Harley Evidence - Wednesday 16th September 2020 (1/2)

Full transcript

00:00:13 good morning everyone welcome to today's hearing we're going to begin by hearing it further from mr ankertel jones who was giving evidence yesterday so would you ask mr ankur jones to come

00:00:25 so would you ask mr ankur jones to come in please

00:00:41 good morning miss strength ready to carry on

00:00:45 carry on yes sir thank you very much miss great thank you good morning thanks so just a couple of um questions now um back in the topic of insulation before we pick up on the acm

00:00:57 before we pick up on the acm story again and i want to ask you about the use of kingspan k15 on the tower we saw in your witness statement yesterday that you'd referred to

00:01:06 to it being a phenolic insulation that was used on the tower were you aware that some kingspan cool firm k15

00:01:14 firm k15 had been used on the tower as well as celetex rs 5000 no it wasn't you weren't you're never aware of that now

00:01:25 aware of that now then again on the topic of insulation i just want to look at the harley specification for the grenfeld project this is ryd

00:01:36 the grenfeld project this is ryd three zeroes four 46822

00:01:48 so these are specification notes that were prepared i think by kevin lam is that right for the project that's got his um signature on it oh

00:02:00 that's got his um signature on it oh yeah title yeah is this a document that you were familiar with while you were working on the grenfell project no i was focused on the other project that i was working on

00:02:12 that i was working on so you don't recall ever looking at this specification noting what was in it checking it no i was

00:02:20 was only to mentally managing kevin's time and to be a stop-in for the first part of the project until there was a project manager and designer on it okay because the point was that there's no

00:02:31 because the point was that there's no mention of the main insulation product here that was to be used behind the rain screen panels on the spandrels and the columns so there's no mention in this document

00:02:42 so there's no mention in this document of the rs 5000 insulation and you can't help us as to why that might be no if we look

00:02:53 no if we look um within this document pack there's some drawings below if i could look at page four

00:03:02 do you see there um that we are seeing drawings showing the insulation and it's using a

00:03:10 using a a wriggly line if i can put that in a very non-technical way for the insulation we see it on the left and we see it on the right do you see that there yes do you remember seeing that

00:03:21 yes do you remember seeing that same marking for insulation on the grenfell tower drawings i i can't remember i probably would have seen them

00:03:31 seen them when i was doing the structural calculations i can't remember now do you agree that that is this the marking that's commonly used for mineral wool

00:03:39 wool in the industry i wouldn't i i work on projects now where people use

00:03:46 use all different kind of hatches and symbols for different installations so i wouldn't be able to say that that was commonly used for rockwell i see so at the time

00:03:56 the time you wouldn't have noticed that that was a symbol that maybe suggested a different type of project a product no no okay thank you so um

00:04:07 no okay thank you so um yes then just before we leave this drawing on the right we looked yesterday at the studio e architects red stamp and we can see it there

00:04:18 red stamp and we can see it there and under a we see conforms to design intent

00:04:23 intent and under b we see conforms to design intent and then subject to incorporation of comments do you see that there yes and i wanted to ask you about the

00:04:34 yes and i wanted to ask you about the the meaning of design intent did you ever think on the project about

00:04:39 about what the meaning of design intent was did that ever ever something that you thought about no i was

00:04:47 i was focused on another project i wasn't looking at this project and that amount of detail at all did you know more generally that the architect was reviewing the drawings for

00:04:58 was reviewing the drawings for design intent no no that wasn't something

00:05:03 something you were aware of yeah okay

00:05:07 so picking um back up on the topic of the acm

00:05:11 the acm panels um we've previously discussed class naught and you've given evidence already about what your understanding was about that classification i just want to turn up

00:05:22 classification i just want to turn up where we see the definition of that this is at

00:05:25 is at clg five zeros two two four at page one two two so this is in approved document b

00:05:36 and if we look on the left column in the middle of the page we see paragraph 13.

00:05:44 do you see that there the highest national product performance classification for lining materials is class

00:05:49 class nord this is a tree achieved if a material

00:05:52 material or the surface of a prod composite product is either composed throughout of materials of limited combustibility or a class 1 material which has a fire propagation index

00:06:03 propagation index i of not more than 12 etcetera do you see that there yes and i wanted to ask you about that the reference there in the main part of that paragraph to lining materials

00:06:14 that paragraph to lining materials i appreciate you said that you weren't familiar with the detail of approved document b at the time of the grenfell project but was it your understanding that class naught was a classification that was

00:06:26 naught was a classification that was primarily concerned with lining materials no i my only understanding of class i was in

00:06:34 in at that point in my career was that it was non-combustible um but it always needed to be referred back to the fire consultant

00:06:45 so you didn't ever think about whether the fact that it was a primarily a classification for lining materials might have impacted on its reliability as a classification for composite products i was completely unaware of that at that

00:06:57 i was completely unaware of that at that point in my career did you ever think about how class naught applied to composite cladding products

00:07:04 products no

00:07:09 now we know that harley obtained the bba certificate the 2008 bba certificate for the reynabond panels harley obtained it from deborah french

00:07:21 harley obtained it from deborah french at arconic on the 23rd of april 2014 when it was sent to mark harris and mike

00:07:28 mike albuston um i don't think we need to turn this up the reference for that email is cep60281 i want to ask you were you ever sent the

00:07:39 i want to ask you were you ever sent the bba certificate for the rayna bond panels

00:07:42 panels during the time that you worked on the grenfell project not that i have any memory of i was completely focused on the other project and only looking at grenfell when i was

00:07:53 and only looking at grenfell when i was asked to look at specific small items or help out can we just turn up that bba certificate it's at bba

00:08:10 6047 so we can see there that it's a british board of agreement in the top right hand corner

00:08:17 corner the certificate number zero eight um we can see looking at the bottom of the page in the paler blue box that the date of first

00:08:28 paler blue box that the date of first issue was the 14th of january 2008 so significantly before the grenfell project looking at this now do you think that this was a document that you had seen at the

00:08:39 that you had seen at the time you were working on the grenfell project

00:08:44 i'd seen other bba certificates to pass through to the design teams and other projects but i don't believe i saw in relation to grenfell

00:08:58 were you familiar with bba certificates more generally than in terms of what their

00:09:02 their status was what their significance was there were something that was asked for by the design team and you'd usually

00:09:13 by the design team and you'd usually request them and pass them on for review would you ever read those certificates for the products that harley was using on its cladding jobs

00:09:25 if they were asking for something specific i might have a look to see whether it had it in there to save wasting their time but i would always send it on i wasn't trained in those aspects

00:09:39 wasn't trained in those aspects and harley never provided you with any guidance or training on how to read these certificates or interpret them no

00:09:47 do you think you had read this bba certificate for the rayna bond panels at the time of the grenfell project i can't remember reading it on that

00:09:58 i can't remember reading it on that project

00:10:01 so we can see on that first page under key factors assessed in the second half of the page that there's a statement about behavior in relation to fire it says there in relation to the

00:10:12 it says there in relation to the building regulations for reaction to fire the panels may be regarded as having a class nought surface in england and wales do you see that there yes

00:10:20 there yes do you remember noticing that about those panels in this bba certificate no i wasn't i wasn't working closely on the project and i wasn't

00:10:31 the project and i wasn't responsible for the selection of materials

00:10:34 materials so i wouldn't have been looking at this i was responsible for the structural design

00:10:40 design now i think you've said that at the time of the grenfell refurbishment project you did not appreciate that these panels were available with a polyethylene pe core but also with an fr

00:10:51 with an fr fire retardant core that's right isn't it yes

00:10:56 can you help us as to why harley appear only everton advanced the pe variant and never suggested the fr variant no i had

00:11:05 had no part in the selection of materials

00:11:10 did you ever seek any advice from arconic about the suitability of using the rainer bomb panels with a pe

00:11:18 pe core at grenfell no played no part in the selection of materials on grenfell

00:11:25 i just want to look at page five under section six

00:11:34 there's a section here on behavior in relation to fire do you see that there yes again looking at this now do you think this might have been something that you had read prior to the grenfell project no

00:11:47 prior to the grenfell project no so you wouldn't ever look to read this kind of detail in the certificate on other projects if someone was asking something specific i might look to see like i said to make sure that i wasn't wasting their time

00:11:59 sure that i wasn't wasting their time yeah but i didn't understand the fire regulations so i wouldn't i wouldn't assume to make any judgment on it i would always pass it back yeah the area of specialism that i had

00:12:10 yeah the area of specialism that i had was structural engineering we can see at 6.1 and then at 6.2 that it's discussing both a standard sample of the product

00:12:21 both a standard sample of the product with a certain coating and then a fire retardant sample of the product within with a different coating do you see that there yes and again i'm going to ask you again

00:12:32 and again i'm going to ask you again does that remain your evidence that you weren't aware that there were these two different

00:12:36 different types of rayna born panels no i was not aware

00:12:42 paragraph 6.4 it says these performances may not be achieved by other colors of the product and the designations of a particular color should be confirmed by and then in england and wales it says

00:12:53 and then in england and wales it says test or assessment in accordance with approved document b now was that something that you were aware of at the time of the grenfell project i appreciate you saying you didn't read this detail but

00:13:05 didn't read this detail but were you aware that there might be differences in terms of fire performance as between different colors of the product no

00:13:16 to your knowledge were any investigations ever made as to the fire performance of the finish for the grenfell panels that was used the smoked silver

00:13:28 panels that was used the smoked silver no i wasn't working closely enough on the project to know how the materials were selected at all

00:13:38 and then at 6.5 it says for resistance to fire the performance of a wall incorporating the product can only be determined by tests from a suitably accredited laboratory and is not covered by this certificate

00:13:50 and is not covered by this certificate do you see that there yes did you have any awareness that the the performance of a wall incorporating products of this nature could only be determined by tests from a suitably accredited laboratory

00:14:02 from a suitably accredited laboratory that's something i didn't learn until i went to

00:14:04 went to bath university yeah and then at 6.6 it says cavity barriers should be incorporated behind the cladding

00:14:12 cladding as required by the national building regulations but should not block essential ventilation pathways particular attention should be paid to preventing the spread of fire

00:14:23 preventing the spread of fire from within a building breaching the cladding system through window and door openings do you see that there yes did you have any um more general awareness at this time

00:14:35 awareness at this time that when using these types of panels particular attention ought to be paid to preventing the spread of fire from within a building through windows my only awareness of

00:14:46 through windows my only awareness of cavity barriers at that point was to always produce elevations that showed where they were which you'd then send off to the fire consultant who would add or remove them as

00:15:00 who would add or remove them as they felt necessary yeah

00:15:04 at this time were you aware that there was a statement in a pre-document b which made clear that any test evidence used to substantiate the fire resistance rating of a construction should be carefully checked

00:15:16 construction should be carefully checked to ensure that it demonstrates the compliance that's adequate no you weren't aware of that no

00:15:24 was that harley's practice more generally though were you aware that harley had a practice of ensuring that the fire resistance rating of a construction product was

00:15:35 product was carefully checked by reference to test evidence

00:15:38 evidence one other projects that had similar questions raised i would send off

00:15:45 send off the information to a fire consultant and they would examine the evidence and confirm whether it did or didn't comply yeah on the on the grenfell project were

00:15:58 yeah on the on the grenfell project were you ever aware of that process having happened i wasn't working closely enough on the project to see whether that process happened or not okay um just another

00:16:11 okay um just another topic now um did you ever have any informal meetings with studio e and building control to discuss

00:16:22 building control to discuss the design of the cladding on site no i was apart from trying to act as a stopping at the beginning i was fully focused on another project mr

00:16:33 fully focused on another project mr crawford of studio e when he gave evidence the inquiry stated that there were a number of informal workshops with rbkc building control where drawings were discussed do you have any recollection of any such

00:16:45 do you have any recollection of any such meetings taking place as far as you were aware no did you ever um attend site and meet any representatives of building control

00:16:56 representatives of building control there may have been somebody there at those first two meetings i have no recollection can we just look at um mr john hoban's

00:17:07 can we just look at um mr john hoban's statement

00:17:07 statement briefly um so he was one of the building control officers who was responsible for the grenfell tower refurbishment project and and i want to pull up his witness

00:17:18 and and i want to pull up his witness statement this is rbk three zeros three three nine three four at page seven

00:17:38 so it's rbk three zeros three three nine three four at page seven

00:17:50 great thank you and so this is mr hogan's statement i want to look at what he says at paragraph 65 we can see at 64 above it

00:18:01 we can see at 64 above it he's asked what advice or information was available and what assessments were made about the components that comprise the exterior of the building their fire safety fire resistance and compliance with

00:18:12 fire resistance and compliance with safety standards do you see that there yes and he says i was provided with initial drawings and details and discussed the works with the architect and his specialist consultant dealing with fire matters

00:18:23 with fire matters and then he says this i also had a brief discussion with the engineer from the contractors installing the cladding system to the exterior of the building at the commencement of the works to the

00:18:34 at the commencement of the works to the exterior

00:18:36 exterior during that discussion this is paragraph 66 i recall that i was advised by the engineer

00:18:41 engineer that tests had been carried out to the metal framework supporting the cladding i also recall that i was advised that the system had been fitted to many buildings throughout england and wales

00:18:52 buildings throughout england and wales to buildings of a similar height and construction do you see that there yes and what we'd like to know is whether it might have been you uh who was the engineer from the

00:19:03 uh who was the engineer from the contractors installing the cladding system that mr hoban spoke to during this brief discussion i i don't have any memory of this i don't think it was

00:19:15 don't think it was myself i don't know if he's referring to the

00:19:19 the the engineers actually installing the cladding on the job well who would you think that was

00:19:26 you know the i don't know the actual guys using the tools to install it on site and he's described as a the engineer from the contractors installing the cladding system

00:19:38 installing the cladding system doesn't sound like the installers of the cladding it sounds like somebody perhaps more qualified than that would you agree i don't know a lot of people refer to engineers

00:19:47 engineers as in installers and engineers use it it's quite a broad term do you have any recollection of speaking to rbkc building control or more specifically mr hoban

00:19:58 specifically mr hoban i don't know until i was given evidence i wouldn't be able to say who the building control was or who the particular person was i have no memory of ever speaking to

00:20:10 i have no memory of ever speaking to them

00:20:13 um if you just go over the page at paragraph 67 over on page eight he also says uh in the last sentence of

00:20:24 he also says uh in the last sentence of that

00:20:25 that i was also advised at the initial meeting on site by the specialist consultant that the cladding would comply with the standard set out and approved document b so just for completeness that that's

00:20:37 so just for completeness that that's what mr hoban says about those exchanges is your evidence the same in terms of whether you can recall any being involved in any discussions with him no my involvement was so small on

00:20:48 him no my involvement was so small on the project that i don't remember this at all thank you so i now want to turn to some exchanges that occurred in march 2015

00:21:00 that occurred in march 2015 which began with some queries about cavity barriers can we turn first up to har406585

00:21:11 can we turn first up to har406585 at page three

00:21:20 yes so this is if we look at the bottom half of the page this is an email from ricky k at cider eyes to ben bailey

00:21:31 eyes to ben bailey on the 26th of march 2015. do you see that there yes and the discussion is around the integrity of the cavity barriers

00:21:42 barriers so he says hi bear apologies for the delay be please find below extract from the approved document of the building regulations and he set out an extract from table a1 there relating to the

00:21:53 from table a1 there relating to the performance of cavity barriers for integrity and insulation and then below that he has indicated that here you can see it's

00:22:03 it's 30 minutes integrity and 15 minutes insulation that's required do you see that there yes so there's a query about that if we can just look at the rest of mr k's email if we just

00:22:15 the rest of mr k's email if we just scroll down

00:22:22 so he's justifying why their cavity barriers will meet those integrity and insulation requirements and in fact will exceed the minimum requirements

00:22:33 the minimum requirements and then if we scroll up to the bottom of page two top of page three ben bailey then responds perhaps if we can just see

00:22:44 then responds perhaps if we can just see the date of the email on the page before the bottom of page two

00:22:50 two so on the 26th of march same day ben bailey responds to simon lawrence simon o'connor and others you're not copied in at this point um and he says simon and then if we can

00:23:01 um and he says simon and then if we can read up

00:23:02 read up he says as discussed please see the email below from the fire break supplier there's quite a large cost difference between what cider eyes and the spec recommend

00:23:10 recommend and upgrading to the 120 minute barriers we discussed on tuesday could you forward this to the client's representative for approval please do you see that there yes so ben's making clear that there's obviously been

00:23:22 making clear that there's obviously been a discussion about whether or not these barriers should be upgraded to 120 minute barriers and there's some pushback here because of the large cost difference do you see that there yes do you remember this episode

00:23:35 yes do you remember this episode where there was pressure on site to avoid having to specify cavity barriers with 120 minute fire resistance i don't remember it but i've been shown the information since

00:23:47 the information since so if we scroll up then an email above that we can see simon lawrence's response

00:23:58 so simon lawrence assistant justin neil crawford

00:24:02 crawford hi neil following tuesday's design meeting harley via their supply chain are questioning the rating of the cladding fire breaks apparently by going to two hours as we discussed has a cost increase of around 12

00:24:13 12 000 pounds their supplier is saying it only needs to be 30 minutes everywhere as per the regs extract below could you take a look to see what you think and discuss with john hoban please do you see that there

00:24:24 do you see that there yes

00:24:28 and then if we go to the bottom of page one

00:24:33 one of this chain

00:24:40 we can see on the 27th of march that's the email in the middle there on the 27th of march so that same day to you ray bailey copies you in on this chain

00:24:52 chain and says dan do you have any comments do you see that there yes and we see your response at the top of the page

00:25:03 so there it is on the same day and you say this

00:25:06 say this just that it's ridiculous there is no point in

00:25:10 point in fire stopping as we all know the sorry as we all know the acm will be gone rather quickly in a fire the whole point is to stop unseen fire spreading in the cavity and moving to

00:25:22 spreading in the cavity and moving to other parts of the building who is john and who is paul are we working to the nbs spec by studio e do you see that there yes and i want to ask you

00:25:33 ask you um about that response and what precisely did you mean by the comment just that it's ridiculous from my training with structural design

00:25:44 from my training with structural design i knew that aluminium facades were unable to resist a fire for very long at all

00:25:51 all and would just melt and fall off the building so putting in a two-hour fire break on that kind of facade was a waste of time

00:26:04 now you say from my training with structural design that um what you've just expressed there is a an opinion about the performance of the aluminium in a fire isn't it yeah because in structural design you

00:26:16 yeah because in structural design you have to consider how materials perform in fire yes for the outside of the

00:26:23 the facades on any job unless it's specifically required they're not required to stay on the building in a fire the the failure mode for cladding in a

00:26:35 the the failure mode for cladding in a fire is that it will melt and fall off so what exactly was it about the acm which would mean it would be gone rather quickly in a fire that it was made from aluminium and what

00:26:48 that it was made from aluminium and what did that mean to you that it would melt at much lower temperature than steel wood

00:26:56 can you describe what the mechanism of failure would be for the aluminium composite material what were you envisioning at the time that

00:27:05 that basically the the aluminium rails and the brackets that supported them and the acm would melt and fall off did the core of the acm panel feed into

00:27:17 did the core of the acm panel feed into your thinking when you made this comment no were you thinking about the combustibility of the panel no not at all

00:27:29 and how did you obtain this knowledge about how the acm would perform in a fire

00:27:36 we're speaking generally across the whole cladding including the acm the cladding and the bracketry

00:27:42 bracketry from knowing how aluminium performs in the fire

00:27:45 the fire isn't it possible thinking back to that presentation by sarah colwell that we know you attended um that we discussed yesterday isn't it possible that you were aware that there were issues with

00:27:56 were issues with aluminium composite material involving pe cores and their propensity to

00:28:02 to promote the spread of fire across walls no this is the fact that aluminium will melt quickly in a fire and there's a fact that's known throughout the industry

00:28:13 industry that in a fire an aluminium facade will not last very long

00:28:19 it will melt and fall off the building and in the next sentence beginning the whole point is to stop unseen fire can you explain how your view about the acm was

00:28:31 how your view about the acm was affecting your view about the cavity barriers can you explain that for us because the view is that if it's going to melt and fall off the building there's no point in putting a two-hour

00:28:42 there's no point in putting a two-hour fire stop on there

00:28:48 so am i right that there you are expressing an opinion about unseen fire spread and what the requirement for cavity barriers was

00:29:01 yeah from the opinion that i'd found on other projects but it wasn't an educated opinion it would the educated part of the opinion was

00:29:11 was that in a in a fire structurally aluminium will fail very quickly and the reading down the email you can see that requirement was 30 minutes

00:29:22 that requirement was 30 minutes why would you put two hours on how is it consistent with your evidence that you were only ever concerned with structural matters that here we see you

00:29:33 structural matters that here we see you expressing an opinion about cavity barriers

00:29:36 barriers and unseen fire spread across the building

00:29:41 building because it's it's what i picked up from the email

00:29:44 the email further down and from picking up bits and pieces over the years but it wasn't an area i was trained in or

00:29:51 or had any knowledge in on the other projects that i worked on i would always send off the drawings to the consultants to be checked but you've used a phrase there as we all

00:30:03 you've used a phrase there as we all know this doesn't seem like you've just had a look at the email chain and then you're expressing an opinion as we all know aluminium melts

00:30:15 well in knowledge of that

00:30:20 was it your view that the cavity barriers would have nothing to expand against to resist the fire spread because the aluminium would melt

00:30:29 usually the from the experience now looking back the cavity barriers are only required to perform for a very short amount of time

00:30:42 perform for a very short amount of time because of that that's why 30 minutes fire barriers are selected

00:30:48 selected did you ever think about how a cavity barrier would work with a an aluminium panel in front of them if you thought the panel was going to melt from all the videos that i'd sort of

00:30:59 from all the videos that i'd sort of been shown by people at the msc it's been shown that most facades only last for about 15 minutes in a fire so it's only to give you that length of

00:31:12 so it's only to give you that length of protection yeah but you didn't know that at the time did you because you hadn't done that

00:31:16 that course but i knew that aluminium melted at a lower temperature i didn't know that it would last for a period of time just not very long at all

00:31:27 period of time just not very long at all given what you knew about how the acm would behave in a fire how did you think the external wall would adequately resist the spread of fire over the walls did that was that ever something you thought

00:31:38 was that ever something you thought about at this point the combustibility of the panels was not something that i ever thought about

00:31:45 only that they would melt and that there was no

00:31:48 was no there was no structural requirement for them to not melt now that phrase as we all know were you saying it was common knowledge across the cladding industry that aluminium would behave

00:31:59 industry that aluminium would behave this way

00:31:59 this way or more generally across the construction industry i think it's it's basic physics it's it's known across the industry i mean it's what i was taught

00:32:13 mean it's what i was taught you know on the msc as well in in the years subsequently that alien melts

00:32:24 when you were writing this email did you ever pause and think well there are fire safety issues around acm that we ought to make sure have been looked at this didn't raise any

00:32:36 looked at this didn't raise any fire safety issues with acm to me at all it

00:32:40 it is just that it would melt sorry sorry carry on it was just that i was being sent little things like this and i was fully focused on another project

00:32:53 we saw that third line the whole point is to stop unseen fire spreading in the cavity and moving to other parts of the building

00:32:59 building did you consider the possibility that there could in fact be unseen fire spread

00:33:04 spread behind the panels before they failed

00:33:08 not if there's cavity barriers

00:33:13 so you didn't think that it might be an issue that there was unseen fire spread behind those panels before they failed no because the

00:33:25 they failed no because the the cavity barriers were going to be installed whether they were two-hour cavity barriers or half-hour cavity barriers as required they would be installed and stop that

00:33:36 they would be installed and stop that from occurring now you say in the last line are we working to the nbs by studio e the nbs spec by studio e why did you query that what was the

00:33:47 why did you query that what was the relevance of that i was probably asking what was in the nba spec

00:33:52 nba spec i mean i was completely focused on another project and being sent small little tasks to do on grenfell i didn't have an overall idea of what

00:34:03 i didn't have an overall idea of what was going on it was you know at that point kevin and ben were running with the project

00:34:13 so you didn't know that by now this is march 2015 you weren't aware of whether they were working to the mbs spec and indeed what the nbs spec said you weren't aware of that at this point

00:34:24 that at this point no

00:34:30 why did you think that ray bailey was asking you for your views if as you say ray bailey would have understood that you didn't have the qualifications to be commenting on fire and fire performance

00:34:42 on fire and fire performance why do you think he was asking you for your view on this cavity barrier point just for another opinion from things picked up in the industry

00:35:04 let's consider the topic of cavity barriers then in more detail now um

00:35:13 based on the emo exchanges we were just looking at do you agree that you knew that cavity barriers would have little function in preventing fire spread if a fire got into the cavity

00:35:24 spread if a fire got into the cavity between the insulation the acm cladding it's still the same case now that the cavity barriers in a range of cladding

00:35:35 cavity barriers in a range of cladding are only required to give a small resistance because after which point there will be no cavity the aluminium will melt and fall off

00:35:46 off at which point there won't be any unseen fire spread because there's no cavity but there might still be fire spread fire spread up other materials including the insulation and there might be fire spread through

00:35:58 and there might be fire spread through the core of these panels would you not accept that looking back on it now and i would accept that but at the time nobody was aware that any of these materials were combustible but given your awareness of the

00:36:10 but given your awareness of the limitations of cavity barriers as we see in this email did you ever consider how important it was to prevent the fire spread into the cavity in the first place

00:36:22 into the cavity in the first place not on this project because i wasn't working closely enough to it so why not you're the design manager why did you never think about stopping fire spread into that cavity in

00:36:34 stopping fire spread into that cavity in the first place because i was the design manager responsible for making sure that kevin was working to program once there was a project manager involved i was barely involved with the

00:36:46 involved i was barely involved with the project at all and through all of that i was fully focused on another project

00:36:52 at the time of the grenfell project were you aware in general terms of regulation and building regulation functional requirement b34 that the building should be designed and constructed so that the unseen spread of

00:37:03 constructed so that the unseen spread of fire and smoke within concealed spaces in its structure and fabric is inhibited were you aware of that

00:37:10 that i wasn't aware of it in those terms i knew that cavity barriers were required to stop fire spreading in the cavity

00:37:19 cavity but i wasn't i wasn't in the knowledge of

00:37:23 of what that requirement was can we just look at

00:37:26 look at approved document b just to test in general terms what your knowledge was can we go back to that clg 50224 at page 82.

00:37:44 so if we look there at paragraph 9.1 at the top of that page it says this concealed spaces or cavities in the construction of a building

00:37:52 building provide a ready route for smoke and flame spread this is particularly so in the case of voids in above and below the construction of a building

00:38:00 building easy walls floors ceilings and roofs as any spread is concealed it presents a greater danger than would a more obvious weakness in the fabric of the building do you see that there

00:38:11 there yes now did you have a general awareness of

00:38:15 of the dangers posed by concealed spaces and

00:38:18 and unseen fire spread at the time of the grenfell project yes i had a general awareness of it and that's why i always sent it off to the experts we see at the bottom of that

00:38:30 experts we see at the bottom of that page diagram 33 provisions for cavity barriers do you see that there yes we look at that now i know you've said you didn't um read adb at the time of the grenfell

00:38:41 read adb at the time of the grenfell project but i think you said yesterday sometimes you were sent little extracts from it on projects or professionals would refer to bits of it had you ever seen diagram 33

00:38:55 well did you see it during the time of the grenfell project or any time before you worked on the grenfell project i think on some other projects i may have been sent it

00:39:07 do you think you were probably familiar with this diagram at the time you worked on the grenfell project not um not familiar i was aware of it

00:39:19 and did you ever think to have a look at it so we saw just now you were um providing ray bailey with your thoughts about cavity barriers and performance did you ever think to have a look at the

00:39:31 did you ever think to have a look at the cavity barrier provisions in approved document b when you gave that advice no because it wasn't my area of expertise

00:39:41 expertise do you agree with me looking at this now that it's clear that cavity barriers ought to be provided to close around openings

00:39:53 we can see the grey shading which is the symbol that which is the the code for cavity barriers in the key below and we've got that label at the bottom left close around

00:40:04 label at the bottom left close around openings and you can see cavity barriers at the head and the sill of that opening do you see that there yes i see that there but subsequently after grenfell working on other projects i would

00:40:16 working on other projects i would disagree that this was clear and i think that this diagram made it confusing because it was showing it for a house

00:40:23 a house rather than a tower block and i think it was

00:40:27 was further confusing by the fact that the they showed the cavity barriers in such a light color experienced many problems since then where these were scanned and sent to people and they didn't come out and subsequently

00:40:39 didn't come out and subsequently approved document b has been revised to make that clearer i see but just to be absolutely clear your evidence was you didn't consider this

00:40:49 this diagram at the time of grenfell so this is your subsequent reasoning and even if the gray comes out we've still got the close around openings and the arrows haven't we yes

00:41:02 so would you agree with me looking at this now that it is clear that there should be

00:41:06 should be cavity barriers around the windows certainly at the head and the sill of a window looking at this now yes

00:41:15 now yes and if we can go on and look at 9.3 of adb which is i think the next page 83

00:41:26 we see there it says in the text as well cavity barriers should be provided to close the edges of cavities including around openings do you see that yes it couldn't be clearer could it

00:41:40 now do you agree that harley specified the cavity barriers that were to be used on the grenfell tower project

00:41:51 on the grenfell tower project sidewise cavity barriers from the evidence i've been shown subsequently i can agree that at the time i wouldn't have known who specified them

00:42:01 them so that's in the harley specification that we looked at earlier ryd3046822 let's let's bring that up actually ryd three zeros four six

00:42:12 three zeros four six eight two two

00:42:22 so this is the familiar or familiar to us now i would say a set of harley specification notes and in that you see in the bottom left-hand corner

00:42:33 left-hand corner we've got fire breaks for the new build zones and fire belts for the refurb zones and we can see that they're ciderised lama firm cavity barriers do you see that there yes

00:42:44 yes did you or to your knowledge anyone else at harley ever make any investigations with cider eyes as to whether those cavity barriers had ever been tested in a rain screen system

00:42:56 no i'm aware of on that project i wasn't working closely enough to it

00:43:02 in your view would it have been possible to comply with the guidance in diagram 33 at grenfell tower and to have put cavity barriers around the windows you mean my view now looking back

00:43:14 yes yes it would yeah

00:43:22 now if we can return briefly to the request for information that was sent on the 17th of september 2014 that you submitted this is exo four zeros one two nine one

00:43:40 four zeros one two nine one so we looked at this yesterday from you to simon lawrence 17th of september 2014 and i want to look at so this is you asking about the required extent of the horizontal fire breaks within the

00:43:52 horizontal fire breaks within the cladding areas and in the suggested solution you say we believe that they will be required at every floor level on the vertical columns

00:44:00 columns but not in the area of cladding between windows

00:44:03 windows this is because there's no chimney effect here and therefore the cladding will not

00:44:07 will not add to the spread of fire do you see that there yes

00:44:12 now prior to making that request and giving that suggested solution did anybody look at any guidance either in approved document b or any other relevant industry guidance and we know

00:44:24 relevant industry guidance and we know now there was other guidance um as to what the extent of

00:44:30 of cavity barriers ought to be not that i'm aware of now

00:44:39 can we now look at harley drawing this is

00:44:48 har408902

00:44:52 now in this drawing what we can see is that cavity barriers have been added to the design and are represented by the honeycomb

00:45:00 honeycomb mesh on the right do you see that there yes um

00:45:04 yes um in the top right do you agree that cavity barriers in the location you've specified

00:45:11 specified did allow a chimney effect at the nose of the column i'm not familiar enough with the design of the job to be able to say that or not

00:45:25 can we then return briefly to the email chain that began with your request for information on the 17th of september 2014. if we go to har

00:45:36 2014. if we go to har 403638

00:45:39 want to read the email at the top of the

00:45:44 chain so again we looked at this yesterday can you confirm your position in relation to terry's comment below about combustibility and continuous cavity

00:45:55 combustibility and continuous cavity paths do you see that there yes and he talks about john hoban having been

00:46:02 been assiduous about checks at the kensington aldridge academy did it concern you at the time that there did appear to be widespread confusion as to the use of cavity barriers in the facade amongst the

00:46:13 barriers in the facade amongst the professionals on the project

00:46:19 i think at the time my knowledge wasn't what it is now from having been educated on it

00:46:26 on it it concerns me greatly now looking back at it

00:46:29 at it but at the time i don't think i was educated enough to be able to form an opinion as to what they were saying right i was able to make judgments about how aluminium performed structurally and

00:46:41 performed structurally and why putting two hours on didn't seem very logical to me but i wasn't education enough to question those people in those positions of authority

00:46:54 of authority if we can look at um within this chain there's an email from neil crawford to terry ashton on the 18th of september um on page three of this chain

00:47:06 um on page three of this chain at 12 18 in the middle of the page so neil crawford says to terry ashton hi terry please see attached our sections and the initial drawing set we have had

00:47:17 and the initial drawing set we have had from harley's the initial drawings from harley's are fairly limited but they attempt to establish the basic approach do you see that there yes do you agree that the harley drawings at this stage were limited

00:47:29 drawings at this stage were limited in terms of what they showed i can't remember what the harley drawings would have shown at that

00:47:36 stage considering that work on site had started on the 2nd of june 2014 was it normal for detailed design questions such as these to be raised at

00:47:47 questions such as these to be raised at this

00:47:48 this late stage on other projects that i would that i would have been the designer on i would have expected things like that to have been closed out sooner

00:48:01 can you explain why we don't see a comprehensive strategy relating to cavity barriers at any point on the grenfell project no i can't whose responsibility was that

00:48:14 no i can't whose responsibility was that would you have thought was was that at the time

00:48:20 the time i would have thought that um both the architect building and building control and ryden shouldn't have been able to sign off and any of the design if they hadn't seen that first and they should have

00:48:31 that first and they should have requested that can we now look at an email har403691

00:48:46 this is an email from simon lawrence to neil crawford and kevin lam and you are copied in there we can see that at the top

00:48:55 the top and it's dated the 16th of october 2014. do you see that there yes and simon lawrence says gents i think we will definitely have an issue with the kitchen window with kitchen window we roughly marked it

00:49:07 with kitchen window we roughly marked it out in flat 145 and it over sales kitchen lounge screen by about 200 millimeters it looks bad regards simon do you see that there yes now was this a reference to gaps

00:49:19 yes now was this a reference to gaps being created by the positioning of the new windows significantly out from the position of the old windows no i have no idea i was working on another project

00:49:30 another project i was being given bits and pieces to do here and there but i wasn't keeping up with any of this because it wasn't relating to management

00:49:41 because it wasn't relating to management of time or programme did you ever consider whether the gaps created

00:49:47 created in that location were problematic from a fire safety perspective i have no idea if this relates to gaps at all so you can't help us on that no now

00:50:00 no now just in terms of the cavity barrier design

00:50:04 design and i just want to look at this point at the nbs specification this is sea 50169 at page 69. and look at clause 342.

00:50:20 so if we blow that up so this is a heading it's within the h-92 rain screen cladding section of the mbs specification and it's headed

00:50:31 of the mbs specification and it's headed contractors design of rain screen generally and we see there that the and we looked at this yesterday that the design standard was to the cwct standard for systemized building envelopes do you

00:50:42 for systemized building envelopes do you see that there yes and i think you said that you weren't aware that the the rain the system had to meet that um cwct standard that's right isn't it

00:50:59 no no you weren't aware yeah

00:51:04 now that standard included providing effective fire breaks now the mbs spec further required the system to contain

00:51:15 system to contain fire stopping to the requirements of the building regulations we see that just down in the same section can you see it says functional requirements yes so it's as specified in this section

00:51:26 yes so it's as specified in this section with fire stopping to the requirements of the building regulations do you see that there yes did you ever think about what that phrase meant in terms of harley's work i never read

00:51:37 in terms of harley's work i never read this

00:51:38 this document it's in its entirety well the rain screen the h92 rain screen cladding section is about 11 pages long so even though the document is very large

00:51:49 the document is very large in its entirety this h92 section is it's not huge you can't remember reading the h92 section of it no i wasn't the designer on the project

00:52:02 wasn't the designer on the project and if we look on at page 71 at paragraph 490

00:52:14 we can see there there's a requirement for cavity barriers to bs 47620 do you see that there yes [Applause] so would you agree that this nbs

00:52:25 so would you agree that this nbs specification is requiring fire stopping to the requirements of the building regulations including cavity barriers

00:52:32 barriers [Applause] yes yeah now we know that studio e had produced drawings at tender stage which did include some references to cavity barriers

00:52:44 barriers if we can look at this drawing and we'll need the offline version this is

00:52:49 sea402499

00:52:56 and i want to focus to begin with in in the top right hand corner the proposed section typical bay so this is one of the studio e tender drawings

00:53:08 drawings and we can see there and it's the fourth label down on the right hand side p10435 and there's some a little hatched rectangle at the head

00:53:19 a little hatched rectangle at the head of the window it says this ensure horizontal and vertical cavity barriers meet tightly do you see that there yes now do you remember being aware of that at the time you were working on the

00:53:30 at the time you were working on the grenfell project that the studio e drawings did show some cavity barriers no i

00:53:35 no i i don't recollect that at all i wasn't the designer on the project so you didn't think to familiarize yourself with the tender drawings as part of your job as

00:53:48 as part of your job as design manager and in any supervision of kevin lam's work no my supervision of kevin lam's work was

00:53:56 was entirely limited to program and passing information on to ray

00:54:03 i was working on another project full-time

00:54:06 full-time if if i'd have had the time to be able to look at this properly and work on it then we wouldn't have employed kevin i see now if staying with this drawing

00:54:19 i see now if staying with this drawing if we go on the left if we just zoom out in a minute and i'll just find the right section i want to look at the proposed plan at sil level yes so it's in the middle of the page

00:54:30 in the middle of the page on the left yeah if you just go down to get that yes so there you can see a column detail on the left

00:54:41 on the left and we see a label coming out cavity fire barrier in line with compartment wall

00:54:45 wall on the column do you see that there yes um

00:54:52 um if you didn't look at these drawings at the time does that mean that there's no point asking you about the the other little bit of hatched um or the other hatched item that's

00:55:05 um or the other hatched item that's actually at the very corner of the column where it meets the spandrel can you see there's another bit of hatched um drawing there yes this doesn't have a label

00:55:17 label and i wanted to ask you whether that might have indicated that a cavity barrier should be there but you can't help us is that right yeah that's right i was just asked to be a face to ride and

00:55:31 just asked to be a face to ride and until we get a designer involved and once the designer was involved i just had to make sure he was keeping up with his

00:55:37 his program requirements

00:55:41 now we can see that you're copied into an email of the 14th of january 2015 in which kevin lam sent to simon lawrence the full set of drawings relating to the upper 20 floors

00:55:52 drawings relating to the upper 20 floors of the windows if we go to ryd3027692

00:56:09 and we can see from that email that kevin lam is sending it to simon lawrence and copying you and others in and he attaches a large number of drawings and he says simon please find attached a full set of

00:56:20 please find attached a full set of drawings related to the upper 20 floors of windows all now construction issue and to be manufactured accordingly clearly the design has varied much but now all as we agreed prior to christmas

00:56:31 now all as we agreed prior to christmas do you see that there yeah now did you check through those drawings to ensure that you were broadly happy with them no i i wasn't in a position or technically qualified to be able to

00:56:42 technically qualified to be able to check through those drawings and make sure i was broadly happy with them i would have literally just been checking that he was producing the drawings and making sure the client was being kept happy from that point of view

00:56:53 being kept happy from that point of view so that's why you're copied in are you simply to check that he was producing something yeah i wasn't he was more experienced than me

00:57:03 than me he was brought in because he was more experienced i didn't have the time and was fully fully committed to another project now none of these drawings

00:57:15 project now none of these drawings showed any cavity barriers around the windows i just want to look at some of these drawings if we can look at ryd 30276 six nine seven

00:57:35 this is um a jam detail showing that the the interface between the the aluminium window frame and the column including the cladding

00:57:46 and the column including the cladding the aluminium cladding coming out with the strong black line at the bottom and then the insulation along the column you see that there yes

00:57:55 yes would you agree that there's no provision on this drawing for vertical cavity barriers at the window jams i agree that there's no cavity barrier shown on this drawing

00:58:09 shown on this drawing and we know we've traced through the history of this drawing we know it was never revised subsequently we can see that from the highly drawing register we don't need to turn it up but for the transcript that's

00:58:20 ryd3065622

00:58:23 did you ever discuss the topic of cavity barriers around the windows with with kevin lamb no i was purely looking at structural requirements on this project i was

00:58:35 requirements on this project i was working on another project full-time and the only instructions i'd been given by anybody was to keep an eye on his progress until a project manager could be appointed

00:58:47 a project manager could be appointed kevin lam says in his witness statement that he

00:58:50 that he particularly at the beginning would have a number of discussions with you and ray bailey to think about the concept design does that mean you never discussed in any of those discussions anything to do with cavity barriers

00:59:02 anything to do with cavity barriers around windows no because i wasn't educated in that on any other projects i was working on i would have always sent it off to the to the design team asking for their advice

00:59:15 can you help us as to why these drawings have been approved for construction without cavity barriers shown around the windows given approved document b diagram 33 that we looked at and other

00:59:26 diagram 33 that we looked at and other industry guidance that we looked at two days ago which all make clear that cavity barriers should be provided around windows no i can't because i wasn't involved with the design

00:59:37 design process there [Applause] can we look at an email of the 3rd of march 2015 this is sea three zeros one two eight five zero

00:59:55 this is an email from mr lamb to simon lawrence

01:00:00 lawrence and others copying sorry just to simon lawrence but copying you and others in and he says simon please find attached drawings now showing the fire breaks both horizontal and vertical

01:00:12 both horizontal and vertical we assume a requirement of 90 minutes integrity and 30 minutes insulation is sufficient if not please advise the vertical breaks are not on all columns just party walls do you see that there yes

01:00:25 do you see that there yes can you help us as to who or what prompted mr lam to include cavity barriers at this stage no i can't in your experience would you expect cavity barriers to be such a late

01:00:37 expect cavity barriers to be such a late addition to the design process this is march 2015 my experience now would be that they're always shown at the very beginning if we can turn

01:00:51 at the very beginning if we can turn to a drawing produced by mr lam which was attached to this email this is har har408581

01:01:04 this is harley drawing c1059200 do you see that there yes and there's a stamp approved for construction

01:01:15 stamp approved for construction and we can see in the little notes at the bottom of the page and the table that

01:01:20 that fire breaks have been added on the 3rd of march 15. can you see that there yes and if panning out again just looking at this

01:01:30 elevation we can see that there are hatched

01:01:34 hatched lines which now show vertical and horizontal fire breaks do you see that there they're marked they're labeled as well yes can you see those so there are randoms

01:01:49 is it your understanding that the word firebreak here is referring to cavity barriers

01:01:55 barriers i have no idea what he'd be referring to on these

01:01:59 on these so that you never queried that with kevin nam you never check what he meant by firebreak no because i was just meant to be looking after his program requirements and probably at this stage he he was he had a project manager to be

01:02:11 he was he had a project manager to be reporting to instead

01:02:17 the cavity barriers marked on this drawing are not located around the sides of the window are they not shown on this drawing now more specifically the drawing does not show any cavity barriers around the head

01:02:29 any cavity barriers around the head sill or jams of the windows themselves does it

01:02:32 does it not showing this drawing now can you also see

01:02:37 also see that the horizontal cavity barrier above the window is not at the level at the head of the window but it's been moved up higher than that and a little way up the

01:02:48 higher than that and a little way up the spandrel panel do you see that there yes do you know why that was

01:02:56 no i don't

01:02:59 did you ever query that i would never have looked at these drawings in relation to fire i would have been purely relief looking at these drawings in relation to

01:03:10 at these drawings in relation to structural requirements

01:03:14 now if we can go to another drawing this is har408470

01:03:28 so this is the the window head detail where the aluminium window frame is coming up and meeting the panel the return of the panel at the top of the window do you see that there and yes can you

01:03:42 do you see that there and yes can you see that

01:03:43 see that and there's no provision for cavity barriers at the head of the window in this more detailed drawing is there it's a one in two drawing no

01:03:53 [Applause] if we look at revision e of that drawing produced on the 3rd of march 2015 this is a ryd50220

01:04:07 2015 this is a ryd50220 and i think we'll need the offline version

01:04:21 [Applause]

01:04:38 ryd5022o yes that's it so this is revision e um and we can see in the little um table at the bottom in the middle bottom of the page that on the third of

01:04:49 bottom of the page that on the third of march 15

01:04:51 march 15 a fire break's been added do you see that there yes so this is a more detailed

01:04:55 detailed um image which helps is it's a section which helps us see that how kevin lam had done it in that bigger elevation and you can see the

01:05:07 bigger elevation and you can see the fire break now with the hatching with the kind of honeycomb hatching fire break and you can see how far up away from the head of the window it is do you see that yes

01:05:20 and do you agree with me we've looked at it just now that this was in contrast to the studio e employers requirements drawings that did show a cavity barrier directly at the head of the window

01:05:32 head of the window looking at the two pieces of information presented to me now i can agree with you on that

01:05:37 on that do you agree with me that that's a worsening in the cavity barrier strategy because what you've got here then at the head of the window is a potential route for fire

01:05:48 for fire to pass into the cavity between the rain screen panel and the insulation

01:05:55 are you asking me with my knowledge now yes actually i am now you've looked at these drawings yes

01:06:03 yes but just to be clear that wasn't something you noticed at the time or were aware of at the time no or even checked for at the time no i wasn't

01:06:13 wasn't wasn't trained in that i wouldn't know what the requirements were i was if i had looked at these drawings it probably would have been an early stage to have designed the

01:06:24 an early stage to have designed the structural components of their structural performance didn't you think it was important that somebody at least had

01:06:35 somebody at least had a kind of general check of kevin lam's designs for cavity barriers to check that they were broadly in compliance with relevant requirements

01:06:46 with relevant requirements at harley i don't know who that would have been um on and with all the other projects that i worked on you always referred it back to the fire consultant to have that check done

01:06:58 consultant to have that check done why wouldn't that have been you on this job as the design manager because i was only responsible for ensuring that he was keeping to program until a project manager could be appointed had you worked on other projects by this

01:07:10 had you worked on other projects by this time which did have cavity barriers around windows

01:07:16 not that i can remember you've never had experience of of cavity barriers being designed around windows prior to grenfell no a lot of the projects i'd worked on before that

01:07:27 before that i've worked on a couple of cladding projects but done a lot of curtmore projects which were all internal so it was via stops rather than cavity barriers

01:07:42 cavity barriers i see so your experience was curtain walling and fire stopping not rain screen cladding and cavity barrows is that what you're saying i worked on projects with cavity barriers but i'd always

01:07:54 barriers but i'd always always deferred to what was told to by the fire consultants and building control

01:07:58 control [Applause] now can we just look at your witness statement um this is har3010149 at page nine i want to look at paragraphs 36 and

01:08:09 nine i want to look at paragraphs 36 and 37

01:08:14 so you say this with the benefit of hindsight and having regard to material i have seen since the tragedy such as the drawing details produced by harley and circulated by the media i can see that window openings into the

01:08:25 i can see that window openings into the cavity should have been closed with cavity barriers as required by a pre-document b diagram 33

01:08:32 33 and then you say this as far as i am aware this was not part of harley's package

01:08:36 package as a separate cavity closer was never shown on the architect's details therefore i would assume that the job of internally closing the window cavity as per approved document b paragraph

01:08:48 as per approved document b paragraph 9.13d

01:08:50 9.13d should have been carried out by another one of the subcontractors working for ryden

01:08:54 ryden in relation to the internal fit out package do you see that there yeah now given what we've seen this morning what was said in the nbs specification given that harley

01:09:05 specification given that harley had tended and successfully been awarded the design of the complete entire external wall package can you explain why you're saying it wasn't harley's responsibility

01:09:17 wasn't harley's responsibility to provide cavity barriers around the windows i think when i wrote this i hadn't been given the full information and i didn't remember what was on the

01:09:28 i didn't remember what was on the project

01:09:30 project and i thought that people were talking about the the way that you would close the dry lining to the back of the window i thought people were talking about the cavity in there for the for the

01:09:41 cavity in there for the for the paragraph 37 so are you saying that you were mistaken in paragraph 37 given what you now know i was mistaken into what cavity people

01:09:52 i was mistaken into what cavity people were referring to it's clear isn't it from the contemporaneous documents the emails that rfi that you send on the 14th of september 2014 that you thought that harley had

01:10:04 you thought that harley had responsibility for putting in the cavity barriers horizontal and vertical on that facade

01:10:14 yeah even looking back on it now i would have thought it was harley's responsibility i yeah

01:10:24 and you say at paragraph 38 in the last sentence you say i believe the architects should have included cavity barriers around the window openings in their design and the fire consultants

01:10:36 their design and the fire consultants and building controls should have picked this up when reviewing the drawings do you see that there yeah i appreciate what you've said about the architects but can you help us as to why nobody at harley picked up

01:10:47 us as to why nobody at harley picked up that there ought to be cavity barriers around the windows

01:10:54 talking from hindsight and looking back there were lots and lots of projects that didn't have cavity barriers around the windows i don't think

01:11:04 think that it was known within the industry or appreciated because of the conversion from

01:11:11 from cavity masonry walls to rain spring cladding

01:11:15 cladding i think that a lot of people thought that it was something he did for cavity walls rather than range from glading so i don't think that anyone hardly knew that

01:11:28 and it doesn't appear that anybody further up the design team knew that as well i see

01:11:36 okay um cavity barriers in the crown did you ever think about on the project uh what was necessary in terms of cavity

01:11:48 uh what was necessary in terms of cavity barriers at the head of the building or around the crown area no i wasn't involved enough of the project but i can say that it's still something that is

01:12:02 difficult for a lot of consultants to work out what to do at the head of buildings okay did it ever occur to you or did you ever have any discussions with anyone on the grenfell project about the potential

01:12:14 grenfell project about the potential risk of

01:12:17 risk of vertical or horizontal fire spread in relation to the crown if flames were at the top of the building

01:12:24 building ever a topic that was discussed no i don't think anyone was aware that any of the

01:12:28 the products were in the slightest bit combustible so i don't think it would have been something anyone considered throughout the whole design process did you ever have any conversations with mr

01:12:39 you ever have any conversations with mr lam about the positioning of cavity barriers at the head or around the crown of the building no

01:12:50 or around the crown of the building no um can we turn to a document inq3014064

01:13:08 inq30s that's it so this is a copy of your linkedin profile that was taken yesterday on the 5th 15th of september 2020. i assume this is something you're you're

01:13:20 i assume this is something you're you're familiar with yes um and we can see there your name at the top and your skills and and the summary

01:13:31 of your abilities and qualities there and then what you've done is you've set out your experience below um in reverse chronological order um

01:13:42 um in reverse chronological order um and i just want to look at page two about what you say about your time with harley

01:13:49 so there you explained you were with harley for nine years and seven months and you split out the time that you were a technical and engineering manager

01:14:00 a technical and engineering manager between september 15 and march 2016 and the time that you were a design manager between september 06 and september 15 nine years one month do you see that yeah and that's entirely

01:14:11 do you see that yeah and that's entirely consistent what you said to us when we went through your background just want to look at what you say about your work as a design manager you say managing design build and supply contracts to major

01:14:22 build and supply contracts to major contractors in the building industry the position involves taking the project from receipt of order through to completion for which the job can be categorized as follows and there we've got detailing design and

01:14:35 and there we've got detailing design and survey

01:14:36 survey planning and coordinating material procurement and production details budgetary control and client liaison do you see that there yes so

01:14:49 do you see that there yes so would you agree with me that there what you're summarizing what you did at harley was taking a project from start to finish and dealing with all the design elements relating to the

01:15:01 relating to the cladding project would you accept that on a project where i was the designer yes and we see there in item one detailing design and survey

01:15:12 in item one detailing design and survey it's not qualified in relation to structural design is it no on those jobs i would have been doing

01:15:23 no on those jobs i would have been doing yeah i would have been doing the detailing design for putting the system components together to be signed off by the design teams and we've also got an item three

01:15:35 and we've also got an item three material procurement and production details so you do indicate that during your time at harley between september 06 and september 15 one of your areas of responsibility as a design manager

01:15:46 of responsibility as a design manager was for material procurement did you see that there yeah on the projects where i was a designer that's what i would be doing and would you agree that there's no qualification there about only focusing on structural design

01:16:03 mr chairman i've come to the end of my question yes um but at this point it's customary to break and see if there are any others that i ought to pick up yes well should we take the usual break

01:16:14 yes well should we take the usual break at this time um and then you can that would be collect your thoughts and decide whether they're

01:16:20 they're perfectly things that need to be asked thank you well ms franklin jones um ms grange has got to the end of the questions that she thinks she needs to ask but

01:16:28 ask but we have to give her a chance just to review things and um decide whether there's anything she needs to come back on

01:16:34 on so we shall break now until 25 to 12 please okay and then at that stage we'll see if there are any further questions so um perhaps you'd go with the usher but please remember not to talk to

01:16:45 but please remember not to talk to anyone else about your evidence when you're out of the room yes sir thank you very much

01:16:56 all right 25-12

01:34:55 yes would you ask the witness to come back in please

01:35:10 all right the stranger jones well we'll see if there are any more questions for you ms grange yes just a few short questions um whose job was it within harley at the time of the grenfell project

01:35:22 time of the grenfell project to think about fire there was nobody assigned across the whole company to do that wrong

01:35:31 so just nobody nobody was assigned to do it

01:35:35 it no each individual person would look after the responsibility on their project right and so does that mean it fell to kevin lam to be thinking about fire on the

01:35:47 lam to be thinking about fire on the grenfell project

01:35:50 it would fall on kevin and ben kevin and ben okay um different topic we looked at the phrase design intent this morning with reference to the

01:36:02 this morning with reference to the studio e stamp and what they were doing on the drawings just in more general terms if you see on your projects the reference to design

01:36:12 design intent or check for design intent by an architect

01:36:15 architect what do you understand that to mean you mean now

01:36:19 mean now yes now now now i'd always challenge that

01:36:23 that to get them to actually set out what that was in a matrix

01:36:30 assuming you couldn't challenge it what do you think design intent means when referred to by an architect so if i just had to look at it and assume

01:36:37 assume what they were meaning yeah i would assume that it met their intent drawings aesthetically or in terms of statutory compliance or both both

01:36:51 and what about back at the time of the grenfell project if you'd been asked the question

01:36:56 question um what do you think an architect means when they use the phrase design intent what would your answer have been i think it would have been the same then just wasn't on many of the other projects i'd worked

01:37:08 on many of the other projects i'd worked on it never been something that i'd noticed before i see

01:37:14 now we've been through a lot of material over the project in the last three days would you do anything differently if you had the chance to do it again i

01:37:25 if you had the chance to do it again i think looking back on it because my limited my role was very limited in in the whole thing and i was only asked to dip in and out look at one piece of information one piece of

01:37:37 one piece of information one piece of information there and to do the structural design i think

01:37:44 at that point i didn't have the education or the knowledge to have picked up on any signs that things were missing so i don't think i could have done

01:37:55 so i don't think i could have done anything differently without the education that i have now i see okay

01:38:00 see okay thank you mr chairman those are all my questions yes good thank you very much uh wellness strength telling jones those are the questions we have for you thank you very much for coming to give your evidence i'm sorry it's taken a little longer than

01:38:13 sorry it's taken a little longer than we originally thought it might but at least you finish now and you're free to go thank you very

01:38:28 much nice grange i think we probably have to rise from a minute or two that we forget keeping purposes yeah i think some cleaning and other procedures have to happen um before we hear from mr kevin lam ten

01:38:40 um before we hear from mr kevin lam ten minutes long enough i think ten minutes is fine yeah all right well we'll rise now we'll come back at 10 to 12 thank you thank you very much

01:48:45 now this grange your next witness i think is mr lam is that right that's correct mr kevin lamb right could you ask mr kevin lam to come in please

01:49:08 i do solemnly sincerely and truly declare

01:49:12 declare and affirm the evidence i shall give shall be the truth the whole truth and nothing but the truth thank you very much good morning mr lam good morning sit down make yourself comfortable thanks

01:49:24 right yes was great yes thank you yes thank you mr lam for coming and attending to give evidence today we we really appreciate it

01:49:32 it if you have any difficulty understanding anything i'm saying to you and asking you in the course of your evidence please ask me to repeat the question or put the point in a different way if you feel you need a break at any

01:49:44 if you feel you need a break at any point please let us know and also please try to keep your voice up because the lady sitting to your right is taking down transcription of what you're saying and so if you can

01:49:55 so if you can keep your answers nice and clear that's really helpful now you've made a statement to the inquiry

01:50:02 inquiry it's in a folder on your desk in front of you and it will appear on the screen if we go to har30s10419

01:50:12 we can see it there and if we turn to the final page

01:50:19 there we can see it's dated the 4th of december 2018 and is that your signature it is yes have you read that statement recently yes i have and can you confirm that the contents are true yes

01:50:30 contents are true yes yeah have you discussed your statement or your evidence with anybody before coming here today no now i just want to start by considering some questions about your background and

01:50:41 questions about your background and qualifications and if we can start by looking at paragraph four of your statement on page one

01:50:48 one you tell us that after leaving school um you began a career in mechanical engineering and you indicate there some qualifications that you obtained in mechanical engineering we see that there

01:51:00 mechanical engineering we see that there right yeah and then at paragraph five you say you entered the glazing and cladding industry in 1988 yeah and you started as a window installer in a small company

01:51:12 installer in a small company and then you say because of my engineering background i was also involved in manufacturing work in the factory

01:51:18 factory glazing on site and minor design and estimating in relation to shop fronts we can see that there yes um and then if we go to paragraph six over the page you tell us that in 1991 you were

01:51:32 you tell us that in 1991 you were employed by fast limited fas limited a large domestic pvc an aluminium window company as a design and estimating manager that's correct do you see that there and

01:51:44 that's correct do you see that there and is it right for that company you tell us at the end of that paragraph that you designed windows and curtain walling is that right that's correct yeah

01:51:53 yeah so does that mean you weren't designing cladding systems you were predominantly focused on curtain walling and windows exactly yes yeah and

01:52:03 yeah and you refer to some day tech autocad training courses um so are those courses to help you do computerized design exactly yes that's right and then at

01:52:15 exactly yes that's right and then at paragraph

01:52:16 paragraph seven you say that shortly after that in 1992 you joined another company called metfab systems a commercial aluminium company specializes in glazing

01:52:28 aluminium company specializes in glazing air traffic control towers and rain screen cladding do you see that there that's right yep now that sounds like quite an eclectic mix certainly the um air traffic control towers i

01:52:39 the um air traffic control towers i think that there's a limited supply for air traffic control towers so you need something to fill up the gaps in between orders yeah fair enough fair enough um and you're saying there that you

01:52:50 and you're saying there that you specialized in the design of um you're a design manager specializes in rain screen cladding is that right so is that where cladding starts to come in as well as curtain walling yeah

01:53:03 and then between 1996 and 2000 you tell us in the next paragraph paragraph eight that you were employed as a technical architectural advisor

01:53:14 architectural advisor for cladding systems at a leading cladding company called shuco that's correct you see that there can you help us as to what your role as a technical architectural advisor involved

01:53:26 technical architectural advisor involved this was helping write nbs type specifications the primary role was regards to glazing although they did have a small amount of

01:53:38 although they did have a small amount of rain screen cladding systems on offer it wasn't a primary role

01:53:44 right and just to be clear you're not a qualified architect are you no when you were working at chico

01:53:55 no when you were working at chico or prior to that during any of your employment or studies before that did you learn anything about the nature of thermoplastic materials and their behavior in relation to fire not specifically no

01:54:08 not specifically no would you say that you developed a specialism working in cladding in these companies uh no my specialism was glazing yeah glazing and curtain warning yeah

01:54:20 warning yeah and does that mean we'll get to the grenfell project in a moment that um prior to doing the grenfell project um you would have said your specialism was in glazing and curtain walling but not in cladding

01:54:31 not in cladding on the whole i was a freelance draftsman so i could draw many different types of product

01:54:40 product but my experience was mainly in glazing yeah during your career did

01:54:51 in glazing yeah during your career did you ever undertake any specific design qualifications which related to facade engineering or something similar

01:55:01 have you ever or at the time of the grenfell project had you ever received any specific training or education on fire safety within facade design no

01:55:11 no [Applause] now looking then at paragraph nine of your statement is up on the page here you explain that you began working as a freelance designer

01:55:22 began working as a freelance designer trading under the name bespoke designs in 2000

01:55:26 in 2000 yes can you help us as to what kind of design

01:55:31 design services you were offering as bespoke design

01:55:34 design um it's drafting work under the direction

01:55:38 direction of various clients

01:55:44 it's it was to cover a shortfall in um in clients own resource pool so if they felt they had a project they

01:55:55 so if they felt they had a project they didn't have the the workforce to complete it i might be called in

01:56:01 called in so does that mean that the services you were offering was not as a a main designer of a facade but as a a make weight as a as someone who was making up

01:56:12 making up a design team yeah um yes yeah yeah simply yeah is that is that fair if you don't agree please yeah i mean it is not to belittle it um but it but it was it was it's to cover

01:56:25 but it but it was it was it's to cover shortfall in resources

01:56:30 now in paragraph 10 of your statement you explain that in total you've had 30 years of experience in design and manufacture within the clouding industry yeah and you say in that paragraph that

01:56:43 yeah and you say in that paragraph that your career included projects of varying sizes including some with acm rain screen cladding yes aluminium composite material rain screen cladding

01:56:54 cladding and you referred there to a car park project

01:56:57 project in hemel hempstead do you see that there yes yeah can you recall any other projects

01:57:02 projects in which you worked on a design involving acm um the only one really of any note would be another project for harley

01:57:13 note would be another project for harley however it wasn't a full design package it was uh just to produce some schematics was that the telcotz project it was yeah

01:57:24 was that the telcotz project it was yeah so you just did some schematics yes i think their internal design team were freed at that point to be able to um design that one fully and and how long were you involved in that telcotz project doing that work

01:57:38 that telcotz project doing that work probably two weeks yeah

01:57:45 prior to the grenfell project had you ever worked on a high-rise residential building over 18 meters yes had you ever worked on a high-rise residential over cladding project

01:57:57 residential over cladding project involving acm no

01:58:04 you explain in paragraph nine of your statement that you came to know daniel anchored jones during the time that you worked uh under your trading name bespoke

01:58:15 uh under your trading name bespoke design

01:58:16 design yeah you say you started to employ him as a designer and you employed him for around three years is that correct that sounds right yes

01:58:26 in what role were you employing him as a designer

01:58:30 designer for you um i think he started off as a technician and very quickly was promoted to project designer

01:58:42 was that as a project designer in structural matters no no no he'd only just come out of university so he wasn't qualified in structural matters right we were purely a design resource

01:58:54 we were purely a design resource drafting resource i see so implementing other people's design actually in practice exactly yeah drafting those was it your relationship with daniel

01:59:05 relationship with daniel as far as you know that led to you being contacted

01:59:08 contacted for the grenfell tower project um it would have had a factor i'm sure um although i had worked for a harley previously

01:59:22 and that was on the chalcott's project that's correct any other projects you'd work for harley no that was that was the only one i'd done beforehand

01:59:32 yes i think you say that in fairness that that's at paragraph 12 of your witness statement that you'd work for harley on one other project if we go down to paragraph 12 maybe on the next page

01:59:46 yeah prior to this i'd provide the design service for the company on one of the projects it will be limited to producing design details for a project proposal

01:59:53 proposal so is that the schematics at childcots that's right

02:00:02 and you say also in paragraph 12 sorry no that was you've clarified what that was

02:00:10 that was so just to be clear you weren't actually doing the project design work yourself on the chalcott's project

02:00:17 not the full design no no we only did the the preliminary preliminary schematic drawings that i believe ray took to a meeting to

02:00:28 that i believe ray took to a meeting to propose

02:00:29 propose what they were intending and can you help us as to what kind of features you would expect to see on those preliminary schematic drawings there are aesthetics yeah so it was um

02:00:42 there are aesthetics yeah so it was um a couple of pictures of windows and cladding

02:00:45 cladding interface through to the to the windows yeah

02:00:51 was your first experience of substantive facade design work for harley on the grenfell tower refurbishment project as far as overcladding was concerned yes

02:01:03 concerned yes were you at the time you worked on grenfell a member of any specialist cladding industry bodies or associations no no so not the cwct

02:01:15 no no so not the cwct no that's more applicable to organizations than individuals

02:01:23 have you since become a member of any specialist no no industry bodies prior to the grenfell project had you undertaken any formal training

02:01:34 undertaken any formal training on the building regulations and the associated guidance in approved in the approved documents including approved document b no

02:01:44 during the project did hardly provide you with any training formal or informal on the building regulations and associated guidance

02:01:53 guidance no no

02:01:57 did you get any formal or informal training through harley to keep up to date with industry codes of practice for the design and installation of cladding and windows

02:02:08 installation of cladding and windows no no

02:02:11 now in terms of your awareness of previous cladding fires at the time you worked on it on the grenfell project were you aware of any previous hip fires involving external cladding facades

02:02:23 involving external cladding facades on high-rise residential buildings none at all none at all no no so you hadn't heard for example of the lachen or house fire in southwark in 2009 or any fires before that

02:02:36 in 2009 or any fires before that in liverpool or scotland no or any fires abroad in say dubai a spate of high-rise buildings in the uae in 2012 and 2013.

02:02:51 buildings in the uae in 2012 and 2013. no including some in dubai no no you weren't aware of any of those while you were working on the grenfell project did you become aware of any no cladding fires

02:03:08 so does it follow that you weren't aware that there had been external cladding fires involving cladding with a p e polyethylene core at the time you worked on the project

02:03:20 can we look at paragraph 11 of your witness statement back on page two so this is with the heading email material

02:03:32 material and you say here um you say harley curtin wall limited and later harley facade limited i used a harley email address while

02:03:43 i used a harley email address while working on the grenfell tower refurbishment project prior to my appointment as the project designer in the immediate days afterwards as well as on a few

02:03:50 on a few other occasions i also use my bespoke design email address to correspond with those at harley and others such as ryden and studio e and then you say within your statement

02:04:01 and then you say within your statement you've exhibited some of that correspondence is it right that your laptop which you worked on during the project became corrupted subsequently that's correct yes

02:04:12 correct yes can you tell us what happened to it and when yes

02:04:16 when yes um i can't remember the actual date but it was christmas time when windows 10 was on offer as a free upgrade

02:04:24 upgrade um as with many other people after entering into the the simple upgrade

02:04:31 upgrade it corrupted my machine right yeah um did that laptop store the emails that you sent and received on the project which are referred to in paragraph 11 of

02:04:43 which are referred to in paragraph 11 of your statement um it did yes yes however a lot of my emails were um specific emails would be printed out and

02:04:55 specific emails would be printed out and kept on file which are the the exhibits that

02:04:58 that uh put in mind have any emails do you think been lost as a result of your laptop becoming corrupted i would be amazed if there's anything of any relevance i see okay

02:05:11 so you've been able to retrieve have you emails relating to your bespoke design email address as well as those relating to your harley email address there was a period that um that

02:05:22 address there was a period that um that i've lost

02:05:24 i've lost but at this stage in the in the grenfell project

02:05:28 project i'd probably only used it a few times because very quickly harley provided me with their own email i see so it might have been what emails that you exchanged with individuals at

02:05:40 that you exchanged with individuals at the beginning of your involvement very much

02:05:42 much yes definitely so in august 2014 yeah what do you what would you uh think the period would be of emails that you might have lost

02:05:53 you might have lost um

02:05:59 it would be easy to see as soon as i was given the harley curtain wall email address yeah i would have stopped using my own right yeah so we could easily refer back to the earliest of my emails

02:06:10 earliest of my emails have you tried to take steps to recover the emails that were lost no because i didn't feel there was any need

02:06:21 so now i want to turn to how you became involved in the grenfell project and look at that in more detail and at paragraph 12 of your witness statement on page three

02:06:32 statement on page three you described that you were approached by daniel anchored jones who was working as a design manager at harley curtin wall about providing a design service for harley do you see that there that's

02:06:43 harley do you see that there that's right yeah

02:06:46 do you know or did you know at the time why you were being approached was that explained to you uh it wasn't explained but um as with all of my approaches that generally because there's a

02:06:58 that generally because there's a shortage in their own resource pool did you become aware subsequently that that was why you'd been approached was that explained to you yeah um it wasn't explained to me but

02:07:09 yeah um it wasn't explained to me but it was immaterial right okay and then in the next paragraph at 13 you say i attended a meeting with ray bailey the director of harley and daniel anchor jones on the 12th of august 2014

02:07:21 august 2014 and then you say in advance of that meeting and you list out there a number of things that you were sent including the contract program a 3d computer model some cad models

02:07:33 a 3d computer model some cad models and you explain some of what that contained do you see that there yes yes and you've exhibited some of the drawings that you were sent

02:07:44 drawings that you were sent to your witness statement can we just have a little look so at exhibit kl2 that you refer to in that paragraph we see that there were sketches from another harley project

02:07:56 sketches from another harley project called ferry a point if we go to har three zeros 10416.

02:08:09 three zeros 10416. so i think we can see from the label at the bottom right hand side on this drawing that it's referring to ferrier point do you see that there yes yeah um and these are harley drawings and

02:08:23 and these are harley drawings and did you consider these drawings when you were sent them

02:08:27 um it was explained to me that this was going to be the um the concept design to be applied to grenfell

02:08:39 design to be applied to grenfell this was this was in harley's terms a proven

02:08:43 proven um solution i see so they did explain to you that that's why you were being sent the details of this project that's right yeah

02:08:52 yeah were you aware that the type of cladding used at ferrier point was rainer bond acm

02:08:56 acm the same no i was aware it was acm but um never considered the manufacturer were you were aware that that it was

02:09:07 were you were aware that that it was rainer bond acm and that was going to be the same

02:09:10 the same as at grenfell so you say you weren't sorry you start again you weren't aware of the manufacturer but were you aware that the same cladding manufacturer was going to be used i was told in the first meeting

02:09:21 used i was told in the first meeting with ray and dan the materials that we'd be using

02:09:25 be using okay so it wasn't specific to these drawings

02:09:28 drawings that have been very clearly laid down what i was expected to be using and what materials were you told you would be using at that first meeting it would be rigid insulation yeah which

02:09:39 it would be rigid insulation yeah which would be

02:09:40 would be a celetex type product and it would be acm

02:09:45 acm and the acm would be hook on cassette panels

02:09:50 you say did they actually use the words celetex

02:09:54 celetex type product i don't recall to be honest you don't recall no now we can see further from the sketches i think you've just referred to in your

02:10:06 i think you've just referred to in your last answer about

02:10:09 that you were told they were hook-on cassette panels at grenfell we can see from these sketches at ferrier that this was actually a face fixed

02:10:17 fixed system wasn't it riveted to the building that's right yes did you notice that that at the time that this was a face fix oh yes this um this was given as a guide

02:10:28 this um this was given as a guide and i was told although this is face fixed

02:10:31 fixed you would be providing a design for a cassette

02:10:35 cassette option and did you know what that meant yes totally yeah had you designed facades with the cassette

02:10:42 cassette type fixings before yes yeah yeah

02:10:46 but not for a high-rise residential building

02:10:50 building not with acm no i've done it with solid aluminium

02:10:54 aluminium yeah we can also see that the insulation used at

02:10:58 used at ferrier point according to this drawing was 200 millimeter rock wool duo slab insulation if you look at the label it might have to blow this up but the very

02:11:09 to blow this up but the very i can see that yeah so just just to help the panel as well at the very bottom left hand side of this drawing if we can blow it up there is a small label

02:11:21 there is a small label that says there rock wool juror glass rigid insulation did you see that sorry absolutely duo

02:11:34 sorry absolutely duo rigid insulation were you um aware of that when you were sent this that this was a mineral wool insulation that had been used at ferrier point i was and i was aware that a mineral wouldn't be used on grenfell

02:11:46 wouldn't be used on grenfell because there wasn't enough zone to provide thermal values who told you that um it was at the very first meeting with dan and ray

02:11:57 first meeting with dan and ray i don't recall at that particular point who was talking so not enough zone does that mean um on this particular job there's a 315 millimeter zone which means you can get

02:12:08 millimeter zone which means you can get easily get 200 millimeters of insulation yeah

02:12:11 yeah um i don't record the exact zone on um grenfell but it wasn't deep enough to get

02:12:17 get the correct amount of insulin so that's the distance between the concrete the original concrete and the rain screen panel that's correct it wasn't deep enough

02:12:24 enough you were told to put mineral wool insulation in there now i was told to put a celatex type rigid slab yeah and was that something you ever had

02:12:36 yeah and was that something you ever had a discussion with them about or was the position that you were simply told that no i was told materials that they'd selected yeah had you used mineral wool on yourself on previous projects

02:12:47 on yourself on previous projects involving rain screen clouding systems yes yeah had you used any celatex products previously when designing rain screen cladding systems or working on the

02:13:00 cladding systems or working on the the drafting of the drawings i've used celetex type products in the past but not on range screen now so did you note that this was going to

02:13:11 so did you note that this was going to be the first time you'd used that product um when you say note i mean i was aware yes um but because i wasn't doing

02:13:24 yes um but because i wasn't doing cladding on a day-to-day basis yeah it was no surprise because it was a few years since i've done cladding and i think that the seller takes is a relatively new product anyway yeah when you say it was a few years

02:13:36 yeah when you say it was a few years since i've done cladding what's your estimate as to how long it had been

02:13:41 had been prior to the grenfell project that you'd worked on a cladding project i would think it was probably um chow cards six years private

02:13:54 now a paragraph 14 of your statement if we go back to your statement h-a-r there we go thank you you described the meeting that you had on the 12th of august with ray bailey

02:14:05 on the 12th of august with ray bailey and daniel anchor jones and you say this at the beginning you say

02:14:10 you say at the meeting we discussed the project and the scope of works i was told that the design was going to be a hook on cassette configuration rather than face fixed and the aluminium composite material cladding was going to be used

02:14:23 cladding was going to be used i also remember discussing the specially extruded aluminium profiles which were going to be used you see that there so you don't mention the insulation there but um is it your evidence that

02:14:37 um is it your evidence that you were told at this meeting that it would be a rigid installation yes it would be used definitely yeah i think you said you couldn't remember whether you were told it was celetex at this point

02:14:48 it was celetex at this point no i don't recall whether it was but it was it was always going to be a rigid insulation a pri type material but thermal calculations had to be provided

02:15:01 thermal calculations had to be provided to come up with a thickness yeah and you prefer that to a pir type material can you help us as to what you mean by that um it's a rigid

02:15:10 rigid insulation slab yeah rather than a mineral did you know pi arte mean poly isocyanurate never gave it a second thought to be honest yeah

02:15:20 can you help us as to what was discussed what whether anything else was discussed at that initial meeting was anything else discussed as far as the specification of the project i mean

02:15:33 the specification of the project i mean in terms of your role on the project and what you were being asked to do um i was being asked to provide the drawings under the um under the technical team

02:15:45 under the um under the technical team from harley obviously i was given a program an indicator program for which i had to confirm i could work to

02:15:57 to and who did you understand to be their technical team at harley well it varied over the period um but at that stage it was primarily dan yeah and ray

02:16:11 it was primarily dan yeah and ray i think there was um recourse to mark stapley if necessary but they were the two front runners as far as i was concerned at that point was this meeting on your understanding

02:16:23 was this meeting on your understanding of it an

02:16:24 of it an interview for harley to decide whether you would be engaged to work on the project

02:16:29 project or was it effectively your appointment was a done deal and this was your introduction to the project that's correct it was a done deal i mean when i spoke to dan previously on the phone it was a case of

02:16:42 previously on the phone it was a case of do i have the capacity to do this particular job it's going to require a certain amount of hours um and i said yes i'm sure i could deal with that yeah do you recall whether any questions were

02:16:54 do you recall whether any questions were asked in relation to your experience or your abilities in relation to high-rise facade design definitely not were any questions asked

02:17:06 definitely not were any questions asked about your experience in terms of cladding design as distinct from windows or curtain walling no were any questions asked about your qualifications or experience

02:17:17 qualifications or experience no no

02:17:21 and can you just help us as to what you came away with from that meeting in terms of what the extent of your role would be my role would be to act as a drafting

02:17:32 my role would be to act as a drafting service

02:17:34 service to transfer the architect's drawings into fabrication drawings which are dimensionally accurate and could be transferred as product

02:17:45 and could be transferred as product drawings

02:17:46 drawings so as the the whole thing could be manufactured and installed did you understand you were going to be the project designer i think the um you don't want to read

02:17:57 i think the um you don't want to read too much into that term why um i think there's a general consensus that once you put the word designer in there there is an element of responsibility

02:18:09 there is an element of responsibility um far more than than maybe there should be

02:18:14 be were you being referred to at the time as the project designer or the lead designer i was never desi i was never

02:18:22 was never told i was the lead designer i was i was told i was a project designer the first i knew of that was when i had some business cards printed up with my name on

02:18:33 on but that didn't stop me from being quite clear

02:18:37 clear that i was working through their technical team

02:18:45 what was said to you about the extent of supervision you would be getting on the project

02:18:51 project um i don't think anything was specifically said um i was told that everything would go through dan um but as a remote source i wouldn't see

02:19:02 um but as a remote source i wouldn't see really what what that process would be i can only assume when i sent drawings to dan he would discuss them with ray and then the

02:19:13 discuss them with ray and then the comments

02:19:14 comments i got back would be acted upon did you understand that you had to send your drawings to somebody at harley for some kind of checking process to occur yes all of my drawings

02:19:25 occur yes all of my drawings would go through the harley team yeah and what did you understand they were doing to them when you sent them a day they would review key drawings for concept for concept what does that

02:19:38 for concept for concept what does that mean

02:19:39 mean compliance with their instructions to me

02:19:44 i was very much designing for harley as a direct client rather than designing for anyone else and was it your understanding that they would be checking those drawings for

02:19:55 would be checking those drawings for compliance with relevant regulatory requirements such as compliance with the building regulations or other i would have created guidance yeah i would expect an overview from them

02:20:06 them but ultimately in my history the responsibility for compliance would always

02:20:13 always fall down to the architect which is the main reason for him checking off all of the drawings we're going to come back to this topic in a minute because it's a key topic um but i just want to ask you one

02:20:24 um but i just want to ask you one further question on that at this stage where did that understanding come from on the grenfell project were you ever told by the way the person checking compliance on this project is

02:20:35 checking compliance on this project is the architect we at harley won't be checking for regulators no i was never told that so that was an assumption you made on the project was it

02:20:44 it yeah based on 30 years of um never doing it a different way i see

02:20:53 where you asked whether you would be comfortable working on a large scale rise high-rise facade project without direct supervision um i was never it was never implied i wouldn't have any direct supervision

02:21:05 wouldn't have any direct supervision right so you assumed you would be supervised definitely during the project yes you wouldn't expect a client to employ a third-party design source and then just let them

02:21:16 just let them get on with it it'd be very dangerous to come up

02:21:19 come up that was not your understanding of what was going to happen no not at all and did you understand in practice that you were being supervised during the project

02:21:26 project yes yeah by who um some of it was by ray some of it was by dan

02:21:34 dan i see

02:21:38 were you given any information about harley's

02:21:42 harley's contractual responsibilities or their scope of work and how you were being expected to help fulfill that um i wasn't told about contractual responsibilities

02:21:55 responsibilities but the scope of work was was very clearly laid out from ray in the first place ray and dan in that very first meeting and tell me about that scope of work

02:22:06 and tell me about that scope of work where did harley's work begin and end um well it was quite clear they they issued me with a copy of their quotation

02:22:17 issued me with a copy of their quotation and uh and on that quotation there's a small 3d model and it really identifies the whole scope of what they price for

02:22:27 price for so every element on that quotation had to be drawn and did you understand that it was a quote for the entire facade works that's right yeah yeah

02:22:39 now i just want to turn to paragraph 79 of your witness statement this is har three zeros 10419 a page 18 and i want to look at the bottom of page

02:22:50 and i want to look at the bottom of page 18 and on to the top of 19.

02:22:54 so you say this there although i was not aware of the exact wording of the contract agreed between ryden and harley i would assume it was to provide a complete facade envelope consisting of replacement windows

02:23:05 replacement windows improved insulation and decorative over cladding as specified and designed by the architects i assume it also included managing the operation and work teams to ensure works were completed in a

02:23:16 to ensure works were completed in a timely fashion do you see that there and then if we go over the page with minimal disruption to the residents always with a view to conforming to health and safety standards and good working practices do you see that there

02:23:28 working practices do you see that there yes yes i agree with that was that your assumption about the contractual position you've said i would assume it was to provide a complete facade envelope yes yes it was my assumption i was never

02:23:39 yes yes it was my assumption i was never led to believe anything else and did you understand that that would include cavity barriers in the facade yes yeah

02:23:50 were you ever given an opportunity to read any of the contractual documents we know now that there was a letter of intent and appendices appointing harley as the facade subcontractor did you ever

02:24:01 as the facade subcontractor did you ever see any of that now that sort of information would not be divulged to myself no

02:24:08 what was your understanding of studio e's role

02:24:11 e's role in so far as it applied to harley's work um it was their responsibility to check all the

02:24:20 all the drawings produced to suit their designing

02:24:24 designing intent and for full compliance

02:24:32 now you just use that word design intent can you explain what you understood at the time

02:24:38 the time checking for design intent would involve well what they intend the design to look like and how it was to perform which obviously would include full

02:24:49 which obviously would include full conformance

02:24:53 what do you mean by full conformance we're building regulations yeah and the other standards that are applicable so just to be absolutely clear your understanding was that the architect

02:25:05 understanding was that the architect would be checking for design intent and full

02:25:09 full compliance with all regulatory requirements including the building regulations definitely and again was that an assumption that you made based on past practice yes yeah did you ever have any

02:25:21 practice yes yeah did you ever have any conversations with anybody within harley or at studio e about what harley what so what studio eve were doing

02:25:30 doing uh in terms of their role on the grenfell project no i think it would have become obvious if we'd

02:25:37 if we'd had drawings returned to us um without comments

02:25:42 comments um i'm sure the architects if they felt it wasn't their role they would have made quite clear rather than just kept commenting see

02:25:53 than just kept commenting see so at no stage did you get the impression that they weren't checking for statutory compliance not at all

02:26:01 did you ever become positively aware that they were checking for that did anything ever stand out and when when they were i mean they were

02:26:12 and when when they were i mean they were certainly involved in discussions about cavity barriers um if they weren't checking for compliance and they would i'm sure they would take a step back

02:26:24 now you said in that paragraph that harley was to provide the complete facade envelope as specified and designed by the architects that's right can you help us as to what you mean by that as specified and designed

02:26:37 that as specified and designed but the architects have provided the design which is apparent on their drawings issued and they're specified uh the specification is the nbs specification that was

02:26:48 is the nbs specification that was supplied

02:26:51 but in practice we know this was a design and build contract um did you know that at the time it was design and build never crossed my mind to be honest

02:27:03 never crossed my mind to be honest forget the design and build but in practice wouldn't it depend at what stage the design was handed over by the architect

02:27:11 architect to the cladding subcontractor potentially yes yeah might you have a situation where all the architects done is look at very general concept design and aesthetics

02:27:22 concept design and aesthetics and it's gone over to a cladding subcontractor at quite an early stage in the design process leaving the subcontractor to do the detailed design work well firstly the architect's drawings were very detailed and the specification

02:27:34 were very detailed and the specification was very detailed um and my client harley instructed me to carry carry on with the drawings based on their documentation yeah

02:27:47 on their documentation yeah did you know that at the time that you felt that the architect's drawings were very detailed and the specification was very detailed yes yeah yeah can i just check yes what i understand you to be saying mr lam is that

02:28:00 you to be saying mr lam is that on this job at least your function was not to develop the design simply to trans translate the architects concepts as shown on their drawings that's right

02:28:11 that's right into drawings that could be used for fabrication and construction exactly yes yes

02:28:18 just breaking that down a bit um would you accept that not all the products

02:28:26 products to be used in the external wall had been specified by the architects um there may have been a couple i don't know what

02:28:35 know what um specifically i mean my my guidance was from harley yeah well we'll come to look at some examples of that in due course

02:28:44 course um but also would you accept that there was still some design work to be done on the facade for example in relation to cavity barriers um i understood the

02:28:55 cavity barriers um i understood the drawings as offered were fully uh full representation of what they required i see so you took those as the as the complete article did you that's right i think they were issued as

02:29:08 that's right i think they were issued as construction issue drawings

02:29:12 and when they're issued as that status then we would expect to expect no further com no further redraws by the architect when you say they were issued as construction

02:29:23 they were issued as construction issue drawings what do you mean by that um

02:29:27 um well the architect um in the early stages of a project they may have tender issue drawings yeah now they would be issued for to subcontractors or builders

02:29:38 for to subcontractors or builders to offer prices yes but before the full design starts the architect would raise those to construction issue to say look this is

02:29:49 to say look this is exactly what we want and then you would base your drawings on their final drawings i see so are you drawing a distinction between

02:30:01 between the drawings for example that studio e did as part of the employer's requirements with the mbs specification which formed part of the tender if they if they were marked up as tender on the bottom of the drawer in general they

02:30:12 bottom of the drawer in general they will be marked as tender or construction issue and here when you're referring to architects construction issue drawings are you talking about drawings issued after for example mr

02:30:24 drawings issued after for example mr crawford

02:30:25 crawford has commented on your drawings no most of his drawings should have been complete before i was even brought on board

02:30:34 board complete for construction issue that's correct yes doesn't construction issue mean that they can be sent and actioned on site and products

02:30:46 and actioned on site and products ordered etc no there's two there's two directions here

02:30:51 here um harley's drawings have to go harley's drawings are based upon the architect's construction drawings

02:31:01 drawings right so they're issued to the architect as approval he will make his comments upon those until they get to a construction status now one would assume that he's done the

02:31:12 now one would assume that he's done the same process with his client being the ktcmo or the builder or whatever

02:31:21 whatever again is that an assumption that you made or do you actually know that's what happened on the grenfell project i don't know what happened on the grenfell project all i do know is that you would generally treat any

02:31:32 that you would generally treat any drawings from an architect which are marked for tender you would treat those suspiciously because they may not

02:31:41 may not replica they might not um

02:31:45 portray the exact requirements from the architect

02:31:49 architect i see okay but we're going to come back and look at some specific drawings later which i think might help flesh out what your understanding was of different

02:32:00 what your understanding was of different drawings by studio e and harley at different stages um were you informed at this first meeting with daniel

02:32:11 at this first meeting with daniel anchor jones and ray bailey or indeed at any other stage in your work on the grenfell project that harley's work needed to comply with a curtin's structural performance specification

02:32:23 specification no i don't recall that no can we just pull up that document that's a rt50914

02:32:36 so this is a structural performance specification it's done for curt by curtin's consulting for studio on the 1st of march 2013. did you ever

02:32:47 march 2013. did you ever see that document on the project i may well have done but i don't recall referring to it if we look within the document if we go to page 11 paragraph 7.1.13

02:33:04 this is where the over cladding is addressed and it says in that paragraph 7113 the system should comply fully with the recommendations of the bre document fire performance of external thermal

02:33:16 fire performance of external thermal insulation for walls of multi-storey buildings

02:33:19 buildings second edition 2003. do you see that there yes i do were you familiar with that guidance no

02:33:30 so you didn't know that that guidance is otherwise known as br135 i didn't i was aware of br135 i see so you were aware of br135 at the

02:33:41 i see so you were aware of br135 at the time of the grenfell project okay we'll come back to that shortly now paragraph 95 of your witness statement

02:33:50 statement if we go back to that on page 22

02:33:58 you stay in the middle of line one you see as i've explained above the architects reviewed harley's drawings and as part of that process i

02:34:09 drawings and as part of that process i would expect any non-compliance with the building regulations and in particular parts related to fire safety to be picked up and flagged do you see that there yes and you assumed that studio he had

02:34:20 yes and you assumed that studio he had the benefit of specialist advice from amongst others fire specialists do you see that there yes and

02:34:28 yes and that expectation again can you explain where that came from was that something that you were told on the grenfell project or just an assumption you made it was

02:34:39 or just an assumption you made it was it was a an assumption based on normal working practice

02:34:46 did you ever make any inquiries to ascertain where the studio had in fact engaged fire specialists no no i didn't but it became apparent during the course of the project that

02:34:57 during the course of the project that they had

02:35:02 did you understand that harley and those working for harley including yourself had to independently check whether the drawings you were provided

02:35:13 whether the drawings you were provided with were compliant with the building regulations including parts relevant to fire safety

02:35:26 parts relevant to fire safety was it your understanding that other parties were relying on harley as the specialist subcontractor being aware of those

02:35:34 those requirements those statutory requirements not having seen the contract no when you say having seen the contract what do you mean by that well you mentioned the contract earlier yeah harley's receipt from uh ryden's

02:35:47 yeah harley's receipt from uh ryden's yeah which implies that they um they should have been doing that implies that harley should have been doing that yeah yeah but i was i was not aware of that because i didn't see that documentation

02:35:59 at the time does that mean that you didn't think it was any part of your role

02:36:03 role to be checking whether or not the designs were compliant with the statutory

02:36:08 statutory requirements i would certainly congratulations i would certainly consider anything that seemed out of the ordinary

02:36:16 just as a matter of diligence yeah so it was only if something stuck out and looked odd yes that you would check it that's correct otherwise would you make an assumption that it was

02:36:28 would you make an assumption that it was compliant with relevant requirements that's right or i may discuss it with with the technical team at harley now let's look at your scope of works let's look at you

02:36:39 let's look at you and your quote that you put in this is har

02:36:43 har four three zeros 10415 so this is a document which you prepared is that right that's correct yeah

02:36:55 is that right that's correct yeah bespoke design at the top it goes to harley and um for the attention of dan ankertel jones we can see that on the left-hand side yeah and it's dated the 12th of august 2014. so this is

02:37:06 2014. so this is the same day that you met ray bailey and dan angus or james is that correct correct yeah did you prepare this document

02:37:13 document before the meeting and take it with you or did did you send this afterwards uh this was sent afterwards

02:37:22 and you say there in the the covering this covering part of it dan further to your email 7th of august 14 and our meeting this morning sorry it was clear uh that you've done this

02:37:33 it was clear uh that you've done this afterwards please find below our quotation for design

02:37:38 design services to the aforementioned project do you see that there yeah that's right so you were quoting for design services on the project drafting yeah drafting yes yeah when we design services there

02:37:54 could we substitute that for drafting services yes yeah yeah now you refer to an email of the 7th of august in that covering part yeah don't think we've

02:38:05 covering part yeah don't think we've ever seen that email can you recall what that said in general terms

02:38:09 terms that email had the documents listed where it says based upon yeah these documents were in that email i see

02:38:19 so yeah we've got a list at the bottom of what you were sent turning to page two of your quotation

02:38:30 we see the design services so we've got elements at the top

02:38:37 top and it's got ga design is that general arrangement design that's correct and then you've broken it down and we see in the third point you've got cladding there yeah do you see that there yeah

02:38:50 see that there yeah does this mean that you were quoting for designing the overall composition of the cladding system and not only the detailed fabrication drawings no

02:39:01 so in relation to the cladding

02:39:05 what were you quoting for what was general arrangement design in relation to cladding what did that involve these are the translation drawings taken from the architect translating his design

02:39:16 the architect translating his design into harley drawings and just to be clear were you ever told that the architect's drawings only took

02:39:28 that the architect's drawings only took the design so far and that there was more design work that needed to be done as part of your job no no not at all

02:39:39 as part of your job no no not at all now you say bullet two then we've got schedules and fabrication drawings and then we've got other items there and that included the windows from the fourth to the 23rd floors that's

02:39:51 the fourth to the 23rd floors that's right yeah and the cladding and then we can see if we go to page three under the heading notional task times we could blow that

02:40:04 up so you've got initial drawing issue 2 to 17 days depending on elements selected design freeze tbc what does that mean

02:40:16 design freeze tbc what does that mean um it's sometimes there is a critical path point in a program where all of the designs have got to be approved by the architects

02:40:27 approved by the architects right um i didn't put it in there maybe it wasn't told to me when that was and then total design period approximately 41 days we can see that there

02:40:36 there yeah how did that estimate of the amount of work compare with the work you think you actually did on the project um i think i may have done a little bit more i don't think um

02:40:48 more i don't think um be vastly more but just bear in mind the 41 days that's not concurrent i might have done it yeah a couple of days here in a couple of days yeah but it but it's in the right ballpark in terms of what actually

02:40:59 ballpark in terms of what actually happened

02:41:00 happened yeah i think so yeah and we can see that your quote was originally ten thousand five hundred and seventy two pounds eighty excluding that you see that there yeah now during the time you worked on the grenfell

02:41:12 the time you worked on the grenfell project where you were also working on other projects yes and

02:41:18 yes and in terms of your time on grenfell was it on an as and when required basis or were you ever told that you were required to set aside a number of days per week

02:41:29 per week we discussed program key dates in the program

02:41:33 program and i had to make sure that my other work didn't interfere with that yeah which is quite common on virtually the jobs i do so you were aware of the general shape of the program so that you could plan your

02:41:44 your work yeah and turning to page four we look at that and we blow that up

02:41:55 this is your quotation summary and it's broken down and then we've got this box on the right yeah with different little headings on the side

02:42:04 the side um and we've got specifications you've quoted in your breakdown for specifications you see that there does that mean that you thought it was part of your role or anticipate at this

02:42:15 part of your role or anticipate at this stage it was part of your role to consider

02:42:18 consider the materials that have been specified no it was simply to put the details as specified on our drawing number 100. but suppose the drawing

02:42:31 but suppose the drawing from the architect didn't show a particular product specified yeah um take the window infill panels the white window info panels um did you anticipate that it might be

02:42:43 um did you anticipate that it might be part of your job to select products and set out specifications for some of the external wall i would never i would never never have been expected to specify

02:42:54 never have been expected to specify products

02:42:56 products but in that particular instance a product was suggested and it was discussed

02:43:02 discussed i see it and when you say it was suggested you mean suggested by harley suggested by me too harley yeah to the team

02:43:10 team yeah so

02:43:13 yeah so is it your evidence that you didn't expect to be doing it but actually in practice

02:43:18 practice you did sometimes make suggestions about materials to be used in the external wall

02:43:23 wall yes yes in a minimal way then at page six we've got your standard terms and conditions under the heading i want to look at the

02:43:34 under the heading i want to look at the heading submissions which is at the bottom of that page

02:43:40 do you see that there and clause 4 roman numeral 4

02:43:45 numeral 4 it says modifications not redesign of architectural submission drawings expected up to revision b inclusive further requests for updates

02:43:57 inclusive further requests for updates chargeable at standard bespoke design hourly rate can you help us as to what that meant what does modification not redesign of architectural submission drawings expected up to revision b

02:44:08 expected up to revision b um it's quite common to issue your first drawing

02:44:12 drawing and receive some comments back from the architect

02:44:16 architect so then you would revise your drawing yep

02:44:19 yep which would take the drawing up to state up to revision a not status a but revision a the architect

02:44:27 architect may make further comments which he shouldn't really do but sometimes historically they do they keep making comments upon drawings that they've already commented upon yeah this is a clause

02:44:40 commented upon yeah this is a clause to try and stop that

02:44:43 or else i could be could be revising drawings forever so you said expected up to revision b does that mean you give them one chance to have another go but after that yeah yeah you're not anticipating no

02:44:55 yeah yeah you're not anticipating no and and really this is just to protect myself certainly in the case of grenfell no further costs were sent onto harley for any of the drawings over revision b

02:45:07 revision b so just to be clear this is modifica modifications you're making in response to architects comments that's correct not modifications you're making to their

02:45:18 modifications you're making to their designs no okay

02:45:24 now you say um i don't think we need to pull this up but in the final sentence of paragraph 14 that at that first meeting with harley on the 12th of august 2014 you also discussed your attendance at a design

02:45:36 discussed your attendance at a design team meeting on site at grenfell the next day yeah that's correct

02:45:43 would it be normal for you to attend design team meetings outside the day after an initial meeting on a new project uh not often but it's not unusual

02:45:55 uh not often but it's not unusual did you get the impression at this stage there was time pressure to appoint a project designer on the job

02:46:02 um well there was certainly pressure on pressure to actually move the job along whether they were just being expedient and i say they i mean harley i don't know right

02:46:15 can we turn now to ryd three zeros one five five four nine

02:46:27 so this is an email sent three days after that initial meeting you had from daniel anchor jones to simon lawrence ryden were you told who the main ryden

02:46:38 were you told who the main ryden contacts were on this job at the beginning only at the dtm one at the design team meeting yes okay um and you're copied in and rob maxwell of harley's also copied

02:46:49 and rob maxwell of harley's also copied in and the subject is grenfell tower design

02:46:52 design and daniel says good afternoon simon following on from the meeting on wednesday i would just like to confirm that kevin will be the main designer working on grenfell tower do you see that there

02:47:03 tower do you see that there yeah and we are keen to get on with the design as quickly as possible therefore we'll proceed with champagne cassettes as discussed we are going to focus on the details around the windows which will allow us

02:47:14 around the windows which will allow us to finalize the extrusion design as quickly as possible if you could send over the drawing submitted for planning this would be a great help we want we want to be sure all the right specs are on the drawings to start with and

02:47:25 are on the drawings to start with and get as much signed off and agreed as we can do you see that there yes now what did you understand him to mean when he refers to you there as the main designer

02:47:34 designer i would be doing the um the actual drawing work

02:47:40 he doesn't say kevin lamb will be the draftsman

02:47:45 draftsman or kevin lam will be the fabrication draftsman

02:47:48 draftsman does he he says main designer that's right main designer but it is um he has addressed this as design manager so one would assume

02:48:01 when would a team work one would assume that he would be controlling the uh the design

02:48:06 design and was that your understanding that daniel anchored james as the design manager would be controlling the design yes if he wasn't doing it himself he'd be passing it on within the company yeah yeah and did that understanding remain

02:48:19 yeah and did that understanding remain your understanding throughout the project um until a later point when um he stepped sideways yeah then that passed over to a combination of ben

02:48:31 passed over to a combination of ben and um mark stapley but i think always ray was in the picture

02:48:42 and then we see in the fourth paragraph um there's reference there to we want to be sure

02:48:47 be sure all the right specs are on the drawings to start with can you just explain exactly what that

02:48:56 meant as far as you understood it yeah i i think this is um in relation to the actual

02:49:07 um in relation to the actual champagne cassettes i don't know i'm making assumptions i don't know yeah you don't know fine

02:49:17 was it your understanding at this point that it was part of harley's job to check the specification to date on the project and check that it was

02:49:28 on the project and check that it was compliant with relevant requirements the nbs the mbs and the drawings that had been produced as part of the spec as i've said before i don't believe so now

02:49:41 i don't believe so now now at the time of the grenfell project and after your appointment did you understand that you had any duties under the cdm the construction design and management regulations

02:49:52 management regulations um not specific obviously i should have um

02:49:55 um a certain care and that health and safety is considered yeah but the the lead designer should have the major uh concern with cdm were you aware that as

02:50:06 concern with cdm were you aware that as a

02:50:07 a designer you owed duties to your client and duties when preparing or modifying a design

02:50:13 design under cdm i wasn't modifying designs so you don't think anything you were doing would fall within the definition of modifying a design no no

02:50:25 did you ever do any design risk analysis or risk assessments for the project

02:50:34 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 subcontractor was responsible for each element of the design i'd not come across that before

02:50:47 design i'd not come across that before to be honest no so that was not something you thought about on the grenfell project

02:50:53 in respect of the design drawings that you produced so you took the architect's drawings and you converted them into drawings that could then be used for fabrication that's right

02:51:04 fabrication that's right what quality control mechanisms did you understand harley to have in place to check those drawings um to check them for walks well for

02:51:16 um to check them for walks well for example for statutory compliance or compliance with the building regulations well i don't know what they had in place but um i wouldn't have expected them to be checking for compliance anyway because why not but i think that was the

02:51:29 because why not but i think that was the architect's role i mean they would certainly have an overview if they um if they felt there was a glaring non-compliance but um i don't think that was their

02:51:40 but um i don't think that was their ultimate role in terms of quality control more generally leave aside from compliance for for the moment were you aware that there was any quality control mechanisms in place in terms of your

02:51:52 mechanisms in place in terms of your drawings

02:51:53 drawings all of my drawings were submitted to the team

02:51:59 i mean to get the process correct in the early stages i used to attend the office

02:52:06 office maybe once a week once a fortnight spend a day in the office part of that day would be spent with ray and or dan and or mark stapley and we would approach

02:52:19 or mark stapley and we would approach key design elements and once we decided around the table what was required

02:52:27 required i would go away produce that and for expedience the drawings were offered issued directly to ryden's but they were always copied into harley for a review

02:52:38 for a review they had an opportunity to review at the same time the architect was reviewing now that's um the early stages yeah sounds like you might have been drawing a distinction there

02:52:49 a distinction there then between what happened in the early stages and what happened later in later stages of the project it was well as as you go on in a project um

02:52:57 um a lot of the drawing work is just dealing with architectural comments yeah concepts are generally dealt with in the early stages

02:53:08 does that mean as you went on in the design process um that you didn't have the same opportunities to sit down with ray and dan

02:53:18 dan or mark had the same opportunities but we tended to as as time went on it was only certain key items that

02:53:29 it was only certain key items that provoked around the table discussion right

02:53:37 now i think you deal with this at paragraph 32 of your statement if we go to that it's on page 8

02:53:44 8 of your statement

02:53:48 so you're saying that if we blow up 32 at the beginning of the project i tended to go into harley offices around once a week and attend meetings on site or in the office as and when was required towards the end of the project

02:54:00 required towards the end of the project i went in less frequently subject to any issues arising in the infancy of the design i would meet with ray bailey and or daniel anchor jones and talk about the design and how to set things out

02:54:12 to set things out ray bailey would tend to provide conceptual input for example suggesting the extruded special profiles to make the installation easier and daniel uncle jones would give more technical structural and engineering

02:54:24 technical structural and engineering input

02:54:25 input such as the fixings and thermal values you see that there yes agree with that and then you say my usual practice

02:54:36 following discussions at harley was to send drawings to ryden and studio e and copy in someone from the internal harley team

02:54:43 team both ray bailey and daniel angle jones were more actively involved at the beginning of the design process including for the first few revisions of each drawing later on if there was a significant change or an issue came up i would speak to ray

02:54:55 or an issue came up i would speak to ray bailey about this in particular i recalled daniel anchor jones becoming less involved quite early on in the job as he was working on other harley projects do you see that there correct yeah now if we just go back a page to look at

02:55:08 now if we just go back a page to look at the

02:55:09 the the bottom of that page again you say there that ray bailey would tend to provide conceptual input can you just help us you've said for

02:55:20 can you just help us you've said for example suggesting the extruded special profiles to make the installation easier can you help us in more layman's terms to

02:55:28 to what that might well fortunately he did a very good job on the flipboard when he was given his evidence of um

02:55:35 of um the extruded um angles there's aluminium angles

02:55:39 angles i see around the window top of the yeah top and bottom of the window openings yeah and

02:55:44 yeah and although you could have something very simple he took it to a further degree to make it

02:55:50 make it a multi-purpose product right so okay and then you say daniel encd or james would give more technical structural and engineering input such as the fixing and thermal

02:56:01 input such as the fixing and thermal values yeah did you understand that daniel's role there was limited to just structural matters i don't believe so now

02:56:14 if you'd had to describe what his role was

02:56:17 was in terms of inputting into the work that you were doing how would you describe it

02:56:24 sorry can you say that again how would you describe i mean you've said here more technical structural and engineering input such as the fixing and thermal values are those the best examples you can give

02:56:35 are those the best examples you can give of

02:56:36 of how he was inputting into the design yes yes really yeah can you think of any other

02:56:41 other aspects that he inputted into

02:56:48 not off the top of my head to be honest no and what about fire performance did you understand that there was anybody within harley who was

02:56:59 within harley who was helping with any fire aspects of the design

02:57:03 design um i don't think there was specific requirements for fire protection other than meeting the requirements for providing cavity barriers

02:57:15 cavity barriers so just to be clear is your understanding of the the regulatory regime at the time that the only thing you needed to think about in terms of fire was cavity barriers not the only thing but um

02:57:28 not the only thing but um the major thing i think yeah what else were you aware of that you ought to be thinking of in terms of fire performance and the facade well materials obviously yeah

02:57:39 yeah um but um

02:57:42 um but um none of that concerned me it was all issued to me as a fate accompli this is what we're doing and if you'd had a query about fire performance on the job

02:57:53 fire performance on the job who would you have understood that you should talk to you within harley to help you with that i would approach the team at one of these round-the-table talks

02:58:06 if there was no one if there wasn't a pool of people i think i would have approached ray

02:58:14 so you say the team at one of these talks

02:58:17 talks that the team would be ray bailey and dan anchored jones is that right it depends sometimes it was dan was there

02:58:25 there sometimes mark stapley was there yeah sometimes ben was there okay so you would have seen ben as part of that team would you that you could at a much later stage yes yeah

02:58:42 mr terry i think that might be i'm part way through this topic but i think that might be as good a good idea to stop at that point yeah yes

02:58:49 yes right thank you well mr lam it's time we all had a break for lunch i think so we're going to stop now we'll resume two o'clock please okay and i must ask you not to talk to anyone about your evidence or anything

02:59:01 anyone about your evidence or anything relating to it while you're out of the room i understand that thank you very much will you give the usher then she'll record you okay

02:59:19 right two o'clock please

02:59:39 you