fire breaks i think that there was somebody else in the business who would have been sent out for that okay
00:43:12 okay can we now turn to the sig quotation for the celetex rs 5000 for the grenfell project this is cell cel 6035
00:43:30 so this is sig can you just tell us who sig were
00:43:36 sig were i only know them now to be honest i wasn't involved in they're suppliers of insulation aren't they yeah yeah and we can see this is a a quote
00:43:47 yeah and we can see this is a a quote from sig for the attention of ben bailey uh and it's dated the 17th of march 2015.
00:43:54 2015. do you see that there yes um and what we can see when we look down this invoice is that there appears to be a discount of 47.5
00:44:06 there appears to be a discount of 47.5 percent
00:44:08 percent in relation to the celetex product celetech the product is celetex rs 5000 specials quantity 660
00:44:19 rs 5000 specials quantity 660 price 132 pounds 19 per each discount 47.5 do you see that there yes would you agree that was a hefty discount
00:44:33 i wouldn't be able to comment on it because i wasn't buying those products i wouldn't know if that was normal or abnormal
00:44:42 abnormal so you weren't aware is this your evidence that you weren't aware that on the grenfell project you were getting a forty seven point five percent discount on the celetex rs 5000
00:44:55 discount on the celetex rs 5000 insulation you weren't aware of that no it was not were you aware you were getting any form of discount no so can you help us as to whether this discount
00:45:04 discount uh came from celetex through sig and on to harley i wouldn't be able to help you with that well we can ask mr bailey about that um
00:45:16 well we can ask mr bailey about that um i want to put to you was this a reason for
00:45:19 for promoting the rs 5000 product over other options at grenfell because you would receive a very significant discount
00:45:27 discount no i wasn't aware of it the only reasons the rs 5000 would have been
00:45:36 been put forward on any projects were that we were being told it was appropriate for use above 18 meters and it was one of the few installations that was capable of
00:45:46 of achieving the high performance requirements and then that would have always been sent to the architect and building control for approval did you get any
00:45:57 approval did you get any discounts on other projects from celetex for rs 5000. i had no involvement with discounting with
00:46:07 with cellotex products so you weren't aware whether there were any other discounts no
00:46:11 no did you ever get similar discounts from any other insulation manufacturers on other projects for example rockwool i wouldn't be aware of them as they were [Applause] so i now we're still sticking with the
00:46:24 so i now we're still sticking with the insulation i now want to ask you about a request for information in september 2014 um and i'm just going to
00:46:33 to explain or follow through how this came about if we can turn to har40s 3638
00:46:45 and i want to start this is an email chain from september 2014. i want to start
00:46:51 start at the bottom of this chain at the bottom of page four and it begins with you there 17th of september 2014 sending simon lawrence of ryden simon
00:47:04 sending simon lawrence of ryden simon o'connor of ryden neil crawford studio and bruce soon you send an email about grenfell tower cavity fire barriers do you see that there yes and you say please find attached rfi
00:47:17 yes and you say please find attached rfi zero zero one which relates to the requirement of fire breaks this may be something that's already been decided or may need confirmation from the local fire officer as to as the opinion tends to vary do you see that
00:47:28 opinion tends to vary do you see that there
00:47:28 there yes so in this email you seem to be having some knowledge of what the local fire officer what their opinion might be and
00:47:39 what their opinion might be and variation in the local fire officer's opinion do you agree i think this just goes back to my previous statement that even the people in authority did not fully understand the requirements and it
00:47:51 fully understand the requirements and it would just vary from place to place i'm not stating that i know what that particular fire officer is going to want okay it's because of that can that
00:48:05 lack of clarity that we asked that question
00:48:09 question now if we turn to that rfi document which was attached to the email this is a exo401291
00:48:23 we can see that this is a request for information form it's a harley form it's to simon lawrence at ryden and it's from you at harley do you see that there yes 17th of september 2014 and you require
00:48:36 17th of september 2014 and you require an answer by the 26th of september 2014 and we can see that the query please may you confirm the required extent of the horizontal fire breaks within the cladding areas do you see that there
00:48:47 cladding areas do you see that there yeah and then you've put suggested solution
00:48:51 solution we believe that they will be required at every floor level on the vertical columns
00:48:55 columns but not in the area of cladding between windows
00:48:59 windows this is because there is no chimney effect here and therefore the cladding will not add to the spread of fire do you see that yep now did you draft that
00:49:08 that did you did you put that document together yeah i drafted
00:49:14 so do you agree that this suggests that you
00:49:17 you are professing to have some knowledge or expertise in where fire barriers are required and whether or not there's going to be a chimney effect in certain parts of the
00:49:28 chimney effect in certain parts of the cladding
00:49:29 cladding relevant to the spread of fire do you agree i think that i didn't fully understand it at that point and i think i was just being asked to send
00:49:40 i think i was just being asked to send an rfi
00:49:41 an rfi i can't remember by who but i was asked to send an rfi because i wouldn't have had enough knowledge to be able to put that together
00:49:51 together so you're suggesting that these this detail these words were not your own is that right yes that somebody else asked you to send that yes
00:49:59 that yes and who would that who could that have been it could have been mark it could have been ray could have been kevin
00:50:10 right and the part about this is because there is no chimney effect here and therefore the cladding will not add that was not your opinion is that what you're saying i at that time i knew that you were trying to stop the uns seen spread of fire but i didn't
00:50:23 the uns seen spread of fire but i didn't really know i would suggest sorry i didn't know much about it
00:50:29 about it well i suggest to you that this does indicate you were expressing an opinion about the spread of fire and what was required
00:50:38 required in terms of fire spread in there in the external cladding
00:50:44 i would disagree
00:50:48 do you know what analysis had been done to get to this view
00:50:53 no because i didn't know about where fire breaks were really required
00:51:01 now if we return to the email chain if we go back to har four zeros three six three eight on page four at the top of the page we can see that on the 18th of september
00:51:15 yes that's it 18th of september neil crawford of cdoe sends that on to terry ashton at x over do you see that there yes and he says hi
00:51:26 do you see that there yes and he says hi terry i'm working on the grenfell tower project
00:51:28 project for studio e the following rfi has come in relating to horizontal fire breaks within the cladding areas can you comment on the rfi attached and whether you believe this interpretation in relation to stack effect is correct
00:51:40 in relation to stack effect is correct regards neil you see that there yes and then at the bottom of page three
00:51:48 we can see that mr ashton responds with this he says neil i've never seen details
00:51:57 details of what you're doing to the external walls do you have any cross-sections elevations kind regards terry you see that there yes i think we'll see that you get copied into this chain later
00:52:09 into this chain later did it concern you that the fire safety consultant hadn't seen any details of the proposed works to the external walls i wasn't aware of it at that time
00:52:20 i wasn't aware of it at that time it's i don't think i would have read down the whole email chain if i got copied back in it later on i see read the response so you didn't think at the time that you
00:52:31 so you didn't think at the time that you ought to send some details as a matter of urgency to the fire engineer on the project
00:52:36 project on all other projects the you usually send the information to the main contractor and they send it out to
00:52:47 main contractor and they send it out to the consultant
00:52:51 or the architect
00:52:55 now after acts over we're provided with some harley plans mr ashton then replies on the 18th of september
00:53:03 september 2014 so same day at 15 32 if we go to the bottom of page two in the top of page three
00:53:16 so we if we look at the very bottom it's there's an email we can just see the start of it from terry ashton 18 september 1532 from terry ashton if
00:53:27 18 september 1532 from terry ashton if we go over the page he says it's to neil crawford neil if the insulation in the cavities behind the rainscreen cladding is combustible you will need to provide cavity barrier
00:53:38 you will need to provide cavity barrier as shown on your drawing number one two seven nine zero six one twenty
00:53:43 twenty in 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 kind regards terry do you see that there yes
00:53:56 do you see that there yes and then if we go up um
00:54:04 one page up to the bottom of page two we can see neil crawford sends you that chorus that email chain neil crawford to daniel lancaster jones 18th september 1550.
00:54:17 18th september 1550. daniel please see correspondence relating to rfi zero zero one cavity barrier requirement below do you see that there yeah regards neil so he's pointing you to that correspondence
00:54:28 to that correspondence yep are you saying now that you didn't read down those emails and have a look at what was the debate was i would have looked at his response but not gone any further i can't remember
00:54:40 not gone any further i can't remember going any further now mr ashton has said if the insulation in the cavities is combustible you will need to provide a cavity barrier as shown on the drawing
00:54:51 barrier as shown on the drawing what was your reaction to that advice do you remember no i don't remember do you remember whether you agreed with it or they had any concerns with it i wasn't able to make a judgment
00:55:04 i wasn't able to make a judgment okay so you didn't ever query why mr ashton appeared to be linking the combustibility of the insulation to the requirement for cavity barriers that wasn't something that you ever queried
00:55:15 queried not that remember
00:55:18 did you think about what guidance mr ashton might be referring to when he gave this advice
00:55:25 the building regulations i would have assumed at that point but you didn't check at that point and look at say approve document b to see what he might have been referring
00:55:36 to see what he might have been referring to no because we would always refer back to them for the guidance and follow what they told us
00:55:45 now this advice if we go up the chain to your email immediately above back to neil crawford
00:55:55 if we can scroll up yeah so then you say daniel lancaster jones 18th september same day 1603 to neil crawford cc and simon lawrence and others at
00:56:06 cc and simon lawrence and others at ryden
00:56:07 ryden neil thank you for your response the installation is class naught therefore after reading the correspondence below i believe that the fire barrier in these
00:56:18 i believe that the fire barrier in these locations will not be necessary can you confirm that this is acceptable do you see that there yes now i'm going to ask you some questions about that but i just want to show you another version
00:56:30 i just want to show you another version of that email so i can make good the point that actually when you sent that email
00:56:35 email here we're seeing it in a chain but when you sent it you also attached the celetex rs5000 datasheet so if we can pull that up now so this is at
00:56:56 har3012103 so you can see at the top of that so this is a harley version of that email and we can see at the top of that page that here we can see that there was an attachment rain screen cladding product
00:57:09 attachment rain screen cladding product data sheet august 14 pdf do you see that at the top yes
00:57:12 yes so it's the same email but we can see here that there was the attachment and i just want to pull up the attachment this is har3012104 so it's the next email in the harley
00:57:25 so it's the next email in the harley document is the next document in the harley run of docs and this is the rs 5000 celetex data sheet do you see that yes
00:57:42 now um was this the first time that you provided studio ian ryden with any indication that the installation was going to be rs 5000
00:57:56 i i honestly don't know you don't know i was assumed that they were completely aware of what was going to be on there and you know
00:58:08 on there and you know at that point i believed that they were the same product as that was in the nbs specification
00:58:16 if you if you thought it was the same products in the nbs specification why were you attaching this rs 5000 data sheet for them to see why were you telling them what the
00:58:28 why were you telling them what the product was i would always do that on all projects would be to send them the actual data sheets can we go back to the email again and look at it har3012103
00:58:43 you say the insulation is class naught therefore after reading the correspondence below i believe that the fire barrier in these locations will not be necessary do you see that there yes so do you
00:58:55 do you see that there yes so do you agree that you are giving advice in this email about what your opinion is of um the fire classification of the insulation and whether that
00:59:06 insulation and whether that means that fire barriers are necessary in certain locations do you agree no i disagree i think that this shows that i
00:59:14 that i didn't understand the fire classifications i didn't know where fire barriers were required and that i believed that it was up to
00:59:26 and that i believed that it was up to the consultants to tell us where they needed to go
00:59:31 if that's right why didn't you just respond saying i can't help you i don't know about fire classifications you need to direct your question to the fire consultant or studio e
00:59:43 fire consultant or studio e but this is me asking them a question to start with they've come back with another answer and i'm asking them if my interpretation of their answer is correct what's happened is mr ashton has come
00:59:54 what's happened is mr ashton has come back and queried whether the installation is combustible and said if it is combustible you'll need to do certain things and you've been asked for your response to that and you have said the insulation
01:00:05 to that and you have said the insulation is class naught therefore after reading it
01:00:07 it this correspondence i believe that the fire barrier in these locations will not be necessary i'm going to put it to you that this is you offering your opinion on fire performance
01:00:18 performance now this is me asking if my interpretation of what they've said is correct that they've come back and said that it's if it's combustible you have to do a
01:00:29 to do a i've gone back and said well it's class o so does that mean we can do b
01:00:35 well it goes a bit further than that doesn't it because you do seem to be venturing an opinion of your own on the basis based on what he's replied
01:00:51 and then you know it's clearly stated at the bottom i'm asking whether that's right
01:00:58 right it would seem to reflect your view of what's meant by class naught would that be fair yeah at that time i wasn't trained in fire at all and he sent back something about that it
01:01:09 and he sent back something about that it was
01:01:10 was about what happens if it's combustible or not combustible and i've gone and looked at the sheet and seen that it's class o so i've sent it back to him asking him if
01:01:20 if the interpretation is correct
01:01:27 why did you think it was relevant to tell people that the insulation was class naught what did you think the relevance of that was
01:01:36 was at that time as i said before i wasn't trained or taught about fire classifications i'd looked at the sheet and that was the only thing that had seen on there so i sent it back to
01:01:49 had seen on there so i sent it back to him
01:01:50 him i see and was that the only check you carried out to look at the data sheet before you responded
01:01:59 yes that was that was at that point in my career that was all i would have known to
01:02:04 known to you didn't check with anybody else or check any other guidance before you responded
01:02:08 responded no i was i wouldn't have known what else to look for at all i was a structural engineer at that point
01:02:27 i think if we go back to the the long email chain har403638
01:02:39 sorry it's not that one i think there was a
01:02:42 was a what we see is there was another request for you to confirm that's right sorry it was in mr ashton's yes go back to that har403638
01:02:53 har403638 um and we look at mr ashton's reply that you were being asked to comment on so that's the bottom of page two yet and on to the top of page three if we go to page three
01:03:08 he says if it's combustible you will need to provide [Music]
01:03:14 [Music] even if there isn't a continuous cavity from the top to the bottom of the building
01:03:18 building and did you ever confirm whether there was a continuous cavity from the top to the bottom of the building
01:03:29 no did you ever go back to mr ashen or mr crawford about the extent of the external wall cavity no i think in this email chain it's only talking about the
01:03:40 talking about the the parts between the windows so i don't think that part had been discussed yet
01:03:49 do you agree with me that more relevant questions about the installation insulation were whether the insulation was of limited combustibility or whether the system had been tested to
01:04:01 or whether the system had been tested to br 135 and 8414 won't wasn't that where the debate should have gone
01:04:07 gone looking back on it now with that knowledge about fire performance for products and testing of products yes but at that point i had no training in that respect
01:04:18 that respect which is why i always referred it on to fire engineers now if we now turn on and we look at a further development on this chain to
01:04:29 further development on this chain to har403638
01:04:38 har403638
01:04:45 what we see here is in the top email mr crawford
01:04:51 is emailing terry ashton and see seeing you
01:04:56 you on the again this is all happening on the 18th of september 2014 on the same day this is now at 17 11. and he says hi terry thank you daniel
01:05:07 and he says hi terry thank you daniel can you confirm your position in relation to terry's comment below regarding combustibility and continuous cavity paths having just finished several weeks of fire stopping checks on the kensington aldridge academy where john hope and
01:05:18 aldridge academy where john hope and crawled into almost every conceivable cavity possible with a torch including nearly falling through a suspended ceiling we need to be clear on our position before going to building control
01:05:28 control regards neil so would you agree that even though you're only cc'd into that there's a part of that email from mr crawford that's directly addressed to you do you see that yes i can see that and if we look down
01:05:40 can see that and if we look down at what terry ashton said below that he said this neil a material which has a class naught rating is not necessarily
01:05:51 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 in any case you need to prevent fire
01:06:02 in any case you need to prevent fire spread from i think it means one flat to the flat above as i stated in my earlier email 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
01:06:14 any part of the cladding apart from around the column casings irrespective of the type of insulation do you see that there yes so that's the advice terry ashton was given was giving
01:06:25 given was giving and your sent that can you recall what was your reaction to that i i can't recall i i believe that
01:06:36 i i can't recall i i believe that from seeing information later on that we put in cavity barriers at every floor level so we must have taken on board what he was saying
01:06:49 board what he was saying but what was your reaction in terms of what he's saying about the insulation because what he's saying there is a material with a class naught rating is not necessarily non-combustible some class naught products will burn
01:07:01 some class naught products will burn when exposed to a fully developed fire isn't that potentially warning you that class naught is not enough
01:07:12 honestly at that point i didn't understand the difference and if i'd read this i i can't remember what i would have thought well we know you're sent it and you're specifically asking questions about it
01:07:24 specifically asking questions about it by mr crawford
01:07:27 did this email called you any concern about
01:07:31 about your statement that the insulation was class naught
01:07:36 i can't remember i can't remember do you know whether it in any way caused you to reconsider the assessment of whether celotex rs 5000 was suitable for grenfell tower i was
01:07:49 for grenfell tower i was under the impression that the celetex product had been already approved by the architect and building control officer and the fire engineer so
01:08:02 the fire engineer so it wouldn't have occurred to me to question them i see so even though the the fire engineer is coming back and saying to you um class naught you've
01:08:15 and saying to you um class naught you've got to be careful around class naught it's kind of that's me paraphrasing what he said in the first couple of lines you're saying that didn't prompt any reconsideration in your mind
01:08:26 reconsideration in your mind about whether or not to use rs 5000 for the grenfell project no because i thought that all those people had already approved the product did you ever raise the combustibility of
01:08:37 did you ever raise the combustibility of the insulation with anyone at ride in x over or studio e did you ever independently raise that question with them no
01:08:46 and can you remember ever going back um about uh your position in relation to terry's comment below about combustibility and continuous cavity
01:08:57 combustibility and continuous cavity past if we go back to the email at the top
01:08:59 top neil crawford is asking you to confirm your position can you confirm your position in relation to terry's comment below about combustibility and continuous cavity
01:09:11 combustibility and continuous cavity bath
01:09:12 bath we can't find any response do you know whether you ever did respond to that email
01:09:16 email i can't remember you can't remember what what advice you gave at that point did you ever take any steps after this to investigate further whether the rs
01:09:27 to investigate further whether the rs 5000 product was compliant no because as far as i was concerned it had already been checked for compliance by people who
01:09:38 checked for compliance by people who understood it far better than i did did you speak to celetex again to get any more information and to raise with them
01:09:46 with them the fact that class naught might not be the the entire answer to whether it could be used at grenfell no because this this didn't jump out at me
01:09:57 jump out at me at that time i have no memory of it
01:10:01 now i want to put it to you directly before we move on from this topic that if you look at the emails as we've done today between you and mr room in august 2014 when you're discussing the quantity
01:10:13 when you're discussing the quantity of rs 5000 to use on the grenfell project
01:10:17 project and you also put it together with this email chain a month later in september where you
01:10:21 where you forward the rs 5000 data sheet and you say the installation is class naught
01:10:28 naught i want to put it to you directly do you accept that it appears to have been you as the person within harley who took the decision to use rs 5000 on the grenfell project
01:10:39 project no it was decided long before i was involved i never put the product forward never selected it never made any decision about using it on the project
01:10:50 decision about using it on the project so can you help us as to who within harley
01:10:54 harley did authorize the use of rs 5000 from a heart from harley's own perspective
01:11:01 i don't know okay
01:11:07 mr chairman i think that would be a good moment for a break because i want to move on to another topic and i just would like five minutes to review my questions yes well let's have a break we'll have a short break now
01:11:18 break now mr uncle jones will they'll come back to half past three and then let me give you a little bit more time to organize yours yeah thank you
01:11:26 you all right uh no talking to anyone about your evidence please while you're out of the room
01:11:30 the room and say if you'd like to give the our show she'll look after you thank you
01:11:41 show she'll look after you thank you good how fast three of them please
01:30:26 yes would you ask mr ankertel james to come back in please
01:30:42 all right ready to carry on yes good thank you yes hi there yes just to pick up one discreet topic um that arose yesterday which was about cvs do you remember we looked at your cv that ryden had put forward
01:30:54 that ryden had put forward as part of its tender proposals um and you said um yesterday that there were certain parts of that cv that weren't accurate like you're involved in the chalcott's estate
01:31:05 you're involved in the chalcott's estate do you remember that yes um and you said that it that that cv was produced without your knowledge of consent can we just look at a document
01:31:16 document relevant to this story this is ryd402798
01:31:26 so this is an email you're not copied in here
01:31:30 here from mark harris to simon lawrence on the 6th of february 2014 and it's seating mike alveston and katie batchelier there
01:31:43 and it's about cvs he says morning simon please find attached cv summaries of three members of the harley design and delivery team there will also be a project specific
01:31:54 there will also be a project specific site manager but at this stage i could not confirm a name i've purposely kept each cv to a single page but can elaborate on experience and qualifications for each individual if so desired
01:32:04 desired alternatively i can send a full cv for each do you see that yes and then we can see that the cvs that were sent were for you mark stapley and rob maxwell and those
01:32:15 mark stapley and rob maxwell and those are the three cvs that we see in the ryden tender package now we've checked those cvs that are sent
01:32:24 sent there by mark harris and they are identical to the ones that we showed you yesterday in the ride and tender including your cv um now what i want to ask you i
01:32:36 um now what i want to ask you i appreciate you're not involved in this here
01:32:39 here did mark harris check with you whether your cv was accurate before it was sent not that i have any recollection of no do you remember having a chance to review the cv before it was sent out
01:32:51 review the cv before it was sent out i didn't even know it had been sent out can you help us as to how mark harris might have sent a cv relating to you that had inaccuracies
01:33:03 relating to you that had inaccuracies no i i have to ask him okay
01:33:11 him okay um now i know i want to turn to um a bit of a more detailed look at exactly how the design process worked on the grenfell project and in
01:33:22 worked on the grenfell project and in due course i'm going to take you to look at the um process for approving drawings
01:33:27 drawings on the grenfell project and so that's this topic um just to kick that off did were you aware that there were any
01:33:38 did were you aware that there were any regular design reviews carried out during the grenfell project either formal design reviews or informal design reviews
01:33:49 reviews that happened with kevin lam
01:33:53 i would have expected that he would have been sending the drawings to the architect and design team for their review but did harley have any kind of processes in place
01:34:05 processes in place to if you'd like kind of draw a line in the sand and take stock of where the designer got to and review the design as it went through or was that was kevin lam just left to get on with dealing with the drawings
01:34:18 to get on with dealing with the drawings and sending those to ryden and studio e as appropriate he was left to do the work yes
01:34:28 did you personally check the drawings that were being produced by kevin lam no you didn't you don't have any memory of doing that no i have a memory of passing
01:34:39 no i have a memory of passing some on to the managing director for him to check
01:34:42 to check but i was working on another project okay
01:34:46 okay we'll look at some emails relevant to that in a moment do you accept that you were regularly copied into emails on the project
01:34:54 project from what i've been showing yes yeah so even after mr lam's appointment you were regularly copied into emails about the project
01:35:00 project yes for a period when you say for a period what do you mean by that at some point i became completely
01:35:11 at some point i became completely uninvolved with the project i can't remember when it was but i think that at some point i stopped receiving emails on the project
01:35:23 and can we just look at something that mr albeston has said in his witness statement about your role if we look at h a r three zeros one oh one five one page three paragraph nine
01:35:38 i want to pick up so this is mr alveston's witness statement three lines down he says this the specification was also
01:35:50 he says this the specification was also reviewed by daniel anchored jones harley daniel ancatel jones would have been looking at the tender documents from a more technical and design point of view
01:35:58 of view for example he would be looking to see that the materials specified were suitable for that job do you see that there
01:36:04 there yes and i wanted to give you the chance to respond to what mr alberton said there about your role do you agree with his description no i think that again it's a um
01:36:15 no i think that again it's a um there's confusion in time frames because at this point i hadn't i wasn't educated enough or hadn't done enough of the msc to be able to be responsible for those
01:36:27 to be able to be responsible for those sorts of things i just want to look at some exchanges between you and mr lam let's just start with the witness statement of kevin lam this is har3010419
01:36:40 this is har3010419 at page five and i want to look at paragraph
01:36:44 paragraph 22.
01:36:50 so if we look down there um so he's talking about some studio e drawings forming the basis of his design along with discussions with both daniel ankartal jones and ray bailey do you see
01:37:02 ankartal jones and ray bailey do you see that
01:37:03 that yes and then he says this i sent preliminary key concept general assembly drawings on 20th of august 2014 to daniel anchor jones for his input and approval
01:37:14 jones for his input and approval to issue to ryden and studio e do you see that there yes now do you remember being um sent those key concept general assembly drawings by kevin lam
01:37:26 drawings by kevin lam i don't remember but i've been showing the emails where it happened and you agree that it did happen yes yeah can we look at another example so if we go to
01:37:37 go to har four zeros three six three four
01:37:44 this is the 22nd of september 2014 if we look in the email at the top from you to kevin lamb subject grenfell design kev could you wait make one change
01:37:56 kev could you wait make one change detail 304 change it to two angles in the shadow gap to allow for tolerance these can be issued then will you be able to attend tomorrow's meeting will you be able to table the other details then
01:38:08 other details then kind of regards daniel do you see that there yes
01:38:11 there yes so you said earlier that you um weren't personally checking any of the drawings that were produced by kevin lamb do you agree that this suggests that you did
01:38:22 suggests that you did sometimes check the drawings i would have been checking them for structural requirements and sort of fabrication things to make sure that
01:38:31 sure that they could be installed i would expect that everything to do with
01:38:38 other elements performance that i wasn't concerned with to go back to the architect and building control such as you know conformity to building
01:38:49 you know conformity to building regulations these were you know looking at them from a point of view of structural performance and whether it could be fabricated i see and what's this an example of
01:39:01 i see and what's this an example of angles in the shadow gap would you say that's fabrication yeah can we look at some more examples if we go to har403636
01:39:13 if we go to har403636 it's on the 25th of september 29 sorry 2014 and
01:39:20 2014 and we can see from the bottom email that kevin said please check attached the vents do not quite manage 5000 meters squared millimeters squared increasing the vent
01:39:31 millimeters squared increasing the vent width we'll get that and however didn't you mention only 2 500
01:39:37 500 millimeters squared when we were at the meeting regards kevin and then above that
01:39:45 you've said these look fine to me can you issue them to everyone please do you see that there yes and we can also see you um potentially amending drawings in
01:39:56 potentially amending drawings in november 2014. if we go to har
01:40:06 403785 this is on the 20 20th of november from mark stapley to kevin lam cc'ing you and rob maxwell and you say
01:40:18 cc'ing you and rob maxwell and you say hi kevin thanks for sending over the drawings dan is going to modify die drawings ex03 and o4 so we can reduce the width to 120 millimeters this will be achieved by increasing the
01:40:30 this will be achieved by increasing the wall thickness on the leg with the serrated edge do you see that there yes so that suggests that you were going to modify a drawing at that point or drawings yes do you agree these were the
01:40:41 yes do you agree these were the structural drawings for the dyes right i would have been involved in that yeah
01:40:49 then can we move on to the 7th of may 2015 this is
01:40:55 har404089
01:41:02 and this is grenfell tower 7th of may 2015 so much further on in time and you say hi kev when you get a sec would you mind sending me the latest drawing model for grenfell
01:41:12 grenfell i'm trying to catch up with all the calcs thanks dan do you see that there yes um and then the response is at har404224
01:41:24 and then the response is at har404224 if we can look at that and there he says kevin
01:41:35 and there he says kevin dan attached however the layout has become a bit messy so please call if you can't locate the info you want do you see that there yes can you help us as to what you were going to be checking on these
01:41:47 you were going to be checking on these drawings so i would have for every project they need a set of structural calculations through the design process you do each bit
01:41:58 bit as it's required and submit it and then you
01:42:01 you probably do a complete tidy up at some point i think it was just trying to do a tidy up and make sure that everything was as had been drawn so all the right angles were aligned
01:42:15 so all the right angles were aligned with what was in the calculations before you know doing a final submittal right yeah did you ever come across any issues with mr lam's work whether one-off issues or
01:42:26 mr lam's work whether one-off issues or recurrent issues did you ever have cause to speak to him about his design work no
01:42:33 no and just going back to how much time you were spending on the project we know that you were doing the facade degree part-time um is it right i think
01:42:44 degree part-time um is it right i think you said yesterday that it was was that one day a week you were taken out studying on that course you'd have a week out at a time
01:42:52 a time and then you'd usually have a week to do the
01:42:56 the work that had been set afterwards so during the time you were doing that course
01:43:02 course what what would you say what percent of your time for harley was taken out by doing that course would you estimate
01:43:17 i think over the course of the year would be eight weeks yeah okay now we can see later in the project
01:43:26 project that there are examples where many drawings are issued without your approval or prior review um let's just look at an example of that this is sca three zeros one three three five five o
01:43:49 so this is kevin lamb on the 18th of august 2015 so later in time to simon lawrence copying in ben bailey mark stapley you ray bailey
01:44:00 bailey mark stapley you ray bailey neil crawford and there's a lot of drawings
01:44:04 drawings ga are they general arrangement drawings that are being issued at that time do you see that there yes and he says neil please find attached these are curtain wall drawings
01:44:15 attached these are curtain wall drawings all now issued for construction based on your comments 7th of august 15. the only item that's deviated from your markups are the internal jam flashings on drawing 352.
01:44:26 on drawing 352. do you see that there now they seem to be curtin wall drawings does that mean they were probably about the lower levels of the tower yes in practice
01:44:37 yes in practice how did you decide which of mr lam's drawings to check i mean was that was there some kind of system or um
01:44:49 system or um practice that you were following in terms of what you would be checking of his work and what you wouldn't check no
01:44:55 no it would only be from individual discussions sometimes he'd send something to me and i might print it off and take it up to ray to look at but generally it would be
01:45:07 but generally it would be almost entirely kept to the structural parts because he had prior knowledge of you know detailing and fabrication
01:45:18 of you know detailing and fabrication to be able to proceed on his own at this point i just want to ask you some more detailed questions about the process for approving or signing off on drawings
01:45:29 drawings um can you explain to us in general terms what the process was by which drawings were issued by harley and then checked and signed off what was your understanding of the process that
01:45:40 your understanding of the process that was followed at grenfell on grenfell i'd only been making an assumption i can tell you what it was on other projects and how grenfell
01:45:53 other projects and how grenfell would have worked from that so does that mean
01:45:56 mean at the time you weren't aware of what the process was no i wasn't i wasn't submitting drawings or getting comments back i was primarily
01:46:07 getting comments back i was primarily concerned that the work was happening how would kevin lam if you're if you're line managing kevin lam you're the design manager and he's the project designer how would he know what the
01:46:18 designer how would he know what the process was for getting drawings issued and approved and
01:46:23 and signed off if if you don't know how would he know any time that we brought in an external designer before it wasn't like the designers in the office you're trying to bring in someone who's
01:46:35 trying to bring in someone who's competent and capable of running on their own
01:46:38 their own and with an external designer the checks you're doing is making sure that they're keeping the program so does that mean you expected kevin lam of his own back to
01:46:49 of his own back to be in touch with ryden and studio e to discuss what the process was for approving drawings yeah as the as the designer on the project
01:46:59 project that's what you'd expect i see so that was your expectation was was it and did you understand that kevin lam was doing that was checking with ryden and others what the process was for approving drawings
01:47:13 i would have thought that that's what had happened yes can we just look at a few examples of what seemed to happen with some of the drawings in terms of the the process for getting them
01:47:25 the process for getting them finally signed off and approved for construction um can you turn to sea three zeros one two seven
01:47:31 seven five six and i want to start by looking at the email at the bottom of page one and over onto page two
01:47:41 so right at the bottom there we see on the 17th of february 2015 at 1104 kevin lam is sending an email to neil crawford bruce soon's you mark stapley rob maxwell ben bailey
01:47:55 mark stapley rob maxwell ben bailey and if we go over to the next page he says
01:47:59 says he says sign sorry we just need to look at
01:48:02 at is that the very top of that page
01:48:09 can we maybe go back to the bottom of page one yes sorry it's important to note he's addressing that to simon do you see that simon lawrence do you see that there at the very bottom of the page
01:48:20 page yes the email of 17th february 1104 simon says this is simon lawrence of ryden and then over the next page he's saying
01:48:29 saying please find attached revised type 10 windows now with symmetry as requested please approve and forward your official instruction for us so that as we can proceed with remakes of those in
01:48:41 proceed with remakes of those in manufacture to see that there yes so this is kevin lam
01:48:45 lam sending to simon lawrence for approval now looking up this email chain if we go back
01:48:53 back onto page one we can see that neil crawford at studio e then responds on the same day at 12 12. hi kevin please see attached comment
01:49:05 12. hi kevin please see attached comment do you see that there yeah so kevin lam is addressing his initial email to simon lawrence but it's neil crawford who's responding first um do you see that there
01:49:16 first um do you see that there yes who on your understanding was responsible for checking and approving the drawings for construction it would have been the architect the architect
01:49:26 architect neil crawford so not ryden
01:49:32 no
01:49:35 and what would that checking and approval process actually entail did you have an understanding of it not not on grenfell it was never specifically spelt out
01:49:46 specifically spelt out i would be i'd be guessing okay now if we turn to um the drawing that mr crawford attaches with his comment if we go to sca403093
01:50:04 this is mr crawford's annotation on that drawing and we can see what he's done i think he confirmed that was his writing in red do you see that there yes so he's made a comment
01:50:17 yes so he's made a comment better to hinge this way as per sketch of email do you see that there yes and he's marked it in the stamp on the right hand side the studio e architect stamp he's marked it status b
01:50:31 um now it's a little bit difficult to read here but what status b says there is conforms to design intent subject to incorporation of comments revise and resubmit for category a
01:50:43 revise and resubmit for category a status do you see that there yes now was it your understanding on the project that in these circumstances the drawings did have to be resubmitted
01:50:54 drawings did have to be resubmitted after incorporation of neil crawford's comments
01:51:03 sorry can you re-read the bit in is not clear
01:51:06 clear yeah you want you want me to reread the category b comment absolutely yeah so what it says is conforms to design intent subject to incorporation of comments
01:51:17 subject to incorporation of comments revise
01:51:18 revise and resubmit for category a status
01:51:23 now my question to you is was it your understanding in these circumstances so where it's marked category b it's not a it's not conformed to design intent
01:51:33 intent was it your understanding in those circumstances that the drawing should be resubmitted to the architect after incorporating the comments they've made
01:51:47 trying to look back on it i have no memory of
01:51:51 memory of any conclusions i would have drawn on this yeah
01:51:58 so you can't help us as to whether it routinely happened on the project that the drawings would be resubmitted to get the category a status no i i can't help you on that
01:52:09 no i i can't help you on that now also on this drawing we can see a printed stamp on the bottom right of the drawing if we zoom out again
01:52:20 can you see there someone's put approved for construction on the bottom there's a stamp there do you see that yes
01:52:28 now do you know who applied that stamp or he would have applied that stamp to this drawing
01:52:38 i don't know who did it no it appears to be to us to be this is a harley drawing it appears that harley had stamped it approved for construction before it had been reviewed by neil
01:52:51 before it had been reviewed by neil crawford
01:52:53 crawford and his stamp i mean there's a lot of revisions
01:52:56 revisions there i mean how would you know he hadn't
01:53:01 hadn't checked it at one of those previous revisions
01:53:05 revisions right well i think we've tried to check and we're not aware that this drawing did get category a status prior to this um were you aware um on other drawings
01:53:17 um were you aware um on other drawings of of
01:53:17 of of it being these drawings being approved for construction with that kind of stamp before they'd been sent to studio e or indeed ryden no i wasn't aware
01:53:33 whose role would you have thought it was to apply that approved for construction stamp
01:53:38 stamp on the project it would it would be the designer's role to put that on on their interpretation of that statement next to the bee so would
01:53:51 that statement next to the bee so would you expect mr lam to be applying that approved for construction stamp after they've got a category a from the architect
01:54:01 architect i think rereading this now i would still read that as that you re-submit it with those in comments
01:54:12 re-submit it with those in comments incorporated means it is that it has a category
01:54:19 i see so you're saying that we can read this not as a category b but as category a assuming these comments are going to be incorporated yes but wouldn't the architect want to check that
01:54:30 check that whatever comments have been made had been properly transposed over to the next
01:54:35 next version of the drawings i mean talking from experience now it it's commonly done that way that the architect will put his comments
01:54:46 that the architect will put his comments on the drawing and he will status it that if the draw if those comments are incorporated it can be assumed that it's a status a but that's not what the b stance says
01:54:57 but that's not what the b stance says here is it no it's reading it now that's the way that i interpret it i see
01:55:06 um so just following the the story of this drawing a bit further if we go back to we go to sea three zeroes one two seven
01:55:15 seven five eight
01:55:23 this is a further email from kevin lam on that day 17th february 2015 to simon lawrence again see seeing neil crawford and others including you
01:55:34 including you on the grenfell project and he says simon the window mods are now approved by neil as attached so all we need now is your official go-ahead to proceed do you see that there yes so was it your
01:55:47 do you see that there yes so was it your understanding that ultimately simon lawrence of ryden had the final responsibility for approving the drawings for construction no i didn't have that understanding
01:55:59 no i didn't have that understanding who was it you thought was responsible for approving the drawings for construction to prison for construction i would have thought it was the architect
01:56:12 i see do you think this might have been a special case where harley or kevin lam here wanted an instruction from ryden over and above the normal process to proceed with
01:56:23 proceed with the drawings i don't know what the time frames are here but i would have thought it was a again i'm just guessing that it was to
01:56:34 again i'm just guessing that it was to do because it was ordering materials and he wanted to be certain
01:56:39 certain that everyone was happy with it right and if we just finish this off um if we go sea three zeroes one two seven
01:56:46 seven six one we see simon lawrence siren lawrence replies to this chain
01:56:54 now we have that again you're copied in hi kevin neil has completed his comments and is happy so you can proceed do you see that there yes so you can't help us as to whether that process was typical
01:57:07 that process was typical of the process that was adopted for assessment and approval of drawings on the project not for this project
01:57:16 would it be fair to say that this step-by-step process did not always occur in such a clear manner in respect of amendments to an approval of harley drawings
01:57:28 sorry can you repeat the question would it be fair to say that this step-by-step process
01:57:32 process sending it to ryden waiting for the architect comments getting it back then ryden confirming again that they're happy that step by step process didn't always occur in respect of
01:57:44 didn't always occur in respect of amendments to and approval of harley drawings would you agree with that
01:57:51 i was under the belief that process of sending them to the architect and getting them approved did always happen
01:58:00 let's look at another example if we go to sea three zeroes one three two two one
01:58:13 and i want to look at the second email at the bottom of page one this is 29th of may from kevin lam to simon lawrence see seeing the same individuals in
01:58:25 see seeing the same individuals in and he writes neil please find attached drawings for the crown element for approval
01:58:31 approval do you see that there yes so although the email is being sent by kevin to simon lawrence it's being addressed in the body of the email to neil crawford do you see that there
01:58:42 there yes and
01:58:45 yes and can you help us as to why he would have sent it to simon but addressed it to neil
01:58:50 neil no i can't we can then see at the top of this email chain that kev that neil sorry responds to kevin and says please find attached comments on the crown drawings do you see that there yes and if we look
01:59:02 do you see that there yes and if we look at the attachment to that this is
01:59:14 ryd3043547 ryd yep and i want to look at page four
01:59:25 and we can see that um neil crawford has stamped the drawing status b
01:59:33 and annotated the drawing regarding metal copings and flashing at the roof parapet do you see that there there's a the red comment and the
01:59:44 there's a the red comment and the bubbles
01:59:46 bubbles yes it says um existing roof parapet requires to be surveyed and metal coping's flashing to fit over do you see that there yes
01:59:58 over do you see that there yes and he's marked its status b again do you see that there yes it's clearly b not a and if we can now turn to sca three zeros one three two six two
02:00:17 we can see from the bottom email that mr lam
02:00:20 lam then sends another email to simon lawrence copying you and others in on the first of july 2015 and he says neil please find attached revised coping detail to the crown element
02:00:33 detail to the crown element do you see that there yeah and he says if you could have a quick look and pass your comments we should then reissue the whole of this element for construction based on your previous approvals yes and he makes another comment about
02:00:46 yes and he makes another comment about the shorter coping and the last line
02:00:50 and then if we go up we can see that mr lambs actually sent it initially to the wrong kneel and then sends it to the right kneel and then neil crawford at the top of that page
02:01:02 neil crawford at the top of that page responds on the first of july hi kevin please see attach regards neil do you see that there and attaches another drawing
02:01:14 if we can look at that that's a sca three zeros one three two six
02:01:20 three
02:01:27 so that we think that's the same drawing and
02:01:31 this time we've got status a window head coping conforms to design intent do you see that there yes in the studio e stamp
02:01:43 and if we keep following the story of this same drawing can we now turn to har four zeros four
02:01:52 har four four zeroes triple four
02:02:02 three
02:02:06 and if we look at this this is from kevin lam to simon lawrence copying in others but again it's addressed to neil
02:02:17 addressed to neil and he says main entrance adjusted as per your further comments this morning cladding drawing just with additional set
02:02:22 set info for the installers do you see that there yes
02:02:29 so it would appear that neil crawford makes some additional comments on the drawing and then neil crawford to kevin lamb no further comments is attached
02:02:43 and if we go to that attachment
02:02:48 if we go sea four zeros three three one zero at page three fca four zero three three one zero page
02:02:58 three
02:03:03 we can see that this is now revision b of the drawing
02:03:10 which was amended on the 26th of august 2015 we can see that at the bottom do you see that there yeah at the start of this
02:03:21 yeah at the start of this chain it was talking about the crown yeah and then this last email it was talking about the main entrance yes but then it's then it's back to this again
02:03:31 this appears to be the drawing that's attached we think by neil crawford and it's mark status a
02:03:42 it's mark status a what i wanted to ask you is in that example it appeared to be neil crawford responding saying hi kevin no further comments as attached whereas before it was sent to simon
02:03:53 whereas before it was sent to simon lawrence
02:03:55 lawrence and again my question is can you help us as to which was more representative of the typical approach to drawings was it simon lawrence or neil crawford who ultimately approved the drawings for
02:04:08 construction i wasn't working closely enough to it to be able to say definitely but it was always my impression that it was the architect who was approving drawings
02:04:24 who was approving drawings can we look now at har404590
02:04:40 this is an email of the 20th of october 2015 from kevin lamb to simon lawrence copying you and others in
02:04:47 in and there's a large number of drawings there
02:04:52 there and he writes um neil so he's addressing it again to neil crawford
02:04:59 please find attached gf curtain wall elements for comment approval do you see that there yes now one of those in the second line of
02:05:10 now one of those in the second line of the attachments the middle drawing is one called c1059ga model 50223. do you see that yes and if we can turn up that drawing this
02:05:21 and if we can turn up that drawing this is sca503316
02:05:33 now we can see clearly here that this hasn't got a studio e stamp so it's not yet been reviewed by mr crawford but we can see in the bottom right hand corner that it's said to be
02:05:44 right hand corner that it's said to be approved for construction do you see that there yes can you help us as to why this drawing would be said to be improver construction when it hasn't yet been considered by the architect no
02:05:57 yet been considered by the architect no i wouldn't mr crawford then replies to the email if we turn to har404669
02:06:19 har404669 and we have mr crawford 22nd of october 2015 saying hi kevin please see attached comments on ground floor
02:06:31 ground floor and then if we turn to the the attachments and the drawing that we were looking at which is the c1059223 drawing if we go to har zero
02:06:46 at page three
02:06:52 [Applause]
02:06:56 here we can see that mr crawford has made a number of comments to the drawing and stamped it status b
02:07:06 do you see that there yes
02:07:11 now following this drawing through mr lam then responds to mr crawford's email this is har404743
02:07:29 so this is kevin lam to neil crawford at studio a 26th of november 2015 and he copies a number of people at harley including you
02:07:41 harley including you but mr lawrence says simon lawrence isn't
02:07:45 isn't copied into this email or sent this email
02:07:49 email and he says neil please find attached gf curtainworld drawings revised in accordance with your comments do you see that there yes and
02:08:00 yes and in the attachments that same drawing c1059ga model 51223a is there and that's revision a of the drawing
02:08:11 drawing and if we can turn
02:08:14 now to har four zeros one nine nine
02:08:20 nine
02:08:29 this is an email on the same date the 26th of november 2015 from ben bailey to mike at lucy at agf their aluminium glass
02:08:40 lucy at agf their aluminium glass facades limited i think they're a fabricator is that right
02:08:45 to be honest and ben braley writes please see our construction issue drawings attached for grenfell tower
02:08:55 and we can see the second email down on this chain is the email from kevin lam returning the revised drawings to neil crawford
02:09:03 crawford if we look down that page that was kevin lam returning them to neil crawford if we go over to the next page you can see
02:09:12 see see that but we can't find any response from neil crawford confirming the revisions are acceptable and stamping the drawing status a and yet it's been sent by ben bailey
02:09:25 and yet it's been sent by ben bailey to the fabricators
02:09:30 and the question that we wanted to put to you is would it be usual for harley to send out construction issue drawings without waiting for studio e to revert with a stamped status a drawing
02:09:43 it wouldn't be normal on other projects no
02:09:47 no do you agree it would be best practice to wait for mr crawford to return having marked the drawings of status a
02:09:56 the only reason that you'd send them out beforehand is if you're trying to get um approximate pricing for something to yeah otherwise it would be best
02:10:08 to yeah otherwise it would be best practice
02:10:08 practice but do you agree that that might deprive studio ian ryden of the opportunity just to see the final version before it was issued for construction
02:10:19 if that was done yes
02:10:24 was there anyone supervising you as the design manager um during the grenfell project so we've talked about your supervision of mr lam but was anybody supervising you as his design manager
02:10:38 i wasn't his design manager on anything more than
02:10:41 more than program and that was to be reported back to the project manager and contracts manager so they would have been interested in how he was maintaining program and it would have
02:10:54 maintaining program and it would have been reported back that way my line manager was mark stapley
02:11:00 stapley but um every time that we bought in an external
02:11:05 external design resource it was that they were competent to do the work under their own steam
02:11:12 steam they might be line managed from a point of view of checking the quality of their work the point of going to a external design resource at that time
02:11:23 external design resource at that time was because you needed someone who was capable and wasn't going to be have to have
02:11:28 have someone shadowing all their work yeah okay
02:11:32 okay um on projects of this size and complexity in your experience would it be normal to have a matrix of responsibilities setting out which contractor or
02:11:44 setting out which contractor or subcontractor was responsible for each element of the design on other projects that was the normal thing to do yeah did you ever query why on the grenfell project there was no such
02:11:56 project there was no such design responsibility matrix i think because of my limited involvement i didn't get involved to that extent so does it follow that you didn't think
02:12:07 so does it follow that you didn't think it was unusual that no such design responsibility matrix had been established on the project on other projects they had been established um
02:12:18 established um i'm not sure if they'd become the norm as they are now
02:12:23 to your knowledge did anyone at harley ever suggest that such a matrix might be helpful on the project no do you think such a matrix would have been helpful on the project
02:12:34 been helpful on the project from looking back at it now yes it would yeah
02:12:40 now i'm going to ask you some questions about the acm in a moment but before we get to that i just want to look at what you say at paragraph 26 of your witness statement
02:12:48 statement about the design process more generally this is har3010149 at page six i want to look at paragraph
02:13:00 26.
02:13:13 h-a-r sorry yeah thank you so if we can read what you say there you say there is a hierarchy in construction design
02:13:21 design where the senior design team consisting of the architects consultants fire acoustic and structural and building controls sit at the top the main contractor sits under this and the subcontractor
02:13:32 under this and the subcontractor designers sit at the bottom the senior design team are seen as the experts
02:13:38 experts and therefore their opinion is always deferred to by everyone sitting below them
02:13:42 them do you see that there yes
02:13:47 now would you agree that harley had a responsibility to consider the viability of the design regardless of any perceived hierarchy
02:14:06 i think harley could only comment on and you know perceive the viability of the design on the areas that they were expected to be experts in
02:14:17 experts in which was the fabrication and installation
02:14:23 parts that that's where their expertise lied
02:14:28 lied you know points such as you know performances were not you know certainly at that time without a technical manager where their experts lie
02:14:39 lie expertise live
02:14:42 do you agree in terms of fire performance that harley could reasonably be expected to provide design input on a project like grenfell
02:14:57 i don't see how they could without their expertise
02:15:03 do you accept that when it came to specialist design input in relation to the facade harley were not sitting at the bottom of the hierarchy when it came to the facade as specialists
02:15:15 facade as specialists harley were actually higher up that hierarchy than you portrayed in that paragraph
02:15:22 only on the points of installation and fabrication you go on to say in the next
02:15:30 next main paragraph um third line down at the top of page seven so if we go over the page
02:15:41 so if we go over the page within paragraph 27 you say this third line down there as far as i was aware the materials were all compliant as they'd all been selected and specified by architects and the specification and
02:15:52 by architects and the specification and drawings had been reviewed and approved by a fire consultant and building control
02:15:56 control i'm not aware of anyone raising any issue or concerns about the materials being used at any stage now we've done a lot and i don't want to go over it again about whether it had been selected and specified by the architects
02:16:08 specified by the architects but i want to ask you a bit about the fire consultant you say and drawings had been reviewed and approved by a fire consultant to see that there yes which fire
02:16:19 to see that there yes which fire consultant are you referring to right if i'm talking about my knowledge then
02:16:26 then i've i would have just known that there was a fire consultant on the project looking back at it now i'd say that was it's over
02:16:33 it's over yeah so you wouldn't have known at the time that it was x over no i wasn't involved enough with the project so would you agree that at the time you wouldn't have known that the architect's drawings and
02:16:45 known that the architect's drawings and the specification had been approved by a fire consultant no i would have expected that to have been done
02:16:54 been done what i was referred to as the stage four design
02:16:57 design did you ever seek any assurances that a fire consultant had reviewed the drawings
02:17:03 drawings no but if i'd been the designer on the project it's what i would have done would it be fair to say that you did not take any positive steps to confirm that a fire consultant
02:17:14 a fire consultant had approved the drawings
02:17:19 it's fair to say that and but it wasn't my position to do that were you ever under the impression that it was harley's responsibility to establish
02:17:28 establish a fire strategy for the cladding design no i would have assumed that that was done before the stage four designed by the architect
02:17:39 the stage four designed by the architect that was something mr soon said in his evidence that's the transcript at day 12 page 1
02:17:44 page 1 6 8 line 9 that it was harley's responsibility to establish a fire strategy for the cladding design you don't agree with that is that no i think it goes back to what you said about having a design matrix
02:17:58 now i want to ask you some questions about the acm mr chairman i won't finish this topic today but if you're happy to sit till half four i'd like to keep going for now yes right thank you can we start by
02:18:10 yes right thank you can we start by looking at the design team meeting minutes on the 13th of august 2014. this is ryd3016885
02:18:29 so this is the design team meeting number one on the 13th of august 2014 and we can see that you are present they're at the bottom of the first column of lists of names
02:18:41 first column of lists of names down anchored jones and kevin lamb we see that there yes and if we go to section seven on page five and read at the bottom at 7.01
02:18:53 7.01 we can see it says planning an overview of the planning application and discharge was given by bc and sl to bring everyone up to speed
02:19:04 that would be simon lawrence and who bc is there um following several months of discussions mock-ups
02:19:14 mock-ups and negotiations the final material submission was forwarded to planners at the end of july formal sign-off is anticipated 29th of august 2014. our feelings are that the risk around
02:19:26 our feelings are that the risk around planning sign-off is now low as the design to date is now in line with the planner's requests sl confirmed that we are to proceed design based on the following criteria
02:19:37 design based on the following criteria champagne colored cladding panels for the main part of the building do you see that there yes rain screen cladding to be cassette hidden fixing type and then he goes on about other aspects of it
02:19:49 of it um was it your understanding by this point so i think this is the first design team meeting and and you're there was it your understanding that by this point the decision had been taken to use the
02:20:01 decision had been taken to use the rainer bond rain screen cladding panels yes did you understand at the time that the product was formed of two thin sheets of aluminium with a low density
02:20:13 sheets of aluminium with a low density polyethylene pe core did you understand that at the time i understood that it had a a core but i didn't understand what it
02:20:24 a core but i didn't understand what it was
02:20:26 was can you explain why you weren't interested in the call why was that not something you wanted to know
02:20:33 know as the design manager for this project what was in the core of the main rain screen panels i think for this project
02:20:41 project i was only responsible for making sure that
02:20:44 that kevin got started and then to make sure he got
02:20:47 he got on according to program in respect to other projects i would usually submit all that information to
02:20:57 building control and the architect to get signed off but can i just ask from a structural point of view you'd need to know uh the weight of the panels wouldn't you
02:21:08 uh the weight of the panels wouldn't you and therefore possibly their composition that's usually specified as a overall weight per meter squared
02:21:18 now i've asked you a little bit about your knowledge of um other cladding fires and i think you've said that you didn't have much knowledge at the time of cladding fires whether domestic or
02:21:29 cladding fires whether domestic or international is that correct that's correct um
02:21:35 so were you not aware at this time that there had been cladding fires abroad on buildings containing polyethylene pe
02:21:46 on buildings containing polyethylene pe cord panels no you weren't aware of that if you'd been asked what is the core made of would you have been able to give
02:21:57 made of would you have been able to give an answer
02:22:00 no so you didn't understand that there was polyethylene in the core not that i can remember now had you been told that it was polyethylene
02:22:13 polyethylene would you have had any concerns in terms of fire performance with a polyethylene core
02:22:21 at that point i don't think it would have jumped out i think that i'd worked on projects previously where the same products have been signed off um
02:22:33 um and to if they've been signed off by building control there i thought it would be okay anywhere else can we turn up an email this is
02:22:48 cep3049719
02:22:59 we can blow that up on the top half of that page this is an email from deborah french of alcoa
02:23:07 on the 13th of may 2013 to individuals at cep including jeff blades did you know deborah french at alcoa did
02:23:18 did you know deborah french at alcoa did you did you know her never spoken to her what about jeff blades at cep did you know him i knew of him i'm not sure that
02:23:28 sure that i ever spoke to him particularly now just to be clear you're not copied into this email i'm not saying you knew about this at the time um but what she says is hi you may be aware
02:23:40 but what she says is hi you may be aware there have been some reports via the bbc concerning a fire on a building in uae regarding acm as a business we are aware of this report and our technical team are following the details but in the meantime i wanted to add some
02:23:52 but in the meantime i wanted to add some thoughts that may help if you get questions from your customers clients etc
02:23:57 etc regarding the supply of rainer bond in the uk as you know we supply both pe and fr
02:24:02 fr core and can control and understand what core is being used in all projects due to the controlled supply route we have by only supplying raynabond to a very small group of approved fabricators
02:24:13 small group of approved fabricators and working very closely with them on all projects we are able to follow what type of project is being designed developed and then offer the right reynabond specification including the core at this stage we will
02:24:26 including the core at this stage we will continue to offer both pe and fr core and continue to the close working relationship we have with our approved fabricators to make sure the right technical support etc etc
02:24:37 etc etc do you see that there yes um now were you ever made aware of um this email or the substance of what's in this email
02:24:49 substance of what's in this email no were you aware of fires in the uae involving acm in around may 2013 no i think the first time that i learned about those
02:25:02 first time that i learned about those was when i was doing the course at bath right so you were never made aware before that of the contents of this email i that there were concerns in the industry arising out of these fires in
02:25:14 industry arising out of these fires in 2013.
02:25:15 2013. no were you aware that rayna bond acm could be supplied with either a pe or an fr core no again i think that was something i didn't learn about until
02:25:27 something i didn't learn about until there was a bath so you weren't aware at the time of the grenfell project that there was an fr core to the rainer bond fire retardant fire resistant core not
02:25:39 fire retardant fire resistant core not like remember now
02:25:45 [Applause]
02:25:48 so you didn't ever have any discussions with anybody at um alcoa or cep about whether a pe or fr core should be used on the grenfell project no i i think i had
02:26:01 no i i think i had virtually no communications with cep or alcoa
02:26:11 mr chairman i think that's probably an appropriate moment because um there's a little bit to go on this topic right um so i will need to ask this witness to come back tomorrow morning well you did indicate that can you give
02:26:23 well you did indicate that can you give me some idea of how long you might require i would hope to be about an hour in the morning with him right well uh mr jones i'm sorry that we've not been able to finish your evidence
02:26:34 been able to finish your evidence today and i'm sure you would like to got away but i'm afraid i'm going to have to ask you to come back tomorrow for a few more questions judging by what ms grange has said
02:26:45 judging by what ms grange has said i think you can have to get away between 11 and half past 11 if that affects your arrangements but we're going to break now so i'll ask you to be back here at 10 o'clock to start again in the morning
02:26:57 start again in the morning and please not to talk to anyone about your evidence over the break all right yes sir good thank you very much would you like to go to the usher
02:27:18 all right it's great 10 o'clock tomorrow morning yes thank you thank you very
02:27:28 much
02:27:36 you