London Fire Brigade Evidence - Tuesday 2nd November 2021 (2/2)

2 November 2021 · London Fire Brigade witnesses, Counsel to the Inquiry · 2:04:17
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Grenfell Tower Inquiry - London Fire Brigade Evidence - Tuesday 2nd November 2021 (2/2)

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00:00:25 would you ask mr carp to come back in please thank you

00:00:42 good all right mr come up i'm ready to keep going yes thank you mr can hear when you're ready thank you um good afternoon mr cowart during the morning session we uh addressed an email from louise upton of

00:00:53 addressed an email from louise upton of the 1st of july 2013 in which she said that she had quotes detailed comments particularly the first section when hazards are identified in relation to the draft gra and she said you'd deal with those later

00:01:05 with those later were any comments regarding hazards and their treatment in the draft gra 3.2 communicated to you either from louise upton or by mr britsman or indeed anyone else from clg

00:01:18 britsman or indeed anyone else from clg not to my recollection though

00:01:22 now can i turn to a further meeting that you had with mr britsman on the 28th of november 2013. um

00:01:31 um now first of all am i right and understanding that there was in fact a meeting on that date

00:01:37 can you remember now off the top my head i can't remember if you were going to show me a document that suggests it it's just happy to agree to it well let's just take it there's a suggestion that one was due to be set up if we can

00:01:48 that one was due to be set up if we can go to an email lfb00102592

00:01:58 it's an email from philip morton to you

00:02:04 suggests a meeting on thursday the 28th of november with uh les britsman at his suggestion can you call whether it took place

00:02:18 i would i would imagine it would have done but i can't say with complete certainty

00:02:24 certainty but it's not a meeting that sticks in the mind for any reason well without knowing the content of it maybe the content no i was hoping to find that from you but um oh sorry i'm asking the question mr cap

00:02:37 asking the question mr cap no in that case i'm sorry i'm afraid i can't really help you thank you can we deal now with um final discussions before publication and particularly concern over lack of consultation concerning the substance of

00:02:49 consultation concerning the substance of clg's changes now the final version of gra was finally published in february 2014 um would it be correct to say that one final issue that was discussed before publication

00:03:01 that was discussed before publication was that of consultation and specifically whether it was a matter of concern that the draft gra had not been subject to any further consultation uh

00:03:12 subject to any further consultation uh following the last round of changes etc made by clg which culminated in november 2013. is that a first summary

00:03:24 possibly i i don't particularly remember such a

00:03:29 such a conversation in that particular tight time scale i was generally concerned about that issue as you know

00:03:39 whether it come to any kind of head or or it got resurrected after christmas i i can't really say for sure if we can look at some of the contemporaneous email correspondence which don't

00:03:50 email correspondence which don't fully address it but i'd be grateful for such help as you're able to provide i'll do my best can we look at lfb trouble zero eight seven four zero four

00:04:02 um now just in general terms just so you know what we're looking at it's an email thread between melanie gillett that's how you pronounce it of clg philip morton yourself if we go to the end of

00:04:13 morton yourself if we go to the end of page two

00:04:17 this is the starting email of the chain and you can see that melanie gillett asked for confirmation that the final version of gra 3.2 had been the subject of consultation with

00:04:29 been the subject of consultation with quotes the usual list of consultees we then see a reply for from philip morton it's on page one

00:04:40 morton it's on page one that's sent on the 6th of february at 12 46 hours and he says quotes this document has been extensively consulted upon with all the normal consultees and many more in addition

00:04:52 many more in addition then if we go further up we see an email from you which says this mel

00:04:59 mel slash all

00:05:01 slash all in addition to what phil says below all of which i can confirm i would also make clear that the published version has of course been changed by clg cfra from the version that was consulted

00:05:13 cfra from the version that was consulted on nationally with other fire and rescue services staff side open brackets fbu closed brackets and other interested stakeholders i don't believe any of these amendments

00:05:24 i don't believe any of these amendments have detracted from the original in any way but when these changes were being proposed and made i did caution les britsman about the implications of making any significant changes as this

00:05:35 making any significant changes as this would be outside the normal gra consultation process

00:05:41 now i think taking a step back this confirms the evidence you gave this earlier today and indeed was resonates in the email correspondence you had with les britsman

00:05:52 correspondence you had with les britsman because the effective point you're making here that consultation ended in september 2012 and if any amendments are significant then that may well trigger

00:06:03 then that may well trigger the obligation to consult further absolutely

00:06:15 at this stage had you had you formed the view that the amends that had been made late in the day by clg were essentially

00:06:26 late in the day by clg were essentially minor and so there was no further obligation to consult triggered

00:06:32 i i didn't feel they introduced any significantly new material they obviously highlighted stay put for good reason

00:06:43 for good reason and and they refined issues as we discussed this morning but i didn't feel the my personal view was that the overall substance of the document had not been

00:06:54 substance of the document had not been significantly changed you'd be very helpful in setting out your view with the benefit of reflection and with hindsight with that benefit do you think the changes were such that

00:07:06 do you think the changes were such that there ought to have been a further round of consultation given the nature of the changes i'm thinking about the particular points about stay put that were included in the fsg section

00:07:18 that were included in the fsg section i think it's always good practice to be open transparent and for a document to have integrity so if you've consulted on something

00:07:27 something you then publish something different those that were consulted upon there's always a risk that they might cry foul and they may may have an issue that you don't envisage that they've got an issue

00:07:39 don't envisage that they've got an issue with what you've published my judgment because again i was still batting for this to be published my judgment was that the changes clg had made would not elicit such a response

00:07:52 made would not elicit such a response however

00:07:54 however such a response was possible so i perhaps take the opportunity to repeat what i said earlier i am mystified even more now i've seen the correspondence i've seen why

00:08:05 why those comments weren't brought forward in my view prior to the national consultation phase i.e june july

00:08:16 june july 2012 would have been the absolutely right time to bring all those comments forward they could have then gone in the version that went out for national consultation and all of those risks and issues would

00:08:27 and all of those risks and issues would have been avoided thank you we're now going to leave gra 3.2 and move to pn 633

00:08:38 okay now you have uh stated uh in written and indeed in your oral evidence that you are not directly involved in the review process of pn 633

00:08:51 of pn 633 except in respect of your role as an assistant commissioner with responsible responsibility for operational policy is that a fair and accurate summary it is thank you

00:09:01 thank you is it correct though that you are ultimately responsible for the content of 633 in your position as head of operational policy absolutely and specifically you were responsible

00:09:12 and specifically you were responsible for the version of 633 that was in force on the 14th of june 2017. yes and that version was published in june 2015 while she was still the head of

00:09:24 2015 while she was still the head of operational policy that's correct thank you

00:09:27 you now you've explained in your witness statement and very helpfully over evidence over the past two days that the review of 633 was in hand whilst the drafting of gr8 point

00:09:39 in hand whilst the drafting of gr8 point 3.2 was taking place is that of again a fair summary i think it i think it is because as as i think i said in my statement it was a very

00:09:51 it was a very close and sort of symbiotic relationship between the two documents they stopped you there just to so that we can see the reference in your in your witness statement if i could ask you to go to lfb double zero double one nine eight

00:10:05 lfb double zero double one nine eight four nine forward slash three and if we can look at paragraph six in particular at the bottom of the page um you said the my review and that's the review there i think of gra 3.2 has also highlighted to

00:10:19 think of gra 3.2 has also highlighted to me the interconnectedness of the development of gra 3.2 and lfbs pn 633 over the course of 2011 to 2015 the extent of which was not

00:10:31 extent of which was not conveyed sufficiently in my original report

00:10:33 report the symbiotic manner in which these two documents were produced meant that the processes applied

00:10:40 applied to the development and review of pn 633 were not in practice as linear and compartmentalized as the process chart provided in appendix 3 to my

00:10:51 chart provided in appendix 3 to my original report indicated for example a large number of the lessons identified from the lachnal house fire we incorporate into the version of lfb's pn 633 it was published in november 2011.

00:11:05 633 it was published in november 2011. this document influenced the initial development of gra 3.2 and then the outcomes of research and consultation for gra 3.2 fed back into the subsequent version of pn 633 that was published in

00:11:18 version of pn 633 that was published in 2015.

00:11:20 2015. all of this meant that there was not a conventional one-way flow of information from national guidance into lfb policy now that paragraph does that convey the nuances you'd want to communicate to the

00:11:31 nuances you'd want to communicate to the panel about the pros the policy development process that determined 633 in broad terms yes thank you

00:11:42 so to be clear there was a revised version of 633 that was published in november 2011. correct and that and following a review as a result of the lack of fire correct

00:11:53 lack of fire correct and a further revised version was published in 2015 which reflected in turn the published revised gra 3.2 correct i think to be complete

00:12:05 correct i think to be complete there was an interim version in 2012 2013 which i think covered some administrative issues it it's covered in the

00:12:16 issues it it's covered in the track i think i'm right in saying that i may be wrong but i think there was an interim version but it was a it was as a result of other policies changing their name or designation

00:12:29 changing their name or designation so it was an administrative change it wasn't a substantive change i'm grateful now the first topic i'd like to discuss with you is the general process for policy development at the lfb

00:12:41 policy development at the lfb now appendix 3 which you refer to there in paragraph 6 is one of the appendices to your report pc6 is that right that's correct and it contained a chart that summarizes

00:12:52 and it contained a chart that summarizes the lfb standard process for producing new operational policy or making amendments to existing policy is that right that's correct now if we can go to appendix 3 it can be found at lfb

00:13:05 appendix 3 it can be found at lfb zero

00:13:06 zero three two eight one three forward slash two

00:13:16 and is that the appendix three you're referring to in your paragraph six of your third witness statement indeed

00:13:24 now the first column on the left hand side

00:13:27 side sets out the different quotes drivers for change close quote is that right yes and these are the events that may be external or internal that trigger akron

00:13:38 external or internal that trigger akron by the operational policy department is that right in a general sense it's not meant to be absolutely exclusive there could be other events

00:13:49 exclusive there could be other events this this this was something i created because there was no agreed process when i took up the post so i created it to try and bring

00:14:00 and bring greater consistency and and it was very useful for people joining the department to to have something very clear to follow

00:14:09 follow and you produced this in 2010 or thereabouts would that be about right i think the first version was as early as that yes it's been changed many times and and

00:14:20 it's been changed many times and and adapted and improved but yeah so what iteration of the flowchart is this is this the last one you had whilst you were still in post i

00:14:30 i think because i because i added it to the report that i'd been asked to write i think i probably added the version it says in the top left hand corner final version

00:14:43 the top left hand corner final version january 2019 it's likely this is a more up-to-date version than when i was in post

00:14:50 post you left in march 2016 correct with whom did you consult to to ensure that this captured developments over the later three years i

00:15:01 i i took it i i took it as a document it was the current version i think that was available at the time the report was written i think to be fair that the changes are

00:15:15 relatively minor but i i don't think it's substantially changed in that time but i think i think for example the delivery and communication strategy

00:15:26 the delivery and communication strategy might not have been there at the beginning for example that's one thank you possibility and that delivery communication strategy is in the column on the far right hand side is that right that's correct

00:15:38 side is that right that's correct thank you very much for that clarification now can we look at the far left hand side column and the examples of the external drivers are set out in the top

00:15:49 the top subheading in that column and they include legislative change national directive and so on and the introduction of a national uh generic risk assessment would also be a generic driver is that

00:16:01 would also be a generic driver is that right

00:16:02 right i think i would have interpreted that to be a national directive

00:16:07 directive it's nationally produced guidance thank you and looking further down that column you give

00:16:13 you give examples of internal drivers including the diot process which we heard about in module 5. can you explain the type of drivers that might be identified by the diot process

00:16:25 might be identified by the diot process that would in turn prompt action by the operational policy team so the kind of the diet process reflects issues identified via performance review

00:16:38 issues identified via performance review so

00:16:39 so the brigade's operational review team for example the outcome of performance reviews of command or performance reviews of operations debriefs

00:16:50 debriefs operational learning the idea of the diet process was to bring that into a kind of systematic approach so that the learning was

00:17:01 approach so that the learning was captured

00:17:02 captured and then applied as necessary and if you look at this in terms of a safe system of work the risk assessment and the policy

00:17:13 and the policy should always be the headline event so if something has been perceived as a gap or as a deficiency the first place that the change should happen is in the

00:17:25 that the change should happen is in the risk assessment then the policy and then that is used to specify training

00:17:32 training and possibly equipment whose responsibility was it to ensure that the internal drivers were identified and acted upon by the operational policy team

00:17:47 i think i'm right in saying the die up process was owned by however gary reason as the director or possibly

00:17:58 gary reason as the director or possibly danny cotton as the assistant commissioner operational assurance because most of it most of the legwork for diet was done in her

00:18:09 legwork for diet was done in her department or by her staff for example the operational news that closely reflected what was going on in die op

00:18:20 in die op so in terms of that part of it that would be either danny cotton or gary reason the introduction of new equipment and

00:18:31 the introduction of new equipment and procedures well procedures would normally be ops policy but we only owned around about 80 of lfb's operational policy so

00:18:43 of lfb's operational policy so there's quite a large percentage is owned by other departments you say only 80 percent well it's

00:18:53 well it's i think that equates to around 190 documents

00:18:58 documents of a total of 2 30 documents so looking at the 20 that wasn't owned by you could you give the panel an idea of the subject areas or activities that the subject of policies

00:19:11 activities that the subject of policies that you did not own yes

00:19:15 incident command that was owned at the time by operational assurance anything relating to transport or terrorism

00:19:25 terrorism or

00:19:30 i was going to say contingency planning emergency planning in its broadest sense that was owned by operational resilience there's a few policies owned by service

00:19:41 there's a few policies owned by service delivery if the easiest way for the absolute facts is if you look at my report it's detailed in there it was just i didn't want to go yeah in pure numbers it's detailed in there so service

00:19:52 it's detailed in there so service delivery which was dave brown's department at the time they owned a few regulatory fire safety phones some as well so the phased evacuation policy

00:20:03 well so the phased evacuation policy which is one that you might will be interested in was actually owned by regulatory fire safety

00:20:11 safety thank you

00:20:13 now looking at the particular example of a national or new national generic risk assessment whose responsibility would it be to be aware of the fact of it and its

00:20:24 be to be aware of the fact of it and its content

00:20:25 content and the consequences for lfb policies so at that time that that was me so i was the point of contact

00:20:36 so i was the point of contact i received them

00:20:40 a large number of them were for operational policy to deal with so so i would just pass them to the team member but where they cross those departmental boundaries that we've just

00:20:51 departmental boundaries that we've just discussed

00:20:53 discussed i would pass them to the relevant head of service thank you now going back to

00:20:59 to the table the next column along from the left is risk assessment and that's the next stage of the process is that right correct and risk assessment is a

00:21:10 correct and risk assessment is a specific document that is generated in order to form the basis of a new or amended policy is that uh at least in broad terms correct that's absolutely correct

00:21:20 correct and if we look at the text immediately under the subheading risk assessment in that column we can see that risk assessment is designed to identify quotes

00:21:29 quotes hazards risks and control measures be implemented within the policy is that right yes

00:21:36 right yes and who is responsible for preparing the risk assessment it would be the responsible team that are dealing with the policy so it's it

00:21:47 are dealing with the policy so it's it should be their first step towards creating or amending the policy so in relation to instant command presumably that would be operational assurance correct and in relation to 633 it would be your

00:21:58 and in relation to 633 it would be your department correct

00:22:02 moving further towards the right we look at the third column and that's entitled procedure development in broad terms that's essentially the

00:22:13 in broad terms that's essentially the drafting process is that fair indeed

00:22:16 indeed and is it correct that the drafting of the policies carried out by the operational policy department or would it be

00:22:23 it be done by the responsible department so for example in instant command it would be done by operational insurance the responsible department

00:22:32 so for 633 it's you correct and is it correct that there are different teams within the operational policy department to take responsibility for different subject areas yes can you

00:22:43 for different subject areas yes can you give us an idea as to how the team is divided across those various subject areas

00:22:49 areas i can certainly give you an idea for how it was when i was unconscious it's changed more recently please do just con if you i'm only going to ask you to speak to matters when you were i understand i just don't want to

00:23:00 were i understand i just don't want to mislead the inquiry about where we are now

00:23:03 now uh so when i was there it was there was a fire team who dealt with

00:23:10 with anything relating obviously to fires both in buildings and not

00:23:15 not there was what was called an operational support team that was all the support appliances like hose land units i think they dealt with aerials

00:23:28 i think they dealt with aerials bulk foam units appliances like that so that was more appliance based and incident based there was a rescue team who dealt with

00:23:39 was a rescue team who dealt with urban search and rescue and the functions performed by fire rescue units they also dealt with international search and rescue which is a

00:23:50 a a version of urban search and rescue but when when there's an international deployment and then there was a hazardous materials team

00:24:00 team who dealt with incidents involving chemicals biological risks uh chemical sorry radiological and nuclear so cnbr cbrn cbrn

00:24:12 cbrn cbrn um fire team would they have been no sorry not cbrn so cbrn was treated as a terrorist issue so that would sit with operational resilience thank you we would advise on

00:24:24 resilience thank you we would advise on the technical side of the hazmat element but it's it's because it's a deliberate act it was it was counted as being a terrorist issue fire team would that team have

00:24:35 fire team would that team have responsibility for 633 yes now you

00:24:40 now you referred to an earlier answer there to advice and support you give to other departments so for example if operational assurance sought your advice in relation to a policy which affected instant command

00:24:52 instant command you'd have the expertise to be able to assist is that a fair summary

00:24:58 uh i mean it would be very context specific and dependent so i i think i'd need to know in what i was just asking a general term question mr carr

00:25:09 question mr carr in in general terms we were a big team you know we were little teams but we were a big team so of course we would assist each other but whether we had you asked me whether we had the expertise to do that that

00:25:22 we had the expertise to do that that that would depend on on the topic and the issue at what degree of oversight of the drafting process so i'm thinking of policies that fell squarely within your

00:25:34 policies that fell squarely within your directorate's responsibility did you have as the head of operational policy

00:25:41 uh so the oversight worked at a number of different levels pardon me so the the drafting work was generally carried

00:25:52 the drafting work was generally carried out by someone at station manager level or

00:25:56 or assistant division officer level if you're in that rank structure the media oversight was provided by a group manager or division officer but sometimes

00:26:08 sometimes they would also do the drafting the next level of scrutiny and support was at dac level and then myself i

00:26:20 and then myself i generally

00:26:21 generally i don't think there's a policy that was produced when i was there that i didn't at least look at did i always scrutinize them line by line

00:26:32 line by line no

00:26:34 no and would the depth or degree of scrutiny depend upon the complexity of the subject matter or its sensitivity or frankly if it considered matters which had been vexed to deal with previously

00:26:46 vexed to deal with previously i think it would all of those things and more so if for example it was an amendment rather than a

00:26:53 a new policy and then i would probably give that a very light touch because i trusted my staff i had a good team and you know i was confident that they would do their job and in particular i would

00:27:06 do their job and in particular i would look to the dic to to assure me that the document was where it should be thank you

00:27:13 thank you now going back to the uh flowchart if we can the fourth column reading from the left

00:27:18 left is entitled stakeholder consultation now that appears to set out a number of different forms of consultation and could we go through them briefly uh together the first is peer group review

00:27:31 together the first is peer group review and it said that this quotes may include end user as a key stakeholder and involve procedural testing arrangements such as operational exercises and use of the operational sounding board

00:27:43 the operational sounding board for these purposes who are the end users so

00:27:48 so the end users and operational policy are firefighters and on spy stations and and officers that either perform incident command or or sector roles

00:27:59 incident command or or sector roles thank you so it's part of this stage of consultation what you're essentially seeking to establish is how the proposed policy would work in practice is that

00:28:10 practice is that a fair general description

00:28:14 very much so uh the the list of possible options there uh i think it it'd be useful for the inquiry to appreciate that they were suggested ways of achieving

00:28:26 they were suggested ways of achieving that outcome so so i wouldn't expect every policy to be subject to an operational exercise so that's what i was going to ask you next about operational exercises um when would they be considered most appropriate for

00:28:39 be considered most appropriate for testing a policy as it were from my perspective it was when you were doing something where you really wanted to be sure it was practicable so we did it for high rise for example

00:28:50 so we did it for high rise for example that's always about to ask you that's a paradigm of a policy that would be subject to an operational exercise absolutely

00:28:59 who's responsible for deciding whether an operational exercise is the the appropriate mode of consultation

00:29:08 that would be the judgment between the policy offer and and the group manager and possibly the dac and possibly me if

00:29:18 if if they felt they needed to bring it to my attention if for example it was about resources getting the remainder of the organisation to commit to it i i might be able to facilitate that for them they

00:29:31 be able to facilitate that for them they need it when they needed heft possibly

00:29:35 possibly um who is responsible for designing the operational exercises but i only did it for a few policies and and the way i

00:29:44 the way i the way i did it was by identifying an event that was already scheduled so in the case of high-rise somewhat ironically then the same names

00:29:55 somewhat ironically then the same names keep coming up andy rowe he was a station manager at southwark fire station and i knew him very well because i'd known him from when he joined i knew that he was organizing quite

00:30:06 i knew that he was organizing quite significant high-rise exercise so i approached him and said

00:30:11 and said there's a new version of and this was i think uh

00:30:16 uh the version of 633 that was published in 2011 just so we're clear and i said it would be really helpful because it's got new

00:30:27 because it's got new content regarding evacuation fire survival guidance and so forth it would be really helpful if we

00:30:34 if we were to trial it in a practical setting and would you mind us using your exercise as a vehicle for that and he was really happy to do that

00:30:45 and he was really happy to do that as the

00:30:46 as the exercise director and so that's how that one played out um for the purposes of the 2015 version of 633 did you design the operational exercise for that policy

00:30:57 exercise for that policy i'm

00:30:58 i'm pretty sure it wasn't subject to one

00:31:03 so i may well be i'd misunderstood you yeah because i think the exercise we used was for the 2008 what became the 2011 edition because i think that exercise was held

00:31:14 because i think that exercise was held in around about june 2011 if i'm correct and so the just for the avoidance of doubt no exercises carried out for the 2015 iteration of the policy

00:31:25 out for the 2015 iteration of the policy not to my knowledge although there were regular high-rise exercises would pat or and or jimmy call have

00:31:35 have done it and i possibly wasn't aware they they could have done i i wouldn't rule it out but i wasn't aware of it but the question might be better directed towards mr rutting tomorrow maybe as a confirmation for sure yeah

00:31:46 confirmation for sure yeah now the second form of consultation set out in this particular column is training impact assessment and the text here

00:31:55 states complete required sections of tcap

00:31:58 tcap and forward to training professional development tmpd for review and comment now

00:32:06 now we've heard evidence in module 5 from peter groves about the the tcap process itself but just to recap in broad terms it's the full request process for

00:32:17 it's the full request process for training

00:32:18 training submitted by the petitioning department to the training department is that right correct and i think in the context it's written here that training and professional

00:32:29 that training and professional development department was an lfb department so this is prior to it going to babcock this is to make sure that in process terms

00:32:40 process terms the form has been completed correctly and also in this context that request would be a need for training that had been identified by the operational policy department yes in the context of 633 for the as a

00:32:53 yes in the context of 633 for the as a result of the creation or an amendment to an existing policy absolutely in other words where the work carried out by the or your department on a new policy had identified either a new training need or

00:33:05 identified either a new training need or as a new policy or a new one as a result of an amendment that would be done by the operational policy department making a formal request by completing the tcap form yes

00:33:16 form yes and that tcap request is then the beginning of a i think the euphemism was continuing dialogue

00:33:22 dialogue between the operational policy department as the commissioning entity and

00:33:28 and the training department itself that's correct it would also normally involve service delivery or fire stations the dave brown's

00:33:39 fire stations the dave brown's department so we we tended to get them involved at an early stage because they were going to be the people responsible for delivery it might also involve other departments if there was a

00:33:52 involve other departments if there was a good reason for them to be involved now

00:33:55 now um who within the operational policy department would be responsible for completing the tcap form when it fell to your department to be the commissioning function

00:34:05 function general leader policy author

00:34:09 is it fair say that rarely if ever would it lie to you to initiate the tcap request form process i i don't think i ever initiated a tcap

00:34:25 can you give the panel an idea maybe use from the context of 633 to give it a specific uh context what would be your involvement um in the process of developing the necessary training with

00:34:37 developing the necessary training with the training department i i didn't have any direct role at all other than in a in a general sense i

00:34:48 other than in a in a general sense i i used to meet with peter groves periodically and without getting into the detail of any particular commission we would review all of the commissions

00:35:01 we would review all of the commissions that my department had initiated with a particular emphasis on any that were showing either amber or particularly red to see what the problem was

00:35:12 to see what the problem was and to see whether there was anything that we could do or that i could do to unblock uh any problems amber or red being the traffic light indicating yes

00:35:25 indicating yes just let me finish this question with indicating delay and implementation of training is that right no indicating a delay in the development of the training in other words the tcap

00:35:38 of the training in other words the tcap process itself

00:35:44 going back to the flow chart the third form of consultation here is ceo's impact a statement um first of all who are ceos

00:35:58 that's a really good question and and i'll be honest i think that may be an addition that was made after i retired because i i right now i can't remember

00:36:11 um moving on

00:36:14 moving on below that there's formal heads of service ac consultation it's the final sub-heading i'm looking at now at this stage the drop policy is at the stage where it's sent to heads of service is that right as its title

00:36:27 service is that right as its title indicates

00:36:28 indicates that's correct and that that when i was there that used to go out in my name

00:36:33 my name via my

00:36:35 via my personal assistant used to send that out and there was a standardized set of texts that went with it

00:36:41 it to

00:36:42 to invite people to comment and to explain how we would like the feedback to be provided when you were one of the consultees for this process ahead of service

00:36:52 service would you essentially receive the request then staff it down to whoever knew most about it generally yes

00:37:00 looking at the fifth column that's entitled representative body consultation um am i right in understanding that is consultation

00:37:11 consultation uh with whoever the the lfb is required to consult so primarily trade unions presumably

00:37:19 yes the representative bodies is the trade unions yeah primarily

00:37:25 primarily uh

00:37:27 uh fire brigade union and the fire officers association but also the

00:37:34 frs staff trade unions unison and gmb were also represented and in some cases had a legitimate interest in an operational policy because some of the

00:37:47 operational policy because some of the policies

00:37:48 policies affected their members but it was mainly the fbu

00:37:56 and the final but sixth column is entitled delivery and that involves essentially further communications with the training department to agree training options is that a fair summary

00:38:09 training options is that a fair summary yes that was pretty much the final stage was how is this training actually going to be delivered and part of that presumably would involve final communication to the subjects of that training

00:38:22 the subjects of that training yes i think that was the next stage the delivery and communication strategy that's why i said this is what it involves here yes absolutely thank you can we now having dealt with the structure turn to the review of 633

00:38:35 the structure turn to the review of 633 itself

00:38:37 itself now um you explain and if we can go to it's probably easier your third witness statement which can be found at lfb double zero double one nine eight four nine

00:38:48 four nine forward slash eight to four

00:38:57 and if we could look at paragraph 188 of that statement which is the bottom of the page

00:39:02 the page you said this as the consultation periods for dura 3.2 were largely completed in 2012 and 2013 work commenced on updating pn 633

00:39:14 work commenced on updating pn 633 to reflect the new hazards identified in the gra 3.2 i asked pat hutting to take the lead on this and for the early stages of this work he was assisted in this work by

00:39:25 work he was assisted in this work by phil

00:39:26 phil morton now it's that particular period of review i'd like to discuss with you this afternoon now you've exhibited to your statement an email that you sent to

00:39:37 your statement an email that you sent to james a court on the 15th of january 2013. and could we go to that it's at lfb trouble zero eight five three one three

00:39:56 and if that could be expanded

00:40:02 uh jim further to our recent discussion please find attached the final draft of the new high-rise national generic risk assessment gra this document has recently been sent to

00:40:13 this document has recently been sent to the gra program manager and it will be passed to clg for typesetting in due course this may result in some formatting changes but will not change the content of this document

00:40:25 the content of this document as previously discussed and agreed i would like you to coordinate a review and amendment of lfbs pn633 to ensure that it is consistent with the attached gra

00:40:37 attached gra mentioned earlier this work would normally fall to the fire team but i've asked you to do it in order to balance workloads and to promote greater team integration and cross-working

00:40:48 integration and cross-working i would also ask that this review has regard to identify any issues and lessons learned from the lachnlin quest which you will know has just started and is due to run until march

00:40:59 is due to run until march station manager morton and myself as gra authors have tried to ensure that the issues arising from this incident as these were understood prior to the inquest have been incorporated into this

00:41:10 inquest have been incorporated into this gra

00:41:12 gra but you will appreciate the need to check that nothing new or different arises during the inquest itself which would have a bearing on lfb's approach to what we do when tackling fires in a

00:41:23 to what we do when tackling fires in a high-rise building i would anticipate that the time scales for this work and the inquest will be roughly aligned the lfb high-rise risk assessment will also need to be updated and a tcap

00:41:35 also need to be updated and a tcap drafted to ensure the changes are properly reflected in training if anything is unclear please don't hesitate to ask and just looking at that draft when

00:41:46 and just looking at that draft when we're talking about how you allocated uh policy work internally um it felt 633 fell to the fire team was mr acor part of the fire team or not and no

00:41:58 acor part of the fire team or not and no he wasn't he his lead was incident communications and i when you asked me earlier for the breakdown of teams i

00:42:09 breakdown of teams i i forgot to mention him but that's because

00:42:12 because he originally sat with danny cotton in her

00:42:16 her department and then at some point and i can't remember when he came across to operational policy did he have a particular expertise or experience

00:42:27 expertise or experience of fighting fires in high-rise buildings was that's why you chose him uh he was a very he's a very experienced fire officer as was pat hutton

00:42:38 fire officer as was pat hutton he'd also

00:42:41 he was also part of the ops review team so he'd attended a very large number of incidents so between him and patent yes i would say

00:42:52 between him and patent yes i would say they were both had relevant experience and knowledge were those the particular reasons why you picked these two offices

00:43:05 yeah in large part i would say so yeah because clearly fighting fires in high rise buildings was a subject of interest and sensitivity

00:43:16 interest and sensitivity presumably that informed the choice of the individuals you made who are going to lead the work on revising 633 is that a fair assumption to make it is

00:43:26 it is and

00:43:28 and because i knew pat hutton would be the person holding the pen

00:43:33 the pen i was always quite impressed with his work he was a very competent station manager very experienced station manager i also wanted

00:43:44 i also wanted phil morton involved knowing that he was about to leave the department but i wanted to provide a degree of continuity between what we've done

00:43:54 done or what we had done in the gra to make sure that was carried across into lfb's policy thank you and so essentially you were content you had a trinity of safe pairs of hands there

00:44:08 trinity of safe pairs of hands there not quite sure i'd have described them as a trinity but they were safe and effective thank you now we've already seen that in relation to the review of gra 3.2 that a number

00:44:19 to the review of gra 3.2 that a number of amendments were made to the draft after your email to james a court in january 2013 and we looked at those yesterday

00:44:26 yesterday in relation to the review of 633 though was your intention that mr acort would keep abreast of developments in the drafting of 3.2 it would ensure that

00:44:37 drafting of 3.2 it would ensure that those were incorporated within 633 that was going to be his responsibility yes it was and my recollection is that as and when i received

00:44:49 any new any versions any new versions on new drafts that i shared them with him and i think you've seen him copied into some of those emails and and indeed i think i shared him with pat hutton as

00:45:00 think i shared him with pat hutton as well

00:45:00 well and

00:45:02 and essentially there were two uh streams of work which mr acort had to be alive to one gra 3.2 but also what may come out of the latino inquest when they

00:45:13 come out of the latino inquest when they were completed that that's true in a technical sense but in practical terms my view at this time was that nearly all of the work had been done

00:45:25 of the work had been done gra 3.2 i was blissfully unaware of clg's

00:45:30 clg's darkest faults but beyond that i i didn't actually think this was going to involve

00:45:36 involve too much work if i'm honest because the gia was written in a way you know one of the very criticisms of it was it was too procedural so it's not unreasonable to say it was going to fit

00:45:48 unreasonable to say it was going to fit fairly well into the lfb template so it's capable of being translated into operational policy without too much difficulty that was my view very much so um could we now go to

00:46:01 view very much so um could we now go to an email from uh mr acor to patra gutting sent on the second of april uh 2013 into which you were copied it can be found at lfb trouble zero eight

00:46:12 be found at lfb trouble zero eight double six seven

00:46:16 thank you and if we could look at the second email from the top which was sent by mr acourt on 9

00:46:23 9 37 thank you and in that he says this pat i've had a quick word with peter cowep with reference the high-rise gra and the lfb policy

00:46:34 gra and the lfb policy it's something that we will lead on for ops procedures and peter is likely to talk to you next week on your return from leave about it in my absence that is as i won't be back until wednesday the 10th could you do

00:46:46 until wednesday the 10th could you do some preliminary work on this and i and involved dave too as he has carried out much of the assessment in terms of policy gaps based on national gras i'm sure peter is able to put the

00:46:58 sure peter is able to put the requirements across more eloquently than i have in this slightly rushed email you then reply in the top email of this thread saying this noted banks pat can you put a 30-minute

00:47:10 noted banks pat can you put a 30-minute slot in our diaries for next week and invite dave along as well i would also like phil m there so that's philip morton

00:47:18 morton to be there as he's done a lot of the work on this gra peter now it appears that a meeting was then scheduled for the 10th of april 2013 and if we go to lfb

00:47:31 2013 and if we go to lfb trouble zero eight double six seven six

00:47:37 that could be expanded

00:47:42 that's entitled lachnal verdicts and a meeting of the recipients of all the directed addresses following your email

00:47:54 addresses following your email yes

00:47:55 yes and its purpose to discuss latino outcomes with reference to high-rise gra and lfb policy um again with apologies for asking a question about a meeting that took place eight years ago but can you remember if

00:48:06 eight years ago but can you remember if that meeting took place i'm afraid not not with absolute certainty what i would say looking at the title

00:48:17 what i would say looking at the title yes and also looking at the attendees and particularly drawbridge that that this may have been more focused on

00:48:28 more focused on was there anything new coming out of the inquest the formal findings of the inquest rather than talking about 633 development more generally

00:48:39 generally so it wouldn't have been the meeting for example when you instructed mr utting for example to carry to carry out the work on 633 looking at the title i

00:48:50 looking at the title i i can't say for sure but the title tells me it was probably more about the substantive issues coming out of the lack of inquest can you remember now

00:49:03 can you remember now uh specifically what you asked patrick gotting to do in relation to a review of 633

00:49:09 633 yes i

00:49:11 yes i i think in brutal terms i asked him to i think we spoke about a gap analysis and then

00:49:20 and then i think what i said to him was that i foresaw this as a relatively straightforward task of bringing across the relevant elements of the gra

00:49:31 elements of the gra into lfb policy recognising that there are sections of that gra for example relating to training and competence which would not form part of an operational policy but that aside

00:49:44 an operational policy but that aside the sections that did fall in part i felt were

00:49:50 largely almost a cut and paste in into lfp policy but there are exceptions because it was written generically for fire services nationally

00:50:02 for fire services nationally so where there was an lfb specific i would obviously expect pat or jim or whoever was going to do the writing to pick up on that and and to put in the lfp specific

00:50:15 put in the lfp specific elements

00:50:16 elements so it's slightly more than a cut and paste job but not substantively more for example it wasn't a root and branch review of high-rise firefighting policy and procedure correct

00:50:28 can you remember uh given the distance of time whether you specifically instructed mr utting to review the rule 43 letter that had been addressed the lfb arising out of latino

00:50:42 i don't recall specifically instructing him to review it but as as has already been shown in the documents we've seen just now i made it clear that we had to make sure there was alignment between what was

00:50:54 there was alignment between what was coming out of the lachenal inquest and and what we were going to put in our policy beyond that general instruction did you deal with or did you give mr

00:51:05 did you deal with or did you give mr utting a particular instruction for example to examine the coroner's recommendation that incident commanders be trained to anticipate that a farm may behave in a

00:51:16 anticipate that a farm may behave in a manner inconsistent with the compartmentation principle no can you help us as to why not given that had been a obviously a source of some discussion and controversy at the inquest

00:51:34 because i've i guess i i'm i'm reflecting on it now i i just felt that he would have my expectation is that he would look at the verdict and look at the document and

00:51:46 the verdict and look at the document and bring across what was relevant from it and i accept given the discussion we've had in the last two days that and i've already accepted that was an omission and i

00:51:57 accepted that was an omission and i think that carried through into my briefing so to answer your question my briefing to him could and should have been probably a little bit more specific thank you

00:52:08 thank you could i ask for your help to resolve a an inconsistency or an apparent inconsistency in the evidence in relation to the lachnal recommendations mr utting has said in his witness

00:52:20 mr utting has said in his witness statement

00:52:21 statement we don't need to go to it but the reference is lfb double zero double one eight nine one eight forward slash sixteen

00:52:30 sixteen paragraph 62 that he was not responsible for reviewing policy 633 following the inquests

00:52:38 inquests now that jars with the evidence that you've given that

00:52:43 that that is precisely what mr utting was tasked to do can you help us or help the panel resolve that particular tension

00:52:57 i can only think i mean i i've i've not really picked up on that before so i haven't had a chance to would you like to look at the extract from mr hutting's station might be helpful just to see the context of it of course

00:53:08 context of it of course i apologize this is um the document manager will be bringing that up now with apologies to him

00:53:23 it's paragraph 62.

00:53:28 quite a stark statement there

00:53:34 if it helps the inquiry my my first faults and i haven't discussed this with pat obviously and i haven't had a chance to really consider it in detail but i suspect what that may relate to is

00:53:46 i suspect what that may relate to is that pat

00:53:48 that pat would have probably known from talking to me and talking to phil morton that the vast majority of the changes associated with lacking had been made to

00:53:59 associated with lacking had been made to the november 2011 document and that

00:54:04 and that statement may reflect that

00:54:09 i understanding accept that's not what he's saying but you've asked me to i i offer a review and that's the best i can offer at this moment in time

00:54:20 moment in time i think

00:54:21 i think pat would

00:54:22 pat would be better place to explain explain that or expand him on it if you need him to i'm grateful thank you i invited you to assist us and you have done so don't worry without pondering it further and if i do and i

00:54:34 pondering it further and if i do and i think of something different i'll let you know but that that would be my interpretation of what that might mean i'm grateful could we stay with mr utting's statement go back to page 14 and paragraph 55.

00:54:50 the question was who supervised you in relation to this this being the work on revising 633 and he says this i was supervised by gm

00:55:01 supervised by gm jim a court dac kevin hughes and ac peter cowab would you agree that he was supervised by jim acord first of all yes was he supervised by dac hughes

00:55:15 to a lesser degree in terms of granularity and day-to-day contact but yes he in terms of his line management chain he's this i would say that answer is a

00:55:27 he's this i would say that answer is a a better description of his line management chain in terms of supervision by which i would mean day-to-day management support that was very much jim o'cool

00:55:39 that was very much jim o'cool probably to a lesser extent kevin hughes but equally i i always had a kind of open door policy and and i was always very happy to speak to people so

00:55:50 to people so it's quite probable in fact i'm pretty sure we did have face-to-face conversations so to that extent

00:55:57 extent you know i'm quite happy to be seen as this supervisor but i the direct supervision was carried out below me and for these purposes we should not the panel should not read

00:56:08 panel should not read that degree of supervision as being synonymous with the fact that you were directly involved in the preparation the revision of 633 correct

00:56:18 can we now turn to a new topic which is the gap analysis that mr utting carried out okay

00:56:25 out okay now he carried out that analysis um or he says he created it to carry that out to um

00:56:32 to um identify

00:56:34 identify and to assist his review of 633 to identify gaps that needed filling and if we could look and stay on his statement and look at paragraph 54 so it's on this page but the sixth

00:56:46 54 so it's on this page but the sixth line down from the top

00:56:50 and it starts with

00:56:53 with gra 3.2 is divided

00:56:58 do you have it six lines down sentence starts on the right hand side yes indeed thank you so it's a long paragraph

00:57:06 paragraph gra 3.2 is divided into two sections section one providing a narrative and section 2 a tabular risk assessment in conducting the review of pn 633

00:57:19 in conducting the review of pn 633 we referred to the risk assessment in section 2 of gra 3.2 and the list of hazards

00:57:25 hazards the risk assessment in gra 3.2 had been the subject of scrutiny and national consultation and we felt it was a good risk assessment to work from as a starting point when identifying the

00:57:36 starting point when identifying the hazards presented in high-rise firefighting we undertook a gap analysis between the risk assessment in section 2 of gra 3.2 and the version of 633 extant at the

00:57:49 and the version of 633 extant at the time of the review we cross referenced the gra 3.2 risk assessment at section 2 with the then current pn 633 to check that every hazard

00:58:00 to check that every hazard that was in the risk assessment was also in pm 633

00:58:04 in pm 633 where we identified hazards and therefore risks and control measures that were not in pn633 we added these to the draft we were working on

00:58:15 the draft we were working on now just before i go further the wii that mr utting adopts there is a reference it would appear to phil morton with whom

00:58:25 with whom he was working at least at this stage in the process does that sound right that's absolutely the case and as i said earlier i'd ask phil

00:58:34 phil to work with pat in the early stages to provide that continuity and and to ensure a free flow of information thank you could we now go to your third witness statement um

00:58:46 witness statement um sorry before we do yes of course could i just sort the inquiries benefit because i just clarify that what you've got in section two of the gra is not a risk assessment and the

00:58:59 the gra is not a risk assessment and the reason for that is it's not scored so the difference there is it's impossible nationally to assess the risk unless you know which of those control measures will be

00:59:10 of those control measures will be applied

00:59:11 applied so so the matrix was very much an assistance but it wasn't a risk assessment and i mentioned that because a lot of people

00:59:19 people were forever confused about that and

00:59:23 and you know so when pat says it it it was a risk assessment he's right it was a restatement i think is a better way to describe it a valid distinction to draw thank you can we go to your third witness statement though yes lfb

00:59:36 statement though yes lfb double zero double one nine eight four nine forward slash nine two

00:59:43 two and paragraph two zero seven thank you looking at the first sentence of that paragraph mr cow to help ensure that consistency was achieved i requested that a gap analysis

00:59:54 achieved i requested that a gap analysis be undertaken between gra 3.2 and the version of pn633 that was current at the time

01:00:03 now bearing in mind that do you think the gap analysis that you say you requested be undertaken is the same analysis that mr utting carried out i would assume so yes now in his second witness statement to

01:00:15 now in his second witness statement to the inquiry mr utting confirmed that this gap analysis that he carried out was recorded in a document which he's provided to the inquiry um mr artin confirmed in a second witness statement

01:00:26 confirmed in a second witness statement that the gap analysis document was last edited by him in may 2013 and if we could look at that analysis please and it can be found at

01:00:37 analysis please and it can be found at lfb double zero one two double one seven four

01:00:47 if that could be expanded slightly

01:00:52 mr calp is that document familiar to you

01:00:58 uh i

01:01:00 i i think it's fair to say i probably had sight of it i i'm certainly not familiar with it in detail because i i didn't play any part in this work it wasn't something that you needed to

01:01:11 it wasn't something that you needed to apply your mind to in any detail is that no as i've said already i had complete trust in pattern fill

01:01:21 if this is the gap analysis that was produced in may 2013. would it not also be the case that the gap analysis could not have captured the significant amendments made to

01:01:32 amendments made to the evacuation and state put elements that were introduced as a result of

01:01:36 result of clg's interventions into gra 3.2 that's a fair observation

01:01:44 and indeed the gap analysis must by definition proceed upon an earlier draft of gra 3.2 indeed

01:01:51 indeed now can we look at some of the points that mr utting makes in his analysis and be grateful for your assistance on those uh could we go to page three first of all which is the section that considers planning

01:02:07 now on page 3 we see the same reference to consistency plans towards the bottom of the page which reads as we've seen in the various iterations

01:02:19 as we've seen in the various iterations of the drafts of 3.2 contingency plans should include a range of events which are foreseeable for the particular premises including fire spread beyond the compartment of origin

01:02:31 spread beyond the compartment of origin and the potential for multiple rescues

01:02:38 now we know

01:02:40 we know from the documents which have charted the drafting process of 3.2 which we've been through that clg expanded this particular text and if we could keep this on the page but also put alongside

01:02:51 this on the page but also put alongside it

01:02:52 it lfb

01:02:53 lfb quadruple zero one two double five forward slash nineteen

01:03:18 on the right hand side as we looked at earlier this morning we can see the second bullet point from the top so there's an operational plan being required in the event the state policy becomes untenable

01:03:30 becomes untenable i'm making no criticism mr cap but just asking for your confirmation that second bullet point which is in the draft

01:03:39 draft not in the gap analysis totally accept that do you think the likely explanation for the absence of that second bullet point in the gap analysis is that the gap

01:03:51 in the gap analysis is that the gap analysis was not updated after clg's amendments were made and after gra 3.2 was finally published in february 2014. is this the only version of the gap

01:04:03 is this the only version of the gap analysis that you've yes that's our understanding and also we have mr utting's evidence as i indicated slightly earlier on that the last time this was amended was in may 2013.

01:04:17 this was amended was in may 2013. that's a fair conclusion to draw them you can't think of any other explanation that's the reason i put it to you

01:04:26 it could be

01:04:30 that pat felt

01:04:33 pat felt that because the number of changes post this point i post

01:04:40 i post may

01:04:43 12 now sorry may 13 13. because i think when he did this gap analysis

01:04:51 analysis phil and myself would have shared with him our relative confidence that we were looking at what was probably close to a final version

01:05:02 final version it may be that the subsequent changes that were made by clg in the way that we've discussed extensively before he he chose to bring them into the

01:05:13 he he chose to bring them into the policy or or not without updating his gap analysis that that's possible something we can investigate with mr but there's no reason that you can definitively speak to as to why

01:05:26 definitively speak to as to why the second bullet point as i said on the right hand side is not in the gap analysis no thank you now there are two other references in the published version of jra 3.2 that don't appear to have been picked up in

01:05:37 don't appear to have been picked up in the gap analysis and i'd be grateful for your assistance in relation to those two points

01:05:43 points could we keep both documents alongside each other for the moment in relation to the right hand side document could we go to page 21 which hopefully is the competence and

01:05:54 which hopefully is the competence and training

01:05:55 training section of the document

01:06:00 and we've looked at this previously and we see the final subheading

01:06:06 on that page just above the three bullet points says this training which will cover highrise instance must include and then if we go over the page

01:06:16 we see the fourth bullet point from the bottom of that list evacuation and casualty removal tactics incident commanders should understand when a full whether partial or full

01:06:27 when a full whether partial or full evacuation strategy might become necessary in a residential building where a state policy is normally in place

01:06:35 place now

01:06:37 if we can look at the gap analysis but go to page four of it

01:06:47 and the middle paragraph in particular and look at the second sentence

01:06:55 which starts fire and rescue services should consider both generic techniques for persons told to stay put as well as bespoke arrangements for specific buildings where this is appropriate

01:07:07 would you be able to confirm for us that there's no reference there to the need for instant commanders to be able to understand when a partial or full evacuation strategy might become necessary in a residential building

01:07:19 necessary in a residential building where stay put is normally in place i can and i guess the same explanation applies in terms of the mismatching timing between these two documents insofar as you're able to speak to that

01:07:31 insofar as you're able to speak to that point

01:07:32 point insofar as i'm able to speak to it and you know recognizing that i was not involved in the detail of the left-hand side of the work thank you um with apologies to the

01:07:44 thank you um with apologies to the document manager looking at gra on the right hand side could we go to page 18

01:07:54 and that sets out from the top of the page information to be gathered in relation to high-rise incidents and the 10th bullet point on that list

01:08:06 and the 10th bullet point on that list reads building construction features such as the presence and location of maisonet style construction sandwich panels timber framing cladding systems

01:08:17 panels timber framing cladding systems would you agree that that also was not included in patrick gutting's gap analysis

01:08:22 analysis you can take it from me there's no reference to cladding systems there at all

01:08:26 all i would fully accept that can i add please do a comment which may help the inquiry so as you can see in the gr

01:08:38 so as you can see in the gr the

01:08:39 the various features that we suggested people should look out for were described in terms of such as so so they were exemplars it was not a definitive list

01:08:52 there's always a question when you're transposing national guidance into local policy

01:08:59 of the need for conciseness and it's possible that

01:09:05 that pat utten quite unwittingly dropped

01:09:09 dropped several of the exemplars when he was writing 633 without probably appreciating particularly in the context of the tragic events at

01:09:21 the context of the tragic events at grenfell

01:09:22 grenfell what that would come to signify but at the time he did it and i think this is very important to emphasize

01:09:31 emphasize he would not have been aware of the hazard

01:09:35 hazard the flammable hazard posed by cladding mr calp

01:09:40 mr calp is that speculation on your part or do you have some sound basis i'm very confident that pat hutting wouldn't have understood the cladding hazard that's not the question

01:09:51 cladding hazard that's not the question but as to whether what i've offered as a possibility i'm i'm trying to help but if if that's not helpful i'll draw the comment well my question is are you speculating or do you have some basis in

01:10:02 speculating or do you have some basis in fact for putting that before the panel that's my understanding that's my speculation yeah i accept its speculation thank you

01:10:16 do you have direct knowledge as to why the reference to cladding systems was dropped from was not included rather in pn 633 by that i mean you can

01:10:28 by that i mean you can give a direct account as to why cladding systems were not referred to in 633 i'm not able to do that

01:10:45 now in relation to cladding um you dealt with this in pc6 and if we could go to pc6 which is a lfb

01:10:54 is a lfb treble zero 327 three four slash two three

01:11:02 thank you and if we could look at paragraphs three point seven point seven and point seven eight at top of the page and you say this cladding was included within planning

01:11:14 cladding was included within planning because as an outer layer on one or more faces of a high-rise building it was understood that the use of this material would create a void which had the potential to promote an abnormal degree

01:11:26 potential to promote an abnormal degree of external spread of fire or smoke 3.78

01:11:30 3.78 as such cladding was noted alongside timber framing surface mounted trunking and voids as an example of a building construction feature that should be recorded within

01:11:41 feature that should be recorded within the information to be gathered by frs in relation to high-rise incidents however at the time gra 3.2 was produced this should not be interpreted to mean

01:11:52 this should not be interpreted to mean that cladding itself was understood as presenting a significant fire hazard and the rationale for this is explained below

01:12:00 below now it's not clear from this whether you're saying that it was a an informed conscious decision not to include any reference to cladding in three 633 which you took the view that

01:12:11 three 633 which you took the view that was no evidence that presented a fire risk

01:12:14 risk or whether it simply did not occur to the policy authors to include reference to cladding notwithstanding is expressly referred to in gra 3.2 which

01:12:26 which of those two

01:12:29 explanations accords with your recollection i i certainly wasn't i wasn't involved in any discussion of that issue with pat hutton

01:12:41 discussion of that issue with pat hutton so any response i provide would will probably be speculative and therefore i don't suspect you'll need me to say it i i wouldn't want to invite you to speculate um so i certainly

01:12:52 you to speculate um so i certainly didn't discuss it with him obviously what i've written here is with the benefit of hindsight that you're not aware of any discussions at the time 633

01:13:03 aware of any discussions at the time 633 was being reviewed as to whether the reference to cladding system should be retained or removed from 633 absolutely not

01:13:15 were you familiar with the local government association guide on fire safety and purpose-built blocks of flats at the time of this review

01:13:24 review no i was not could we go to an lfb0011893

01:13:42 have you seen that document before

01:13:50 possibly but i would not i would certainly wouldn't claim any familiarity with it now it's published in 2012 so it's in circulation during the time the currency of the 633

01:14:01 during the time the currency of the 633 review

01:14:02 review um

01:14:03 um that guy does refer to the risk of cladding systems on high rise buildings and if we go to page one one one

01:14:17 this isn't a section of the guide which is

01:14:20 is concerned with managing fire risk and if we could look at paragraph 72.1 and 72.2 in particular they say this under the general heading external fire spread

01:14:32 general heading external fire spread 72.1

01:14:34 72.1 the external facades of blocks of flats should not provide potential for extensive fire spread when assessing existing blocks or flats particular attention should be given to

01:14:45 particular attention should be given to any rain screen or other external cladding system that has been applied and to facades that have been replaced 72.2

01:14:54 72.2 the use of combustible cladding materials and extensive cavities can present a risk particularly in high-rise blocks

01:15:02 blocks restrictions are normally applied to the nature of such materials and in particular their surface spread of flame characteristics cavity barriers are also required in some circumstances

01:15:13 required in some circumstances assistance from specialists may be required to determine if the external surfaces of walls are satisfactory and whether there is adequate provision of cavity barriers now would you agree that

01:15:25 cavity barriers now would you agree that that text appears to anticipate the use of combustible cladding materials in the construction of high-rise buildings indeed

01:15:34 to the extent to which you can speak to this

01:15:37 this do you know whether mr a court or mr utting or d.a.c hughes were aware of the substance of the lga guide insofar as it considered external fire

01:15:49 insofar as it considered external fire spread

01:15:50 spread if they were and they never shared that or discussed that with me

01:15:59 you don't remember it at all being referred to during discussions surrounding 633 with which you with within which you were involved no

01:16:10 during the sorry if it helps the inquiry this is very much the kind of material that i would have expected regulatory fire safety colleagues to

01:16:21 fire safety colleagues to draw to our attention because as it says in the title of the document this sat

01:16:28 this sat in in their world you know they would have known about this document i'm sure and i would have expected it to come through that route to us is it fair to summarize your evidence

01:16:40 is it fair to summarize your evidence that um

01:16:41 that um you can't confirm whether you saw this document at the time but you are unaware of the the substance which i've just quoted to you i may have seen it but i i'm certainly

01:16:52 i may have seen it but i i'm certainly unaware of this level of detail going back to the meetings which you had with clg and i'm thinking about the discussions with mr britsman about what the gra 3.2 was doing the job which they

01:17:03 the gra 3.2 was doing the job which they perceived it needing to do did they ever raise your attention to issues relating to

01:17:11 to cladding and rapid external fire spread cladding absolutely not rapid external fire spread

01:17:23 rapid external fire spread which was all already in the document we may well have discussed that in the context in which it was in gra already

01:17:33 now there's um a draft completed after you'd received a response from clg added item 14 to the reference section

01:17:44 added item 14 to the reference section which was the lga guide and if we can go to lfb double zero one zero two five one three four slash three nine

01:17:58 that could be expanded so we can see item 14 at the bottom

01:18:04 can you help us as to why the reference the lga guide was included here i can only assume it was added by clg

01:18:16 clg but it's not something to want a better phrase you clocked at the time i'd i'll be honest i didn't pick up on that but then as i've already said i never saw these amended documents so

01:18:29 amended documents so i think it's possibly true to say that the first time if i had seen it i would have seen it would have been on publication and so for the avoidance of doubt uh you

01:18:40 and so for the avoidance of doubt uh you did not have regard to the lga guide when you were drafting gra 3.2 no thank you

01:18:48 you so that's probably a convenient moment yes

01:18:51 yes well at this point mr carf i think we should have a short break

01:18:56 break so we'll stop now we'll come back please at 25 to 4 and again please don't talk to anyone about your evidence while you're out of the room all right thank you very much

01:19:26 right thank you 25 to 4.

01:36:38 would you ask us to come up to come back in please thank you

01:36:49 microscope

01:36:55 all right we'll go on yes when you're ready mr kennedy thank you thank you sir mr cow um can we now turn to a report that you made for the corporate management board and if for

01:37:07 corporate management board and if for that purpose can we go back to your third witness statement where you referred to the gap analysis as carried out for the purposes of pn 633 and could we therefore go to nfb double zero double

01:37:19 therefore go to nfb double zero double one nine eight four nine forward slash nine two and the second sentence

01:37:28 okay this is the paragraph we referred to earlier on this afternoon in questioning and you say in the second sentence of paragraph 207 this the outcome of this assessment is described

01:37:39 outcome of this assessment is described in paragraph 2 of the summary section of the report to odcb and then you mentioned that report is referenced elsewhere now if we have a look at the report that

01:37:51 now if we have a look at the report that was submitted to the operational directorate's coordination board odcb you're referring here i think to a report that you prepared dated the 17th of september 2014 is that right

01:38:04 of september 2014 is that right if it's the report i believe i can't see it at the moment but let's go to lfb trouble zero two nine eight nine five

01:38:19 yes now the purpose of the report is set out in the summary section on the first page and says this on behalf of the chief fire officers association seafarer national gra

01:38:32 association seafarer national gra working group london fire brigade played a central role in reviewing the generic risk assessment gra fighting fires in high-rise buildings and this resulted in a significant

01:38:43 and this resulted in a significant amount of amendments being made to this gra

01:38:47 gra at the conclusion of this work operational procedures op undertook a comparative review of the new amended gra and the existing lfb high-rise policy and risk assessment

01:38:58 high-rise policy and risk assessment this review identified that the revised gra contained a number of new hazards and control measures which were not reflected in the lfe high-rise policy this comparison initiated amendments

01:39:10 this comparison initiated amendments being made to the lfe policy pn633 to ensure it included the content of gra 3.2

01:39:17 3.2 the new draft policy 633 has been consulted on with heads of service that has yet to be submitted to brigade joint council for health and safety at work bjc hsw

01:39:29 safety at work bjc hsw so would it be correct to say that by the time you prepared this report in september 2014 the amendments to 633 had an effect been made

01:39:41 yes yes i i seem to remember it was in in a state of kind of mature draft state and this report essentially served as an update to odcb about the new hazards

01:39:53 update to odcb about the new hazards that have been identified in the gra and the changes that have been made to the policy 633 as a result is that a fair summary it is and as it says in the next

01:40:04 summary it is and as it says in the next paragraph the key reason for bringing the report was that i felt having expanded

01:40:12 expanded our description of the risks that we needed to think about the resources that we sent in the first instance to the fire

01:40:19 fire now can we go to page two in particular the bottom of that page

01:40:27 where it says under the heading analysis of gra

01:40:32 of gra it says this a gap analysis between the national gra and the existing lfb high-rise risk assessment and policy identified the following 17 new hazards

01:40:43 identified the following 17 new hazards and this is the point you were just referring to in your answer now we're going to come on to the risk assessment shortly but can we look for the moment at least on the relevant new hazards and that we can see the third

01:40:55 hazards and that we can see the third one up from the bottom of the page is evacuation now

01:40:59 now it may well be obvious but i don't want to assume that what did you mean by evacuation in this particular context as a hazard

01:41:08 a hazard as it's described in the gra 3.2 so if you look at great and i can't remember the exact way we defined it but it would that's what it's referring to and can you explain in more detail

01:41:21 and can you explain in more detail please why is evacuation a hazard sorry i can i can totally understand how that would appear really clumsy it's not necessarily clumsy it's just

01:41:33 it's not necessarily clumsy it's just it's unpacking the complexity of the topic i think is what i'm aiming to elicit

01:41:39 elicit it's it's referring to the hazard section of the gra 3.2 and the fact that that version 3

01:41:51 version 3 brought that that issue of of evacuation and the impact that firefighting can have on evacuation and conversely the impact that evacuation can have on

01:42:03 the impact that evacuation can have on firefighting recognizing that that can can create issues and risks why is it a new hazard

01:42:13 the reason it's in inverted commas is because it's not a new hazard it's been there for a long time it hadn't been previously formally identified as a hazard

01:42:24 hazard in

01:42:25 in uh

01:42:27 uh so it's probably it probably does form part of

01:42:30 part of 2011 because 2011 policy informed the gra

01:42:37 the gra but

01:42:38 but previously it wouldn't have been recognized formally as a hazard if that makes sense no i understand

01:42:50 is it fair or should the panel read into evacuation that you're in fact here intending to uh convey the need from instant commanders to be able to carry out

01:43:00 out the evacuation of a building when stay put becomes untenable or is it not that limited it's not that limited and it because it's in the context of the

01:43:11 it because it's in the context of the hazard section it's as that is described in the gra the first when we wrote this it was a bit of a shorthand for there's some quite long uh

01:43:22 uh subheadings in the gra and we've we've very much abbreviated that and shortened it down to one word and i accept that as a result is confusing

01:43:33 a result is confusing given the understandable wish to condense material so it's digestible for particularly in these types of reports to what extent did you consider when compiling this report

01:43:44 you consider when compiling this report for odcb

01:43:46 for odcb whether you should condescend to the detail of

01:43:49 detail of the circumstances in which stay put um becoming intenable on the wider implications of that decision for training provision for incident commanders was that considered as a

01:44:01 as a precise particular issue that ought to be flagged up to odcb in this particular context

01:44:07 context no

01:44:08 no because as i've said already the the main aim of this report was to consider the predetermined attendance for high-rise fires

01:44:24 when the report was submitted were you pressed upon the nature and extent of the consequential new training needs that flowed from the new gra 3.2 and therefore the new

01:44:37 the new gra 3.2 and therefore the new 633

01:44:39 633 we certainly discussed training and as i think the police sorry as i think the report reflects that there was a decision to delay uh taking it to bjc hsw

01:44:53 uh taking it to bjc hsw and i think that was to allow the training needs to be to be assessed among other reasons so so yes odcb was

01:45:04 so so yes odcb was was a ball of considerable scrutiny so so i'm sure we would have discussed training

01:45:09 training can you help the panel as to why cladding systems are not expressly identified in this list of new hazards given that they've been highlighted in gra 3.2 well

01:45:21 gra 3.2 well to be clear they weren't highlighted in gra 3.2 as a hazard

01:45:30 is included within gra 3.2 version 3 and indeed version 2 under the planning section so it was not included specifically as a

01:45:42 included specifically as a hazard

01:45:44 hazard and you didn't think there was enough information out there to flag it up with odcb as being a hazard in our context of high-rise fires i can only repeat my previous answers

01:45:56 i can only repeat my previous answers which is and nobody regrets this more than me

01:46:00 than me that we did not recognize that material as a hazardous substance in its own right

01:46:08 right can i turn to a separate topic which is consultation and the first stage according to the flow job which is peer review now we've taken things slightly out of order because you referred to the gap analysis in your report to odcb

01:46:21 the gap analysis in your report to odcb which was in fact put together at the end of a consultation process for 633 but i'd like to go back in time little and to ask you some questions about the consultation process itself um to the

01:46:33 consultation process itself um to the extent that you're involved in that and to the extent there was substantive consultation sorry is this for 633 yeah yeah of course

01:46:42 course now we've seen on appendix through the flow chart the first stage of the consultation process was normally peer growth peer group review correct now if we can go to your pc6 report

01:46:55 now if we can go to your pc6 report which is lfb treble zero 327 83 forward slash two nine

01:47:06 and if we look at paragraph 4.5.11

01:47:13 you say that consultation this starts with a peer review within the owning department and can where appropriate include procedural testing arrangements

01:47:24 arrangements such as an operational exercise based on the draft policy this option was utilized in the course of developing pn 633

01:47:34 633 now

01:47:35 now you then go on to clarifying your third statement of paragraph 205 which can be found at lfb double zero double one nine eight four nine four nine two

01:47:50 you say this and it confirms the evidence you've given earlier on i just want to take you to the statement by way of clarification the operational cat exercise was carried out in 2011 prior to the significant review of pn 633 in

01:48:02 to the significant review of pn 633 in november 2011 which was driven by the lessons identified from the lachnal house fire in which was developed alongside the extensive process of national

01:48:13 extensive process of national consultation review for gra 3.2 and then you go on to say in paragraph 206 this

01:48:21 206 this in light of that work i determined that it would not be necessary to repeat this work again for pn633 and carry out any additional peer review or operational exercises

01:48:35 so just to establish once for all and i apologize we do go over slightly the ground we covered uh before the break but the operational exercise that was carried out in 2011 was based on the

01:48:46 was based on the version of pn633 that was in process or been reviewed at the time

01:48:53 the time it was based on the version that became published in november 2011. before the inquests into the latino house fires yes

01:49:03 yes and before any substantive work on gra 3.2 had started uh

01:49:08 uh no

01:49:09 no some work

01:49:11 some work i think there was an early draft of gra 3.2 in existence around that time probably yeah this is on early isn't it it would be very early but it would have

01:49:22 it would be very early but it would have been very reflective of all the work that we'd done for 633 so i think we would have done some of those structural changes in terms of the chronology of the

01:49:34 terms of the chronology of the information so unpacking version two and putting it into a more chronological format so i think there would have been an early draft but it would it would indeed have been a

01:49:45 but it would it would indeed have been a very early draft so it would the operation exercise would have been

01:49:52 have been conducted

01:49:54 conducted not on the basis of the final draft of 633 is that right it's got to be correct it would have been a probably a

01:50:05 probably a relative

01:50:06 relative i was talking them by the way about gra 3.2 rather than pn 633 i understand that but in terms of pn 633 given that that was published in

01:50:17 given that that was published in november the exercise was in june july well it's never it's more straightforward than that the final gra 3.2 was published in february 2014. indeed so i'm thinking about when the

01:50:29 indeed so i'm thinking about when the operational exercise was held i think it was june july of 2000 i think that's right the only i think the definite dates you give here are that the significant review was current the

01:50:40 the significant review was current the exercise was carried out in 2011 that's all you say prior to the significant review in november 2011. my point was a more simple one this sorry which i think is getting obscured that the exercise in relation to pn633 was

01:50:54 the exercise in relation to pn633 was carried out in 2011 which was obviously before

01:50:57 before the final version of gra 3.2 was published in february 2014. correct

01:51:04 now would it be fair to say that in that case it's

01:51:09 case it's unlikely that the exercise you carried out by way of peer review in 2011 covered those aspects and in particular the points included by dclg which were included in the final

01:51:21 dclg which were included in the final version of gra 3.2 which was published in february 2014. it's certainly true to say it wouldn't have included the points raised by clg

01:51:33 raised by clg i i would be less clear about whether it included the points

01:51:39 but other than that because

01:51:43 many of those were already in 633 ied version published in 2011 and therefore i think a lot of the issues certainly around

01:51:54 issues certainly around five survival guidance calls

01:51:59 failure one of the things i remember the exercise tested because again it wasn't in version two of the gra was a failure of the

01:52:06 of the rising main there was no acknowledgment in version two that you might not have a rise in main so i know they improvised an alternative way of getting the water to the fire floor

01:52:19 to the fire floor and and

01:52:20 and and moving the bridgehead i think was another thing that we did in the exercise and again that was not envisaged in version two so so some key elements were tested but i wouldn't want to

01:52:31 to mislead the inquiry to think that the exercise tested every single nuance and in innovation it didn't it tested certain agreed elements we've taken a fair degree of

01:52:43 fair degree of prospective insight to have tested against a document that hadn't yet been completed and one of the matters which i suggest you would not have been tested in 2011 was when and how incident

01:52:54 in 2011 was when and how incident commanders should carry out an evacuation of a residential high-rise building with a stay put strategy in place is that a fair observation that's a fair observation i wouldn't disagree with that

01:53:03 with that did you not consider that due to the significant changes that had been made to gra 3.2 by clg it would be a benefit to design and carry out a fresh operational exercise

01:53:14 carry out a fresh operational exercise that reflected those later changes when testing 633 i think on reflection and and certainly with hindsight i i certainly wouldn't disagree with that

01:53:27 disagree with that at

01:53:27 at the time

01:53:29 the time i

01:53:29 i i didn't

01:53:30 i didn't i didn't see that so can you give answers no can you give the panel an idea of the extent of your consideration of whether a fresh operational exercise was required

01:53:44 operational exercise was required in light of the extensive revisions of gra 3.2 particularly those revisions actioned by clg in the late stage of the process

01:53:58 i i think it's fair to say that i didn't give it any active consideration and and i can see on reflection that that was probably a mistake does the word

01:54:09 was probably a mistake does the word active add anything there can you give any consideration to it

01:54:15 i couldn't say with any certainty that i did know

01:54:21 so in terms of a process of peer review in relation to the draft policy 633 that was under review between 2013 and 2015 would it be correct to say

01:54:32 correct to say that no peer review in fact took place i don't think that is a fair assumption because my recollection is that the

01:54:43 is that the policy went to the operational sounding board

01:54:47 board and that was a very effective mechanism for peer review so that was something that i created partly as a response to the dysfunctionality of bjc hsw because

01:55:01 dysfunctionality of bjc hsw because the views of frontline firefighters in my opinion were not coming through so we set up this sounding board group which was nominated representatives from

01:55:13 which was nominated representatives from fire stations across london fire brigade and we used them to kind of road test and check the practicality

01:55:24 check the practicality of operational policy and i'm pretty certain pn 633 was subject to review by the operational sounding board can we come back to that sounding board

01:55:35 can we come back to that sounding board element of the the process you've identified there um could i before that go to an email you sent on the third of july 2013

01:55:44 july 2013 to andy rowe uh jim a court patrick gutting and philip morton which is lfb double zero double one eight nine two eight

01:56:03 now if i can look at the top email it's concerned with the head of service review of the draft policy we're going to come on to that mr cap so i don't want to deal with that just now i just want to deal with the headline

01:56:15 i just want to deal with the headline point of this top email in which you say this for your information only as i have decided that the volume and complexity of previous consultation for national gra on which the revised pn633

01:56:28 national gra on which the revised pn633 is based renders peer review a poor use of everyone's time nonetheless this remains one of the most high profile and significant policies we will promulgate this year so new and

01:56:39 will promulgate this year so new and your teams need to know it is coming now looking at the clear terms of that contemporaneous email would you now accept that no peer review process took

01:56:51 accept that no peer review process took place in relation to draft 633

01:56:59 i'd contradict my own statement in an email if i if i said anything else but subject to the review by osb which i know we're going to come on to which i would count as peer review

01:57:11 to which i would count as peer review what i meant by peer review here if i remember correctly was

01:57:16 was the review that would normally take place within ops policy so that's the review within the policy leads so they tended to look at each other's work on a peer basis

01:57:28 other's work on a peer basis and and that is what i meant in that context in that email there's no reference in this email though to the ops sounding board is there there isn't

01:57:40 there isn't but

01:57:41 but i'm

01:57:42 i'm very confident because i didn't put everything in an email that that i would have agreed with jim the call and or pat hutton that we should consult on 633 via

01:57:55 that we should consult on 633 via sounding board now

01:57:57 now this sounding board when was it set up uh

01:58:04 uh good question

01:58:08 i think it was around 2012 2013 who was on it so

01:58:18 so it was primarily firefighters frontline firefighters from fire stations i explicitly didn't want senior officers on it because they were consulted in other

01:58:30 because they were consulted in other ways senior officers being from what rank up uh station manager and above so it had no station managers or above on it it did have quite a few watch managers

01:58:42 managers quite a few crew managers and the greatest percentage was firefighters we tried to make it reasonably representative of the operational workforce how many people sat on the

01:58:54 workforce how many people sat on the board therefore in total

01:58:57 in total there was about 120 for each

01:59:02 for each consultation or for each review we would select 15 or 20 to look at a particular document or a particular project how are those 15 or 20 selected

01:59:15 project how are those 15 or 20 selected and by whom uh by

01:59:19 by so so

01:59:20 so so to take it back a step the the process by which the board was created was i wrote to the area

01:59:29 area and invited them to make nominations and i think i made it clear that i was looking for independently minded people but constructive individuals who weren't

01:59:41 but constructive individuals who weren't going to come along and just throw stones at something so therefore it was a it wasn't an open [Music]

01:59:49 [Music] process that people could apply for they were selected and that was quite uh purposeful on my part in terms of who's who selected the 15 or

02:00:00 in terms of who's who selected the 15 or 20 for each policy that would have been the

02:00:03 the uh

02:00:05 uh that would have either been the policy author

02:00:08 author or i'm just trying to think somebody was running it was tom goodall tom goodall was running the sounding board for me on a day-to-day basis so he

02:00:19 board for me on a day-to-day basis so he may well have done the selecting

02:00:24 can you remember now when uh the sounding board uh considered the draft 633

02:00:33 633 i

02:00:34 i certainly can't remember the dates but i'm confident they did look at

02:00:38 look at it can you remember now the detail or at least the gist of the response they gave no because that would have gone to tom goodall and pat hutton it wasn't fed

02:00:51 tom goodall and pat hutton it wasn't fed up to you

02:00:52 up to you i don't recall uh any any feedback i used to attend uh we used to have we used to bring them in as a group a big group and and i used to attend those meetings

02:01:03 meetings and

02:01:05 was there discussion of 633 i honestly can't remember but they were a very positive lively group so they you know they did a good job

02:01:16 they you know they did a good job can you remember whether their response caused any amendments to be made to the draft of the policy i i can't and i would suggest pat huttin

02:01:27 i i can't and i would suggest pat huttin would be well placed to answer that thank you

02:01:32 so we're coming up to five past four yes the next section that i want to come to will take half an hour or so

02:01:43 half an hour or so probably longer i'm mindful that it's been a long day already i'm also mindful that um i'm nearing the end of my prepared questions anyway

02:01:55 questions anyway what i propose there for subject to your approval is that we rise for today now

02:02:02 now i finished my examination uh tomorrow morning and i anticipate that mr cap will be released in good time before lunch tomorrow that also has the benefit of inviting

02:02:14 that also has the benefit of inviting those who've been watching to suggest any further questions they'd ask us to consider yeah for those to be ideally sent

02:02:22 sent i'd suggest before seven o'clock tonight well would we have very helpful i think wouldn't it it would be immensely helpful yes well mr carp um although council has nearly got to the

02:02:33 although council has nearly got to the end of his questions you probably know this but we we have to have a break at that point so that other people who are not here can um

02:02:43 um suggest questions that we ought to ask you so we shouldn't i think find it possible to get to the end of your evidence this evening in any event so it's not a problem i think it's best to stop early i'm very very happy to come

02:02:55 stop early i'm very very happy to come back tomorrow well that's very nice too so um i think we will break there it's a slightly early afternoon but that probably isn't completely unwelcome again i'm not complaining all right good and um we'll resume at 10 o'clock

02:03:07 and um we'll resume at 10 o'clock tomorrow please and it sounds from what uh mr kennedy has said that you can be pretty confident of getting away well before lunch the whole day tomorrow is yours well you might he might salvage some of it anyway

02:03:19 might he might salvage some of it anyway if i do that's a bonus good well thank you very much well then um apart from reminding you not to discuss your evidence with anyone after you've left the room

02:03:30 the room that's it for today and we'll see you tomorrow morning thank you very much thank you very much indeed

02:03:52 mr kenya well thank you very much we'll stop at that point um it sounds as though you will finish well within the morning yes and um that will no doubt be welcomed by mr calf anyway we'll see

02:04:04 be welcomed by mr calf anyway we'll see how we get on 10 o'clock tomorrow then thank you thank you very much

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