Mark Dixon of SD Plastering gives evidence about the internal window surround works at Grenfell Tower, including the use of Celotex and Kingspan insulation. He explains how materials were selected without specification, the lack of fire safety guidance, and reliance on others in the design chain to identify compliance issues.
00:00:09 right would you ask mr dixon to come in again please thank you
00:00:28 right mr dixon ready to carry on yes yep good thank you yes mister yes thank you just to pick up on one point from this morning's evidence um you said that when you were considering with ryden how to overcome
00:00:40 considering with ryden how to overcome the problem of the boeing that there might have been a number of scenarios i think you said there might have been half a dozen other scenarios you thought about can you help us as to what those other scenarios in general terms were
00:00:52 terms were i'm not even sure we we trialed any others in the end i think what we did was we probably thought through it logically we might have packed some plasterboard on the back or some ply packers across or all of those and i think the issue might have been we
00:01:04 and i think the issue might have been we couldn't get them under compression enough
00:01:07 enough to stay in place yeah and why the the celetex was used i see yeah that's helpful so turning on now and
00:01:14 and staying with the the story chronologically we're turning now to your quotations that you provided and the method statements um so if we can turn up ryd three zeros
00:01:25 um so if we can turn up ryd three zeros four
00:01:25 four zero six eight six
00:01:32 so we can see this is an email from you to mr marriott at ryden it's copying in simon o'connor and simon lawrence on the 6th of may 2015 and the subject is priced for
00:01:44 2015 and the subject is priced for windows surrounds and you say dear all please find attach the quotation for carrying out the windows surrounds at grenfell can i ask you to check the numbers as i'm unsure about the three bed units as we've never been in one and the drawings
00:01:56 we've never been in one and the drawings are not clear adam i know this is nowhere near your allowance
00:02:00 allowance but i've looked at this for a few hours now and believe that even our costs might be tight the team i was hoping to use wants considerably more money than i've allowed due to the risk element so i've built a team using mostly
00:02:12 so i've built a team using mostly employees
00:02:14 employees to tackle this which gives me more flexibility if we have access issues on site you see that there yes so just picking up on a few points from that paragraph um you seem to know that
00:02:27 um you seem to know that the price you're quoting here is nowhere near the allowance that ryden have allowed for and does that mean that ryden had told you how much they'd allowed for in their budget
00:02:38 budget i think we've been discussed at some point to say that we've got a budget set at this
00:02:41 at this they'll give you a an indication of where it's going because in a lot of the time if there is a case that that happens
00:02:49 happens some people just turn around saying i'm not interested in doing it i can't get anywhere near those figures we saw the process through because we was asked to so we produced the price anyway yeah and can you help us i mean you might not be
00:03:00 can you help us i mean you might not be able to remember specific figures but by how much approximately did it exceed ryden's budget was it by a significant amount
00:03:09 amount um i i think so but there's probably more to the point that i've seen documents since then that bounded a figure about between 90 and something thousand pounds was their budget and i think we was 132
00:03:21 budget and i think we was 132 right around about that figure so there was a significant difference yeah thank you that's helpful um so if we can turn to that quotation that you attached to this email this is
00:03:33 ryd3088957
00:03:39 did you put this quotation together yourself
00:03:42 yourself i do yeah and we can see on the left hand
00:03:46 hand side there's a column for description of item
00:03:49 item yep and if we look the first item is remove existing frame so does that remove the existing wooden window frame
00:04:00 i i think it was the inner frames i think if i remember rightly the windows were built up as you had an outer aluminium frame and inside of that were two other
00:04:07 two other two other windows to sit in there so you kind of dismantle the frame right so i think to my recollection that part of the frame still remained yeah it was fixed in place and that gave us something to actually fit the
00:04:19 gave us something to actually fit the ball up against against the new window frame in the old window frame yeah i see so it says there remove existing frame place plasterboard backer to gain margin so what's that bid at
00:04:32 to gain margin so what's that bid at that point in time this is uh when this was done
00:04:35 was done so this is 6th of may yeah when this was done i'm saying someone i need the flexibility just in case i've got a different scenario so i might cut pieces of plasterboard in to bridge the gap and put it on that or we may go back to
00:04:47 we may go back to the insulation so i think that just gave me the flexibility to do one or the other
00:04:51 other i see so you've written in that top box plates place plasterboard backer to gain margin and close cavity and then in in the row that's filled in below that row five you've got place
00:05:03 below that row five you've got place celatex
00:05:03 celatex insulation to reveals and should that be base of windows you should be yes yeah so are you saying that what you were proposing in this quote
00:05:12 quote was an uh was either one of those options either passed a board or celetex or are you saying that it was both no no i think it gave me the flexibility to move in and
00:05:23 flexibility to move in and out of either one of those options as it was then we didn't use the plaster build at all
00:05:28 at all and the sample the original sample never used the plasterboard and i think actually in my statement that was offered as well i it's highlighted in there that that comment there should have been taken out
00:05:40 comment there should have been taken out of the second quote yes i was going to come to that later so i understand that but but just thinking back to when you put this quote together were you contemplating that you might use plasterboard backer and
00:05:52 use plasterboard backer and some celetex insulation or a combination of both
00:05:56 of both yeah yeah yeah
00:06:02 and we can see you've put place celetex insulation there yep um what celotex insulation did you have in mind when you wrote this um it was no more than a 25 mil celetex
00:06:16 um it was no more than a 25 mil celetex it was more to do with the thickness we only had a very small margin to work with to actually be able to place something in there and it was there the celetex was there because it could be put under compression but it could also act as a support as
00:06:27 but it could also act as a support as well as giving some sort of thermal benefit as well i see yeah so was there would there have been a particular celotex product that had the right thickness that you had in mind
00:06:37 mind the 25 mil yes i think it's a tp 10 or it was it was a very basic one its criteria was nothing more than for us to have a back into the ball to stop this bowie
00:06:48 to stop this bowie yeah that's helpful and again did this quote envisage that you would be placing the plasterboard stroke celetex insulation all the way around
00:06:59 celetex insulation all the way around the window so not just at seal level but also
00:07:02 also jams and hair yeah yeah you're going to have to do that the problem except that the gap was the same so the detail would have had to have been the same yeah [Applause] and then if we can turn to um another
00:07:14 and then if we can turn to um another document
00:07:15 document i think you provided at this time this is a risk assessment a method statement this is sdp 50198
00:07:30 this is sdp 50198 so i think the date of this document is the 19th of may 2015. yes we see that actually that's the start date it's got on here
00:07:40 on here um and sorry and the issue date so does that mean this would have been issued then um normally issued it normally issued a week before but sometimes a few days before depending on
00:07:51 sometimes a few days before depending on how much pressure we're under and had ryden told you that they wanted a risk assessment and method statement from you
00:07:56 from you that's standard everybody does that yeah and we can see it's um there's reference to sdp solutions in the top right hand box is that another trading name for sd
00:08:07 box is that another trading name for sd plastering it is yes in a lot of instances now where we use stp solutions because we're multifaceted and certainly as we've built the business and plastering if you won't get some inquiries of
00:08:19 you won't get some inquiries of sometimes if you're just known as a plastering company so the solution is just a brand name yeah mr dixon you're speaking quite quite fast and i think the transcriber
00:08:30 quite fast and i think the transcriber may
00:08:30 may sorry occasionally just struggles like you try and speak a little bit more slowly sorry um so if we look here on the scope of works at the bottom of that page we've got a box for scope of works
00:08:41 page we've got a box for scope of works and it says install and make good flowplast soffit and fascia board around window reveal so that's the upvc isn't it yes and then you've got boarders to be cut and stuck
00:08:53 boarders to be cut and stuck using adhesive and all gaps made good with mastic so that's about how you're going to stick that board around the edge yes yep and then you go on to say opera
00:09:04 and then you go on to say opera operatives must make all cuts within communal areas um can you help us as to why there isn't any reference here in this document to
00:09:15 document to celetex insulation or any other form of insulation board being placed in the cavities around the window frames it's a pretty generic document that's the short of it these are where we do these now these are
00:09:26 are where we do these now these are vastly different to how they looked x amount of years ago so there's a lot more detail in them now yeah and that's why there's no reference to plasterboard either there's no other reason than that i see
00:09:38 there's no other reason than that i see and can you help as to why the risk assessment and method statement doesn't make any mention of the fire resistance or fire performance of any of the materials
00:09:46 materials that were proposed for use around the windows
00:09:50 windows um no more reason and we wasn't asked to provide anything that had a certain resistance or offered a certain uh compartmentation line or anything like that there was no guidance in saying
00:09:59 saying these are the things you can't use or these are the things you have to use yeah
00:10:03 yeah um i think with all of this and whether it be the celetex in the in the reveals or the plastic or anything else there was ample opportunity to inspect every stage of this
00:10:13 this yeah and to highlight that if there was something that didn't quite fit or wasn't up to the expectation of everybody
00:10:18 everybody to stop start again and then prescribe something else as a solution in your experience would it be usual not to get any form of specification for the products being
00:10:29 specification for the products being used from a design and build contractor like ryden you'd you'd normally expect to see more detail than this
00:10:39 at around this time did you or anyone else at sdp discuss the size and shape of the gaps with ryden in terms of not participating vulnerability to fire spread or anything
00:10:51 vulnerability to fire spread or anything like that
00:10:52 like that no
00:10:57 and was this risk assessment and method statement provided to the installation team for them to work from yes yeah and you've talked a few times about
00:11:07 about um potentially applying compression to the insulation can you just explain what that process would involve is it just pressing down on the upvc to push
00:11:18 just pressing down on the upvc to push down or is that quite the opposite so what you have is you've got the new window frame and you've got the existing uh inner line whether that be the window frame or the back of the board yeah yeah so what we were trying to do is cut the
00:11:29 what we were trying to do is cut the insulation that was oversized for the opening so that when you push it in you have to force the other side in which then in turn keeps it under compression i see yeah i understand
00:11:42 compression i see yeah i understand and where are operatives specifically informed that they had to do it under compression to fit it that way well it wouldn't have it wouldn't have wanted to stay in place otherwise you'd have had the same problem it was then tilted further into
00:11:54 problem it was then tilted further into the cavity and it would have ended up the same problem we had before yeah and just for completeness at this stage and we'll come back to this later now
00:12:01 now what we know is that following your first quotation on the 6th of may we can see a revised quotation was then sent on the 29th of may 2015. if we can just pull that up now this is
00:12:13 if we can just pull that up now this is sdp five zeros one eight nine
00:12:21 if we blow that up so this is the revised quotation and is it right that this
00:12:26 this revised quotation included for some boxing in work adjacent to the front doors of the flats yes but it didn't change the scope or sequence of work to the
00:12:37 the scope or sequence of work to the windows surrounds correct yeah
00:12:43 can i check where was sdp ever provided with any drawings either from the architect or from ryden to assist with carrying out these
00:12:54 to assist with carrying out these windows surround works not to my knowledge and again if the if there had been a set of drawings and it showed something different that's what would have been constructed on site and even if there had been an error in one there wouldn't have been an error in
00:13:06 one there wouldn't have been an error in every flat
00:13:09 so you say not to my knowledge again if there had been a set of drawings and it showed something different that's what i've been constructed were you ever aware of a set of drawings which
00:13:18 which addressed the way in which these windows surrounds should be constructed did you or anyone else at sdp to your knowledge ever have a discussion about the design of these internal
00:13:30 about the design of these internal window surrounds with studio e the architects on the project not to my knowledge
00:13:35 knowledge were you even aware that studio e were involved when you were carrying out this work
00:13:39 work yes did you ever come across studio e as part of your other work on the project uh there may have been some correspondence somewhere on the line but normally the the idea is
00:13:51 on the line but normally the the idea is that if i want to correspond with a any sort of um design issue my line is into ryden's and then ryden's back out again to the architect and then the arc set back in and back out to me
00:14:03 the arc set back in and back out to me again yeah we don't go around the back of that no but to your knowledge you don't think you had any discussions with at any stage with with studio e if they were they may have been on site i may have met two or three of them i
00:14:15 i may have met two or three of them i have no idea but not to my knowledge yeah what about with harley we know they were doing their works on the exterior including applying the upvc membrane around the windows
00:14:26 the upvc membrane around the windows did you ever have any discussions with them about the interface between your work and their work no i think there was a the very early stages it was just a bit of sequencing when they took out the
00:14:37 of sequencing when they took out the glass from the windows yeah that was with one of their team supervisors but no more than that
00:14:46 and did you ever produce any drawings yourselves of the work that was going to be carried out to these window surrounds no i don't believe so
00:14:57 now just a little bit more on the the contractual arrangement between you and ryden
00:15:02 ryden it's correct isn't it that prior to taking on the work to refurbish the windows surrounds sd plastering was awarded a contract by ryden to undertake the dry lining and plastering works
00:15:13 plastering works at grenfell tower yes
00:15:18 if we can turn to ryd3031801
00:15:30 this is an email from february 17th of february 2015 from adam marriott to you at sd plastering copying in a
00:15:41 to you at sd plastering copying in a number of others at ryden and its subject is grenfell tower dry lining package and um he says mark simon further to your quotation of november 2015 and our subsequent
00:15:53 of november 2015 and our subsequent discussions we attach our letter of intent for the dry lining package required at grenfell tower
00:16:02 do you think that's a mistake in the date there he's saying 14th november 2015 do you think he perhaps meant 2014 for that given that this is an email in february 2015. uh i'm unsure okay now
00:16:14 uh i'm unsure okay now what we can see here is that um there's a letter of intent sent for the driver lining package and a number of other documents are sent including ride in
00:16:25 including ride in standard terms and conditions they're they're at appendix b and they're one of the attachments um now if we can turn up those standard terms and conditions this is a
00:16:39 ryd3031806
00:16:46 so these are their standard terms and conditions it was appendix b that you were sent and do you recognize this document uh as much from my time at ryden's as i do from the actual
00:16:57 do from the actual uh this part yeah i see so this would have been standard terms that for subcontractors but depending on what type of package they change slightly but yes yeah if we can look on at page
00:17:10 yes yeah if we can look on at page four at paragraph 2.18.1 it says this all workmanship is to comply with the following and then it says all workmanship is to comply with all manufacturers suppliers instructions
00:17:22 all manufacturers suppliers instructions and recommendations and current relevant british standards and code of practice do you see that there yes
00:17:30 so we can see that you were provided with those terms and conditions in relation to the dry lining work but my question for you is did you understand that sd plastering was required to comply with these state same standard terms and conditions when
00:17:42 same standard terms and conditions when they were carrying out work to the windows surrounds it applies across every piece of work doesn't it yeah they would ask you to try and comply with anything any of the standards anything else
00:17:53 anything else not necessarily knowing what every single standard is the fallback position for that is that you have a design team in place you have a management team in place you have building control in place so there's all these fools that if
00:18:04 so there's all these fools that if someone does make a mistake a mistake or doesn't quite understand what it should be this can be picked up by another party i see so i think what you're explaining there is it would have been implicit
00:18:15 there is it would have been implicit that your work had to comply with any relevant standards is that right you would have thought that any work that anybody does if there's a standard for it
00:18:24 for it that's the compliance yeah but did you actually ever think about and apply your mind to whether these standard terms and conditions also applied to the work you were doing to the windows surrounds
00:18:36 to the windows surrounds um at the end of the day they're always in the back of your mind that there are standard conditions that you need to work to so if this was uh if that would have been an instruction it would have still fallen under the main contract so these conditions would have still
00:18:48 so these conditions would have still been part of that i see that was your understanding at the time i think that's my understanding now i think
00:18:53 think and the same for everything every element of work you do if there's a bs for it
00:18:57 for it although it might not be written down we've all got a duty of care to try and comply to that yeah now in mr hughes's witness state mr david hughes's witness statement he says that sd plastering also did a large
00:19:09 that sd plastering also did a large number of additional work such as screeding fire stopping and fire proofing for the transcript that's uh in his statement ryd3094213
00:19:21 uh in his statement ryd3094213 page 9 paragraph 44. um did sd plastering undertake any fire stopping and fire proofing work at grenfell tower yes on the lower levels can you just
00:19:34 yes on the lower levels can you just explain what that involved at the lower levels
00:19:36 levels penetrations internal penetration so between walls so when we created a wall if someone penetrated wall at the top we would then fill it with the appropriate mastic canal to make sure that line was reinstated
00:19:47 that line was reinstated yeah and in terms of the individuals that carried out that work would they have been the same individuals that were then used for the windows surrounds uh not necessarily no no okay if we can
00:19:59 uh not necessarily no no okay if we can just turn to an email this is
00:20:04 ryd3064707
00:20:10 this is an email um i want to go down to the third email in the chain that's at the bottom of that page it's an email from jason north who's one of the ryden site
00:20:21 north who's one of the ryden site managers
00:20:22 managers to you copying in david hughes about grenfell tower and if we look in the first line
00:20:32 second sentence so he says hope all well with yourself do you think you can stretch to supplying our good cells with the following and then he says somebody qualified for fire stopping
00:20:43 fire stopping this is to include all penetrations etc removal and replacing of panels um can you just help us when he says there someone qualified for fire stopping what
00:20:55 someone qualified for fire stopping what did you understand him to mean by that experienced someone who's got some sort of experience in it doesn't mean necessarily qualified um at that stage in time
00:21:04 in time most people working within fire proof it was someone that had actually been on one of the product courses so you understand how to install the product yeah and that's kind of qualified since then obviously things have changed quite
00:21:15 obviously things have changed quite dramatically and qualified means something very very different yeah now when you were carrying out the window reveal work um were any of your
00:21:28 um were any of your workmen required to have particular qualifications or training in terms of the work that was being done no and again it was seen as a nothing more than a cosmetic
00:21:39 than a cosmetic detail so the skill base for that is slightly different in someone who can install
00:21:44 install the elements that went in they didn't need to be qualified as a fire technician they didn't need to be qualified as a surveyor or anything else that's the limitation of that task yeah okay now i just want to come on to
00:21:58 yeah okay now i just want to come on to some more detail about the choice of materials
00:22:01 materials uh used in the windows surrounds um mr lawrence simon lawrence said in his oral evidence the inquiry that he didn't know
00:22:09 know who had selected the insulation materials to be used but he thought that you would have gone away looked at your supply chain to find out what rigid insulation would fit in the thickness that was needed before
00:22:21 in the thickness that was needed before choosing where to get the materials from that was his evidence would you agree with that that that's what happened in practice um yeah there would have been there have
00:22:32 um yeah there would have been there have been quite a few discussions about that material and certainly would have had a sample on site at some point so it may be that we've gone away and looked at availability um but i think there's also an email from simon prior to this
00:22:43 an email from simon prior to this okay concerning the sample window that he actually mentions that the other team had fitted celetex so there is a reference already to that much earlier on
00:22:56 um
00:23:01 so is your is your evidence that the selection of materials was based on agreement between ryden and sdp as to what the appropriate rigid insulation board would be for those
00:23:12 insulation board would be for those locations
00:23:14 locations yeah i don't think there was anything to say that the materials that we used on site and put in place for people to inspect there was nothing to say that that wasn't the case not to use them yeah now we know that the insulation
00:23:26 yeah now we know that the insulation used by sdp in the windows surrounds uh was either 25 millimeter celatex tb 4000 insulation boards
00:23:37 tb 4000 insulation boards or 25 millimeter kingspan thermopitch tp10 insulation boards is that correct i would suggest that's correct yeah now at the time of the grenfeld
00:23:48 yeah now at the time of the grenfeld project were you generally aware of the requirements in the building regulations uh not in particular this because we didn't take on a design element of this so
00:23:59 take on a design element of this so we'd not done anything at this height yeah the regulations within refurb and new build
00:24:03 new build they're very different and they're very open to interpretation that's one of the biggest problems yeah um so what we was guided by was saying that this is what we're going to do
00:24:11 do can someone give us formal agreement that we can continue yeah that's exactly how it was put together yeah so you were looking to others on the project to tell you if there were any compliance issues with what you were proposing
00:24:21 proposing the the guidance on refurbishment is as i say is quite hazy in some areas so the whole point of that is that you put it through a chain of command including the design teams
00:24:33 including the design teams the client building control and my understanding is that everybody had looked at that everybody had agreed that and said we can proceed on that basis when you're saying your understanding
00:24:44 when you're saying your understanding that everybody had looked at that are you saying that everybody had seen precisely which insulation products you were proposing to use
00:24:51 to use the celotex and the kingspan and your understanding was that all of those people in that chain were happy with that my understanding is that everybody knew what was doing
00:25:02 and you referred there to the design team
00:25:06 team did you ever have a discussion with studio e about this specific insulation products and building control you also referred to um
00:25:17 to um would building control have been made aware of the products you were using in that location i can only assume so but you don't have any direct evidence of that in terms of no you weren't on site when there was a
00:25:28 weren't on site when there was a building control visit no but only on the basis that we was allowed to continue i see yeah we'll come back to that topic i think a bit later um
00:25:41 topic i think a bit later um were you aware of any of the guidance in approved document be on fire safety at this time
00:25:46 this time not at this time were you aware that there was some specific guidance for buildings over 18 meters in terms of the types of materials that could be used on them
00:25:58 used on them in a new build situation yes but not in a refurb situation so was it your understanding that if you were refurbing a building an existing building that if that was a tall building there
00:26:10 that if that was a tall building there wasn't any particular requirements my understanding was that there was a design team in place building control in place yeah um to ensure that if there was a regulation in there or if it was open to
00:26:21 regulation in there or if it was open to interpretation that was brought to site and then if there had been anything within the detail in that they wasn't happy with that it could be stopped rectified before it continued up through the
00:26:32 before it continued up through the building
00:26:33 building yeah but i'm asking you about your knowledge did you have any knowledge at the time that there might be special rules for a refurb if that building was over 18 meters no i didn't were you aware that that
00:26:45 no i didn't were you aware that that guidance provided that any insulation materials used in an external wall were required to be of limited combustibility had you ever heard of the term limited combustibility at the time of the
00:26:57 combustibility at the time of the grenfell project yes in what context did you heard about that uh
00:27:03 uh it would just rose up in countless conversations whether it be in a technical
00:27:06 technical it could have been it was normally to do with insulation anyway yeah and it might have been on a previous scheme somewhere in a new build situation rather than a refurb because
00:27:17 rather than a refurb because even in a lot new build they were still installing phenolic insulation on the outside of buildings which is now something that's not done anymore so that term would have probably come from a new build rather than a refurb
00:27:28 refurb yeah and you're quite sure that was the term limited combustibility are you i can't be certain but i've certainly heard it before and i've certainly heard it quite a while ago and if you'd heard that term at the time what would you have understood that to
00:27:39 what would you have understood that to mean
00:27:40 mean that means whatever product is put in there should have some sort of fire rating and it doesn't add to the fire yeah did you think there were any there was any guidance which might apply
00:27:52 any guidance which might apply in terms of fire safety to the internal works that you were doing to the windows at grenfell tower now what i'd actually assumed is that the process had already been done yeah that the strategy was achieved
00:28:04 yeah that the strategy was achieved which means that everybody knew exactly what was required where it was required and the safety to ensure that nothing is missed is that a site management team a a control officer uh and studio e
00:28:18 a a control officer uh and studio e have the ability to sign those off and say we're happy with what's being done the overall strategy is the key yeah you say there that you what you assumed is that the process has already
00:28:29 assumed is that the process has already been done
00:28:29 been done but i think you agreed that it was you that first suggested that celetex is that right you know i i actually said was simon o'connor had already simon lawrence had already
00:28:40 already simon lawrence had already identified an earlier email that celetex had been placed by somebody else we probably replicated that i see and the kingspan product was that something that you chose yourself i think the kingspan only came about
00:28:52 i think the kingspan only came about because there was no availability of celitex at the time yeah but they perform almost the same but did you take the decision to swap the kingspan in because you thought it was a like-for-like product oh i think probably andy would have contacted me at
00:29:04 probably andy would have contacted me at some point it said there's no sellotapes can i get king's banner and i would have said yes
00:29:07 said yes yeah and who's the andy your friend yeah
00:29:14 were you aware at the time that there was guidance including an approved document b that provided that cavity barriers had to be installed around window openings to prevent the spread of fire from a
00:29:25 prevent the spread of fire from a compartment into any external wall cavity no
00:29:32 have you ever been involved in a project where cavity barriers have been installed around windows or other fireproofing around windows in a new board situation yes yes and and
00:29:44 yes and and what was that new build situation what was it it's a block of flats it was six stories high so and we installed the barriers on the outside as well so as part of uh part of our works we've installed the insulation
00:29:55 our works we've installed the insulation the barriers around the windows um uh but that again that that is a new build situation not a refurb situation and just help us as to that in that new build situation what what were the
00:30:06 build situation what what were the barriers that you were installing around the windows were they cavity barriers they were vented barriers so these were these are actually a product by fire firm so it's their vented system right yeah
00:30:18 did you ever consider the fire performance of the materials that you were installing around the windows no i didn't no
00:30:28 did you ever consider how the window surrounds at grenfell tower would behave if there was a fire in the compartment but did it occur ever occur to you that
00:30:39 but did it occur ever occur to you that there might be a need to be some form of fire barrier or fireproofing around the windows
00:30:47 internally no the directive was not to place one on the internals so i guess you can assume that somewhere on the outside of the building the strategy was already in place to deal with any fires on the outside
00:30:58 deal with any fires on the outside i see that was an assumption you made at the time was it it wasn't what i needed to make at the time because my concern was the inside not the outside yeah and did you think someone else was
00:31:09 and did you think someone else was responsible for that for that fire fire proofing on the outside of the building we had no works on the outside of the building did you ever check yourself whether there were any cavity barriers around
00:31:20 there were any cavity barriers around the windows during the time that you were
00:31:22 were involved in the internal window reveal work
00:31:26 work no there was no requirement to do that did you ever consider having a meeting with harley to discuss the interface between your work and their work
00:31:38 work and their work no because they're starting to intimate that i'm taking on the design responsibility for this that wasn't the case at all this was a series of works that were directed towards us with a series of
00:31:51 with a series of benchmarks to hear which was it needed to be
00:31:54 to be in a pre-finished product it needed to be
00:31:57 be as quick as we can to cause as less disruption to um to the resident did you in fact know at the time that there were no cavity barriers
00:32:06 barriers immediately around the windows
00:32:11 had you known that there weren't any such cavity barriers around the windows do you think you would have done anything differently in terms of sdp's work
00:32:21 if i'd known what the consequences of and the outcome were would i have done something differently everybody would have done something differently i understand that but if you'd known at the time suppose
00:32:32 but if you'd known at the time suppose in that very first meeting at the show flat
00:32:35 flat simon lawrence had said to you and while you were chatting by the way there aren't any cavity barriers around the windows
00:32:40 windows we've got cavity barriers but they're further out away from the window do you think you would have raised any concerns about that at the time um possibly yeah i may have said to him
00:32:51 um possibly yeah i may have said to him well this is this is different to a newborn situation but as i keep in between newfound new build and refurbish there is a different criteria for this
00:32:59 for this and what you hope is that someone above my pay grade and a design element is actually looking at the strategy and saying right okay there's no barriers around windows but because because we're compartmented between floors and on the 60 minute walls
00:33:11 floors and on the 60 minute walls the risk is is reduced
00:33:18 i see yeah mr cole says at paragraph 23 of his witness statement i think i just read out what he says this is sdp 50220 at page four
00:33:31 sdp 50220 at page four he says as far as i'm aware stp were never instructed that the materials used in the completion of the works should have been of limited combustibility do you agree with that yes how often
00:33:44 yes how often had sdp used the celetex tb4000 or the kingspan thermopitch product previously in that situation yeah never never
00:33:58 did you or anyone else on behalf of sdp ever seek any information about the fire performance of those insulation products um no we didn't look at the day sheets
00:34:11 um no we didn't look at the day sheets did you or anyone else to your knowledge at sdp ever asked ryden or any other party
00:34:17 party any questions about the suitability of those particular products in this application in terms of compliance with the building regulations only in the fact that we created a sample using the same materials which hopefully would have
00:34:28 materials which hopefully would have triggered
00:34:29 triggered any conversations in non-suitability yeah when you created that sample how would those looking at the sample have known that it was that form of insulation is written on
00:34:41 that form of insulation is written on the face of it yeah so you'd have gone on the fact that it's on the branding yeah yeah i believe so it depends where you cut the ball obviously yeah but if again if there was a trick out for anybody to say
00:34:52 out for anybody to say right okay this detail is not going to work it needs to achieve this then it's somewhere in that criteria yeah as i said making a mistake once is is a mistake
00:35:03 making a mistake once is is a mistake making it throughout the building that's a very different thing with so many people looking at it yeah did you ever give any matters of compliance with building regulations or other industry guidance did you ever
00:35:14 other industry guidance did you ever give that any consideration in terms of these internal works no because i had assumed that this had already been done before we got there everybody else had already looked it and said this is the solution yeah did you know at the time that the
00:35:27 yeah did you know at the time that the celetex
00:35:27 celetex product was a european classification f product class f would that have meant anything to you if you had been made aware of that
00:35:39 you had been made aware of that uh based on what i know now yes but back then not limited if one of your operatives had said by the way i've had a look on the product sheet and it's
00:35:48 and it's it's class f file performance would that have meant anything to you i wouldn't mean that it didn't perform particularly well against fire right so did you know in general terms
00:35:59 right so did you know in general terms about the european classification system from a1 a2 down to f
00:36:03 f yeah i'm sure would have picked up on it at some point but again on that particular product in that particular solution they do sell it in this country yeah yeah which by that alone means that
00:36:14 yeah yeah which by that alone means that it can be used in certain situations yeah but it didn't ever occur to you that because this was a tall building there might need to be a need to just check whether that was appropriate
00:36:25 check whether that was appropriate no because we made it obvious to everybody what we were doing and what we was using yeah ultimately what i wanted and what should happen is there are several other people in this chain that can stop that process
00:36:36 can stop that process if they're not satisfied with it did you know that the kingspan product was a class
00:36:41 class e euro class product
00:36:46 were you aware that this was a combustible insulation material um not particularly no now mr lawrence said in his oral evidence to the inquiry that there was
00:36:57 evidence to the inquiry that there was no formal approval process for the use of the two insulation products the celetex and the kingspan and i think that accords with what you're saying that there was no
00:37:08 that there was no formal approval process but that what you're saying is because it would have been seen
00:37:12 been seen in the mock-up that was the process by which it was approved that would have been seen and it would have been talked about so there would have been discussions we don't we do a mock-up to give everybody the
00:37:23 mock-up to give everybody the opportunity to comment but you didn't ever see in a formal specification or a drawing you didn't ever see it formally specified that this would be
00:37:34 formally specified that this would be the celetex or the kingspan product
00:37:42 would it be more usual at the time for a design and build contractor to insist on their own
00:37:47 their own specification for a product like this i need to have the specification imposed on you
00:37:52 on you rather than yeah i guess it comes down to
00:37:56 to where the details being used and the importance of the detail yeah at the time would you have preferred to have had more guidance on what to use in that location
00:38:07 guidance on what to use in that location from ryden in hindsight yes i would prefer to have every piece of guidance in front of us
00:38:15 now paragraph 32.2 of your witness statement you say that the kingspan thermopitch boards were used interchangeably with the seletex boards depending on
00:38:26 with the seletex boards depending on their availability from your suppliers um can you recall what quantities of the kingspan product were used approximately in comparison with the sellers i have no idea
00:38:37 sellers i have no idea okay
00:38:41 did you ever have a discussion with ryden
00:38:45 ryden where you discussed using the kingspan in substitution for the cellotex did you ever have that specific discussion i can't remember if that happened but i'm sure we'd have made someone aware of it at the time that we were changing
00:38:57 it at the time that we were changing products
00:38:57 products and if you'd have made someone aware who would that have been do you think it would have been one of the site team it probably wasn't done formally yeah saying we're swapping products yeah so at this point i just want to take you
00:39:08 so at this point i just want to take you through a few photographs so we can just orientate ourselves um in in the work that you did um if we look first this is in section nine of dr lane's phase one report
00:39:19 of dr lane's phase one report at blas six zeros nine at page 20 and i want to look at figure
00:39:26 at figure 9.13
00:39:32 so this is if we can blow this up what we're looking at here we're looking at a window jam and we're looking at the side
00:39:39 side of the window where the window infill panel would join the the window itself do you do you agree with that
00:39:47 with that yes yes and we can see here that i think there it's celetex insulation it's got red branding on it and you can just see the end of the cellotex there
00:39:58 cellotex there that that insulation has been used to fill the gap between the original window infill panel and the new window infill panel do you see that there it is there to provide support to the plastic
00:40:10 provide support to the plastic yep and we can see that what what's at the bottom in yellow is a deformed upvc window surround which is just peeled back and melted
00:40:21 peeled back and melted and fallen away showing the board behind is that correct yes and that was work that your operatives did on site wasn't it was yes yeah we can see another picture of this if we go to mr hyatt's phase two report
00:40:33 if we go to mr hyatt's phase two report this is phyr5029 at page 20.
00:40:46 and i want to look at figures 4.11 and 4.12 yes thank you so i think we're looking at the other side of
00:40:54 side of that window arrangement back down towards where the window infill panels are we can see the new white window info panel can't we in that gap do you see that there and we
00:41:05 in that gap do you see that there and we can see that here some of the insulation and its foil facial has fallen away um and then if we look on the right hand picture
00:41:15 picture is it right that here we can see an example of celotex and kingspan being used in the same location is that correct yes because we've got the firmer pitch the kingspan thermopitch on the bottom with the green and the
00:41:27 on the bottom with the green and the celotex on the top with the red and you're looking at the rear of that yeah
00:41:33 that yeah and again that's work that your operatives would have done to put those boards in place and were they under compression when they were going in at that location on the sides of the windows do you cut the insulation so it's too
00:41:45 do you cut the insulation so it's too big and then squeeze it into that gap yeah it doesn't have to be precise because it will it as long as it's got connection at some point um originally it could have been that we didn't fulfill we didn't feel the whole of that that we
00:41:56 we didn't feel the whole of that that we just used blocks of it to support it but it was easier to put this in and also it actually assisted with
00:42:03 with um the thermal performance yes yeah and is it right that the insulation was stuck to the underside of the upvc
00:42:14 the upvc was there an adhesive used the upvc was stuck to the insulation right so on site you'd put the glue onto the adhesive onto the upvc would you and then yes put it
00:42:25 then yes put it in and it would just stick to the board yes yeah
00:42:29 yes yeah that's helpful let's look at the window head next
00:42:33 head next if we can go to blas 609 at page six
00:42:40 and i want to look at figure 9.3
00:42:48 so if we can zoom in there so i think what we're what we're seeing here at the top of the page is the original timber window reveal linings which were left in place is that correct yep and then because the windows have
00:43:01 yep and then because the windows have been moved out we've then got a gap at the head and it's in that location is that right that the
00:43:09 that the insulation has been compressed and pushed into that gap to support yeah to support the rear of the plastic board yeah so the gap didn't go all the way across you had some support from the original timber
00:43:20 original timber window reveals correct yeah but you had gaps beyond that yeah which means and where this came about was the fact that um on the lower seal section that if you
00:43:32 on the lower seal section that if you didn't try and fill in the back with some sort of uh rigid material you was going to be able to push them down and that was the concern
00:43:39 concern yeah and just to be absolutely clear that was work at the head of the window that sd plastering did yes yes because it also shows the steel angle above which were appeared above and below the windows yes
00:43:52 appeared above and below the windows yes which was fitted by harley yes and and dr lane has helpfully labeled that non-combat non-combustible steel angle at the window head that runs all the way along is that correct it looks exactly looks
00:44:03 is that correct it looks exactly looks like yeah
00:44:04 like yeah and then let's look at the um staying with the jam i think if we can look at another dr lane photograph this is blas
00:44:15 is blas 609 at page 13 and i want to look at figure 9.9
00:44:27 now here am i right that what we're seeing
00:44:30 seeing is the interface between the side of the window and the columns yes yes and um we can see the black edpm membrane that's been applied by harley
00:44:42 that's been applied by harley to for waterproofing purposes yes and then there's a gap that's been measured here this one is approximately 120 millimeters but we know that gap
00:44:53 120 millimeters but we know that gap varied up the tower yes were you aware of that at the time it did very yeah i think i didn't put that in my statement that it varied yeah and then at the bottom of the page
00:45:04 yeah and then at the bottom of the page she's highlighted the gap between the inside face of the window frame and the edge of the concrete sill we can see that there and that's because the original concrete tapered off didn't
00:45:16 the original concrete tapered off didn't it
00:45:17 it it did from away from the windows and below it so that we've got this gap in that location and is that the gap where you applied the insulation board yes but we wouldn't have filled that gap
00:45:29 yes but we wouldn't have filled that gap at that angle it would have filled the gap straight across so it would have in fact what he would have done is just close that gap off yeah so there'd still be a void underneath it a triangle shaped void but you're
00:45:40 a triangle shaped void but you're capping off the top yes before putting the ub upvc on top yeah that that gap there that she's highlighted in red the unfilled gap between the edge of the column and the window support bracket
00:45:52 window support bracket was anything ever done in that that gap there to my knowledge
00:46:01 now if we can look at um on the same page figure 9.109.10
00:46:11 yes so there i think we're looking up to the head of the window we've looked down and now we're looking up is that right i i believe that's showing you yes the
00:46:22 i i believe that's showing you yes the reveal yeah on the right-hand side and the head yeah and this is helpful because we can see the old timber window frames is that right on the right hand side i think you can see about in there yeah yeah
00:46:33 [Applause]
00:46:40 and then at the sill if we look finally at the sill position um if we can go to blas 609 at page five and look at figure 9.2
00:46:55 so if we can zoom in on that a little bit more
00:47:00 so here we can see the seal position starting at the very bottom we can see the original timber battens and then we can see the original concrete window sill is that correct at the bottom yes
00:47:13 sill is that correct at the bottom yes and beyond it that's where we then get the void where the concrete slopes off before the new window is that right yes and it is it that bit that was marked in yellow that was the little the bit that
00:47:25 yellow that was the little the bit that was bowing when you looked at the correct sample uh yes it was
00:47:34 and again we can see the black edpm membrane down the side and just to be clear did your operatives place
00:47:42 place insulation board in that gap that's marked with yellow yes
00:47:49 i believe it actually came across the top of that gap and then was wedged in up against what this doesn't show if i remember rightly there was a birch an existing timber surround
00:48:01 an existing timber surround which looks like it's been removed in this photo yeah so i think it was actually between the rear of that existing timber frame and the existing window frame that's where the compression happened
00:48:12 compression happened i see we can see a little channel at the bottom is that maybe where that timber has been removed i think there's probably a batter missing somewhere through here as well and it sat on top of that it was fixed and came out
00:48:23 of that it was fixed and came out yeah i see
00:48:27 yeah now can we turn to something that was
00:48:30 was known as the nbs specification on the project this is sca50169
00:48:45 this was prepared by studio e architects on the grenfell project it's called the mbs specification it formed part of the employer's requirements in ryden's contract can you recall i'll
00:48:58 ryden's contract can you recall i'll take you to a specific bit of it in a moment but can you recall ever seeing any extracts from the nvs specification when you
00:49:05 when you did your work it may have been more towards the dry lining though i see not in line with this so we may have at the extracted pages that form part of the dry lining package it may have been the whole document
00:49:16 it may have been the whole document but it had been yeah we would have only focused on the elements associated to dry lining if you had those
00:49:22 those elements that related to the dry lining package
00:49:25 package did it ever occur to you to ask can we see anything in the nbs specification that relates to the windows surrounds no the i think we was we was one of the
00:49:36 no the i think we was we was one of the last people to cost this element of works there'd been many before us you'd like to think that
00:49:41 that there'd been a series of processes have gone through and what we was being exposed to was the remaining option yeah so does that mean in your view that the window surrounds when after thought
00:49:53 the window surrounds when after thought on this project i think reading back through the emails and then out but remembering that the original ones were a birch surround which appeared and then a saving was taken and everything else that they were
00:50:04 taken and everything else that they were after
00:50:04 after i think they were a ve option that were designed into it i think you just said a ve option do you mean a value engineering option yes yes so this this these windows surrounds
00:50:16 yes so this this these windows surrounds were the product of some value engineering because the birch was too expensive yes that's quite well documented through something
00:50:24 were you aware at the time that birch had been
00:50:28 had been which windows surrounds had been specified by the architects no it's only become apparent through reading the information that we now have yeah so nobody at rider never said to you by the way originally we were going to
00:50:40 by the way originally we were going to have birch here but we can't afford that if they did i didn't notice it
00:50:47 it okay
00:50:49 [Applause]
00:50:53 can we turn within this mbs specification to page 242
00:50:59 and this is the beginning of the p10 section which is for sundry insulation and proofing work and if we can look um at page 243
00:51:10 and if we can look um at page 243 one page on from that and if we look at clause 235 at the very bottom of that page
00:51:20 page can you see there it says compressible insulation in gaps manufacturer rockwool limited
00:51:28 and it says the material is mineral wool to bsen
00:51:32 to bsen 13162 thickness to suit application available and then installation joints buttered no gaps cotton fit tightly between around cladding supports
00:51:43 tightly between around cladding supports fasteners used where necessary to retain insulation and or prevent slumping do you see that there yes did you ever see this part of the nbs specification
00:51:54 specification not to my knowledge
00:51:58 are you familiar with the rockwool product that's that's mentioned here it mentions a brand it doesn't mention a product did you know that rock wool was a mineral wool
00:52:10 mineral wool it's a rock wall at the time rock well not a mineral it's a rock wall based product i see yeah had you heard of mineral wall based products at the time you were working on grenfell
00:52:19 grenfell and rock walls yes yeah
00:52:24 did ryden or any other party ever suggest to you that sdp ought to consider using a mineral
00:52:32 mineral wool around the outside of the windows no
00:52:35 no but um secondary to that a 25 mil mineral wall unfaced or faced is not going to provide the support that you require to stop the seals from bowing rock is a very compressible flexible
00:52:46 rock is a very compressible flexible product
00:52:48 product because you've perhaps applied a plasterboard and then some mineral wool if necessary you could have done a multitude of things but none of those were specified or drawn and which
00:52:59 were specified or drawn and which indicates that they didn't foresee that being
00:53:02 being the main issue of fire escaping or the compartment line yeah did you know at the time that there was a difference in terms of fire performance been between a mineral wool or rockwool type
00:53:13 between a mineral wool or rockwool type insulation and say a phenolic insulation or a pir insulation board again depending on what brand because obviously there were plenty of um on the market at the time that
00:53:25 um on the market at the time that performed
00:53:26 performed similar but rockwall is a you know it is it's based around wall it's based around rock it's manufactured from rock so it's it's non-combustible yeah and when you say there were plenty
00:53:37 when you say there were plenty on the market at the time that performed similar are you saying there were plenty of
00:53:42 of insulation boards foam boards which performed similar to rockwool at the time
00:53:48 time probably not exactly the same as rockwell but have different gradients in different categories as the european f2a so there would have been other products that had a different performance standard
00:53:57 standard yeah but it depends on the thickness as well they don't all necessarily start the thinnest one yeah you might have to get to normal thickness yeah did it ever occur to you that our compressible mineral wool
00:54:10 compressible mineral wool insulation might be preferable to fill the gaps rather than a rigid insulation board
00:54:15 board it would have uh it wouldn't serve the purpose that it was intended for which was to support the seals i see did it ever occur to you that uh such a mineral will insulation might
00:54:27 uh such a mineral will insulation might be preferable in terms of the fire performance of the window surrounds
00:54:34 did you ever consider how the upvc surrounds
00:54:38 surrounds and the combustible insulation would perform in a fire if there was such a fire in the compartment uh no and that never gave you cause for
00:54:49 uh no and that never gave you cause for concern
00:54:50 concern no because that it's the overall strategy that deals with fire in the same vein in a in a set of uh window reveals there can be curtains the seal can be full of books
00:55:01 seal can be full of books there could be a multitude of other combustibles in that area yeah that are not fire proof yeah but it's true to say isn't it that the upvc was particularly susceptible to plastic
00:55:13 particularly susceptible to plastic deforming and yeah definitely yeah so it wouldn't provide
00:55:18 provide the same sort of fire protection as um plasterboard or some other form of one might say more orthodox or at least definitely
00:55:29 definitely old-fashioned material yeah definitely not it's not fit for that purpose it was fit for the purpose that it was intended for in this situation which was given us by the guidance which was the product needs to be easy to install
00:55:40 the product needs to be easy to install needs to be quick it needs to be pre-finished and again these decisions when i started reading through the document this was way in advance of we got involved in it that those decisions had already been made
00:55:51 already been made yeah i i understand that mr dixon we're just trying to understand what you understood at the time and what you were told at the time um on the upvc
00:56:03 um on the upvc um we know that ryden had used a plastic fascia and soffit board in the
00:56:09 in the mock-up that you saw first up um do you know
00:56:13 know whether that that that's what we know as the upvc
00:56:16 the upvc do you know whether the upvc that sdp then purchased and used for the windows was the same as that that had been used in the mock-up i can't say if it was definitely the same product
00:56:29 so was sdp ever instructed by ryden to use a specific type of upvc board or was it that left to sdp
00:56:37 to sdp to come up with whatever it thought appropriate it was to try and marry as close as possible to the aesthetics of the one that was already in place
00:56:47 did you ever discuss the selection of the upvc windows surrounds with ryden did you ever have a discussion about that
00:56:54 that no did you ever consider the appropriateness of the selection of upvc surrounds
00:57:00 surrounds when used in combination with a combustible insulation behind did you ever consider the far safety implications of installing a upvc window surround no
00:57:14 now expanding foam is my next topic um can you just help us and if necessary we can go back to some of the photos is it right that expanding foam was used
00:57:27 is it right that expanding foam was used to fill
00:57:28 to fill the oddly shaped gap at the junction of the window and the concrete column not by us not by you no
00:57:39 did did fdp ever use any form of expanding foam yeah i don't believe so not around anything in this around
00:57:51 if we can look at an image from dr lane's report this is blas six zeros nine at page 13 and i want to look at
00:58:02 look at figure 9.10
00:58:14 yes so there we did look at this earlier we see in the middle label with the red wiggly hatching around it that dr lane has noticed that combustible expanding foam has filled
00:58:26 combustible expanding foam has filled the gap
00:58:27 the gap there between levels um can you help us as to whether or not that was something sdp did i don't i don't believe that it's any anything to do with our works
00:58:38 it's any anything to do with our works there's no there was no point to us putting that in so i'm assuming at some point it was to fill the gap between the frame in the window or done from the outsides rather than the inside right so just to be clear
00:58:52 right so just to be clear to your knowledge there wasn't any form of expanding foam used by sdp installers not to my knowledge
00:59:01 now i just want to look at now at your statement to the met police
00:59:07 police if we can look um this is met3056695
00:59:16 this is your main statement that you gave to the police and um if you look at the bottom of page one
00:59:24 one we can see you say there stp is an experienced construction company providing and then you list various works
00:59:31 works yep and then you also say compartmentation fireproofing and property development do you see that there i do
00:59:42 and if we also look at the top of page four of this statement
00:59:48 you say compartmentation refers to subdividing areas and what that compartment needs to achieve this can vary from sound to fire resistance and water resistance with regards etc
01:00:00 and water resistance with regards etc with regards to the work carried out by sdp at grenfell tower the compartmentation was determined and directed
01:00:06 directed as per the architect's drawings provided by ryden
01:00:12 and then in the the last paragraph on that page
01:00:19 you say sorry penultimate paragraph you say compartmentation follows the indicated lines of fire protection given by the architect and can involve
01:00:30 given by the architect and can involve either construction of walls or placing of fireproof materials to fill gaps within those indicated lines
01:00:37 lines now looking at all of that can you just help us
01:00:43 help us in what way did your work on the grenfell project around the windows include compartmentation and fireproofing was was there any compartmentation and fire
01:00:54 was there any compartmentation and fire no there wasn't there's none indicated as required normally what you do is and this mainly refers to the lower four floors with the compartment walls so all the walls in there will be given different rates in 30 minutes 60
01:01:05 given different rates in 30 minutes 60 minutes 120 and that means that if you have to then someone makes a penetration on your wall you just need to compartment it back to that line as shown on the drawings yeah there's no drawings indicated um to us
01:01:16 there's no drawings indicated um to us or we was guided to that said you need to achieve 30 minutes round the window or 60 minutes or whatever it might be
01:01:22 might be yeah so when you're referring there to compartmentation and fireproofing is it right that you're actually referring to other works that sdp did at grenfell tower correct yeah it had no bearing on the upper floor works
01:01:34 had no bearing on the upper floor works yeah and you also said in those paragraphs that the work at grenfell that
01:01:39 that sdp did was determined and directed as per the architect's drawings again can we agree that you didn't have any architects drawings directing you as to what to do on the windows surround
01:01:50 to what to do on the windows surround agreed
01:01:54 now if you were aware that compartmentation can include placing of fireproof materials to fill gaps
01:02:02 gaps can you help us as to why at grenfell tower
01:02:05 tower no consideration appears to have been given to the gaps around the windows and placing fireproof materials in those gaps
01:02:13 gaps i can only assume again that prior to our involvement in it the strategy had been run
01:02:18 been run and someone had taken the decision that it wasn't required in those areas
01:02:24 did you ever query with ryden i mean you you worked for them for a long time you knew them well did you ever query and say to them we need a proper specification for this and we need the architect to
01:02:35 and we need the architect to approve this did you ever say that to them no because we came so late to the party we've assumed that everybody else has already run every scenario got it right there's been a lot of people involved in getting it to this stage
01:02:47 involved in getting it to this stage i don't need to be guided anymore and i'm being told it's an aesthetic finish we've got we've just got to close this off and make it look like it's supposed to again round the windows yeah but do you agree that you yourself
01:02:59 yeah but do you agree that you yourself didn't take any proactive steps to examine the fire performance of the windows surrounds and the extent to which those complied no i didn't i didn't i wasn't asked to
01:03:11 now moving on in the correspondence now i want to ask you some questions about some correspondence on the 27th of may 2015
01:03:19 2015 and some issues that were flagged by ryden about the work to the windows surrounds um if we can turn up ryd3z
01:03:42 so this is an email from simon lawrence to you
01:03:46 to you of the 27th of may 2015 and the subject is grenfell flat 145 and 17th floor communal now flat 145 was the pilot flat wasn't it correct yeah and we can see he says i
01:04:01 correct yeah and we can see he says i understand you're visiting grenfell tomorrow to take a look at the window trims amongst other areas
01:04:09 and then he asks in the next paragraph once you've had a chance to take a look could you give me a call please he talks about the boxing in the next paragraph which we're not concerned with and then he says this in the fourth
01:04:21 and then he says this in the fourth paragraph i then took a look at the window trimming which unfortunately wasn't the finished item that i was expecting
01:04:28 expecting there are still some areas which need tidying up eye joint strips need installing a couple of side trims outstanding and there's a large gap behind several reveal returns which are too large to mastic
01:04:40 mastic also andy has used a different upvc product than the original it had more of a bull nose whilst i preferred the square edge i'm not that fussed
01:04:49 fussed however they now need to re-trim the original window so it matches and then i want to read the next paragraph as well he says my biggest concern
01:04:58 concern is how they have fitted the window boards compared to the original attempt it seems that because they have used a thicker board they have decided not to install
01:05:08 install a plasterboard packer below in my opinion that was a big mistake this means that now all of the windows have a void beneath them which is only partly stuck with grip fill
01:05:19 fill as soon as you press them they noticeably deflect some really badly in my opinion this isn't acceptable and they all need reinstalling have a look and see what you think
01:05:32 so um i just want to ask you a few questions about that and in particular about his biggest concern where he talks about the window boards
01:05:45 the window boards um now is it right that at this point what he'd seen was the use of a thicker board a thicker insulation board with no plasterboard packer below no i think i think uh he's he's talking about a
01:05:57 i think uh he's he's talking about a thicker plastic board so what i believe this what this refers to is we did one sample window and a flat of which there were more than one window
01:06:04 window yeah so then what you had is there was one window still to finish they asked andy to finish that to get hand over the show flat and he went to get some available materials which then
01:06:16 materials which then was a different plastic capital so what he's referring to is i've got square edge on three windows i've got bulldoze on another one although it's thicker i can still push the back down so his concerns were not
01:06:27 the back down so his concerns were not to do with the plasterboard it was still concerns to do with it looks different to the other windows that have already been finished in there and also the the back has not been supported correctly
01:06:38 supported correctly i see so when he says it seems that because they've used a thicker board they've decided not to install a plasterboard packer below the thicker board he's referring to is the upvc is it
01:06:50 the upvc is it but is it right that there there'd been a decision at this point not to install a plasterboard packer below i don't think we ever installed a plastic ball packer below i think we went from
01:07:00 went from staring here for quite a while and then saying well okay they managed to support it with celatex in the in the original one
01:07:06 one let's go back and support this with celetex again he said what happened here seems to be that the uh the alternative window board was was
01:07:18 the alternative window board was was deeper than the original one that had been fitted correct didn't leave enough room for the packing that was originally used so no packing was used i think they thought by using a thicker bald
01:07:29 thought by using a thicker bald they can balance it and stick it to the front and it would self support at the back
01:07:34 back but it doesn't it wants to do that so i think what we've got to recognize here the show flat was there was a deadline to get it finished i think you can see in one of simon's other emails how frustrating he gets with daniel
01:07:45 frustrating he gets with daniel osgood or whatever his name is saying why isn't it done why isn't it done and it was all hands to deck and i think what andy had done has got picked up some more plastic to do this last window to try and get it finished
01:07:56 last window to try and get it finished to show the residents and that and inadvertently picked up a different material but it was only in that one window location so you're saying this was a thicker uv pvc
01:08:06 pvc with no nothing underneath it no plasterboard no no insulation in all honesty i don't know if andy packed it out with insulation but the mere fact that simon's saying that he could
01:08:17 simon's saying that he could put pressure on the back and drop it down indicates to me that we've not supported that as we had done every other window yeah because every other window after they'd been completed we didn't have any defects that said
01:08:28 have any defects that said yeah and push them back down but do you agree he seems to be saying in this email that not installing a plasterboard packer below he thinks was a big mistake i think he's incorrect i don't think that's what he meant at all
01:08:40 that's what he meant at all we never installed a plaster ball packer at the back there's no window if you expose every window on the job there's never been a plaster ball packer in there well we saw in your quote for the job that you had got mention of plasterboard and
01:08:53 got mention of plasterboard and insulation and you said you wanted to keep that flexible so that you had some we and we didn't need it
01:08:59 need it but might that not have caused him to think that you were going to be using a plasterboard packer below the upvc okay but then let's let's refer to it as exactly what it is as a packer that means it can be 35 mil wide
01:09:11 means it can be 35 mil wide by 100 mil deep there's no closing of the cavities there's no nothing it acts as a supportive strip so you can have them at intervals of 500 mil i see so what you're saying is they wouldn't have stretched across the whole
01:09:22 wouldn't have stretched across the whole of the gap so a plasterboard closer it would have been a pack up right there was talk of creating small plasterboard 100 mil rips sitting them in there under compression and then making sure the glue lines are
01:09:33 and then making sure the glue lines are on there
01:09:33 on there but what we was finding was in between those 500 ml you could still get some compression yeah so everybody went we've got to get a continuation of that that that detail well we've supported it
01:09:44 that that detail well we've supported it yeah i'm sorry had you finished yeah yeah i think you're going a bit fast for this transcriber so i can't help that try not to yeah please if you would thank you
01:09:54 yes so just to be absolutely clear i think what you're saying is any consideration that was being given to a plasterboard packer was a much narrower product just a strip of it
01:10:05 narrower product just a strip of it which wouldn't have addressed the problem of bowing either side of it is that is that correct no and i think what you've got when you say no does that mean sorry sorry are you agreeing with me i am agreeing
01:10:16 agreeing with me i am agreeing with you yes you're quite right so the the the reality is using the smaller plasterball packers would have just supported areas at different increments rather than trying to create one detail running
01:10:28 trying to create one detail running through yes you have a problem just let's get that down
01:10:36 yes okay the other issue with um using plasterboard is it's considerably more difficult to scribe in
01:10:44 scribe in to the gap which would have been irregular with the insulation you can then cut it to the approximate side and compress that in i see that's helpful
01:10:55 i see that's helpful and where he says um this means now all of the windows have a void beneath them which is only partly stuck with grip fill helpers just what what's the grip fill well he calls
01:11:06 what what's the grip fill well he calls it grip fill but it's the adhesive between the bald it's between the bald and the and the plastic
01:11:13 plastic so we stuck the two together between which board and the plastic between the insulation board yeah yeah and the plastic that's how we adhered the two together
01:11:24 that's how we adhered the two together so that would suggest that there was some insulation underneath what he'd inspected at this time
01:11:32 time um i'm not sure can you repeat that bit yeah so i'm asking you about the it's three lines down in that last paragraph he said this means that now all of the windows have a void
01:11:44 that now all of the windows have a void beneath them which is only partly stuck with grip fill and i'm just asking you what the grip fill was and i'm trying to work out what was stuck to the grip fill so i think what
01:11:57 stuck to the grip fill so i think what he's doing is he's saying you've only stuck the front section with a grip fill which is not grip though it's the other product that we use
01:12:03 use but you're only stuck at the front which means there's a void at the back which in turn
01:12:07 in turn means that we can push the back of the ball down which is the whole point of putting the bridging material in there
01:12:20 okay was any consideration ever given to putting
01:12:25 putting a full width of a plasterboard packer across that gap thereby enhancing the fire performance of the window
01:12:36 of the window no
01:12:40 did you ever think about the fire performance of a plasterboard product in that area
01:12:45 that area no and whether a fire rated plasterboard product might have provided more fire resistance in the event of a fire
01:12:54 fire it would have done but it wasn't requested as that was the detail that needed to be done
01:13:02 but i think what you're confirming and we'll follow this through is that in the end
01:13:07 end it was only ever insulation that was uh installed in those gaps and no plasterboard packer was ever installed that's correct yes correct
01:13:18 installed that's correct yes correct now mr lawrence in his we looked in the earlier parts of this email he obviously thinks you're going to be visiting when the tower the next day did you actually go in and inspect
01:13:30 actually go in and inspect this window surround the next day um i i can't remember i would normally i'm pretty good if i say i'm going to go and look at it i'm going to go and look at it
01:13:38 it and i would suggest there's no following emails from this which means we must have rectified it
01:13:44 right can you recall who might have been with you when you went back and looked at the windows surrounded
01:13:54 now just looking at paragraph 27 of your witness statement if we pull that out sdp
01:13:58 sdp 50196 at page six
01:14:04 you say during the course of completing the works in the pilot unit it became apparent that contrary to what i had specified
01:14:11 specified within the original quotation it would not be necessary to use both insulation board and plasterboard to bridge the gap the installation board alone being sufficient for this purpose and firm
01:14:22 sufficient for this purpose and firm enough
01:14:23 enough to provide the necessary support for the plastic soffit and fascia board i had made an allowance within the original quotation for the potential use of plasterboard in the works as a precaution
01:14:35 the works as a precaution in case the insulation board alone did not provide sufficient support for the plastic soffit and fascia board so
01:14:42 so we can see that and you just explained to us i think how that came about um
01:14:50 and did that become apparent at the time you were doing an another pilot of the window
01:14:56 window at the time you were working on window 145. no what i did was i gave myself the flexibility of coming across something else in the building that we had and envisaged because if that had been the case rydens would have said
01:15:07 been the case rydens would have said can you deal with that problem within your price so i'd taken and said right okay you might have to do this there you might have to do that there but in the most
01:15:15 most what we've done in the show flat should fit most areas right now if we can look at another email
01:15:22 email an email you send in response to that long one from mr lawrence um if we go to ryd three zeros four two eight
01:15:31 eight four four two four eight eight sorry ryd three zeros four two four eight eight
01:15:40 so this is your reply to simon lawrence it's on the same day 27th of may 2015 you reply in the evening
01:15:51 2015 you reply in the evening and we can say you say evening simon's starting at the top c responses below i'm on site tomorrow and we'll assess all areas
01:15:59 all areas but in relation to the points raised and and then you say this you say the fitting of the window boards was changed by me to try and streamline the process based on a thicker board
01:16:10 process based on a thicker board this does not work so we will change back to the original method of plasterboard backer first giving a more even surround do you see that there yep now would you
01:16:23 do you see that there yep now would you agree that when mr lawrence read this he would therefore have assumed that you were going back to an original method of having plasterboard backer
01:16:34 having plasterboard backer first yeah that's incorrect we didn't we definitely didn't use a plastic packer so why were you telling mr lawrence at this point that you would revert back to that method of installation it
01:16:45 back to that method of installation it may have been because it was quarter 8 in the evening so were you saying this to try and get mr lawrence off your back no definitely not we don't i don't try and get anybody off my back if i've got
01:16:56 and get anybody off my back if i've got a duty to do something i do it this is this is just a mistake the plaster ball backer wasn't in there it was actually the cellotex backer i see so are you saying this is just a
01:17:07 i see so are you saying this is just a mistake you made in this email yes that what you meant to say is we'll go back to the original method of
01:17:13 method of celetex insulation first giving a more even surround yeah even with the ball nose the thicker ball the thicker ball that andy picked up
01:17:22 up um when we was questioned over it i think uh
01:17:26 think uh it was never ever going to work because it wasn't supported enough at the back so we knew it was going to end up changing back did you ever realize that you've made that error in this email when you were
01:17:37 that error in this email when you were working on the project uh no no i was only exposed or reminded of this a little while ago yeah did so you never went back to mr lawrence and said to him by the way when
01:17:48 lawrence and said to him by the way when i said i was going to change back to the method of installing plasterboard backer i didn't mean a plasterboard backer i meant something else correct so i didn't go back to rectify them
01:17:58 them and if we can turn to sd plastering's revised quotation that comes in just two days after this on the 29th of may 2015 if we can turn
01:18:10 on the 29th of may 2015 if we can turn that up we saw it before sdp five zeros one three seven
01:18:22 here your we see in the email you're sending
01:18:25 sending adam marriott morning adam please find attached our revised windows sheet which now includes the boxing in and we know that you added the boxing in to the front of the flats
01:18:36 front of the flats and if we look at page two of this document we can see that revised quotation
01:18:43 and if we look in the top left hand side do you agree that it still says remove existing frame place plasterboard backer to gain margin and close cavity
01:18:56 to gain margin and close cavity correct and i think in my other statement as well that i issued there was a note in there saying that that comment should have been removed for clarity yeah so what you ought to have done is so you you say you made a mistake in
01:19:08 is so you you say you made a mistake in your 27th of may email referring to plasterboard backer and then that wasn't taken out of this revised quotation when you sent it
01:19:19 revised quotation when you sent it but that to one side as we've established the packer yeah which is only going to be 100 mil wide or anything would have still benefited no more apart from it had no combustibility but the cavity would have still been
01:19:30 but the cavity would have still been open yeah
01:19:33 open yeah but do you agree that based on what we've just looked at the email in this revised document mr mr lawrence and ryden
01:19:43 ryden may no would have assumed that you had to use plasterboard packer in those locations
01:19:48 locations that would insinuate that they didn't go and check anything after that point i see they checked every single unit after that point there was no plasterboard anywhere yeah
01:20:02 so chairman that might be an appropriate moment for a break i'm doing well i haven't got too much left to go but um i think we if we break now it's gonna get more central time yes yeah all right
01:20:13 get more central time yes yeah all right thank you um well uh mr dixon we're gonna have a short break now we'll come back at 25 to 4 please and resume then that's right and again please don't talk to anyone about your
01:20:25 please don't talk to anyone about your evidence while you're out thank you thank you thank you please thank you
01:20:37 uh 25 to 4 please
01:36:50 [Applause]
01:36:55 yes would you ask mr dixon to come back in please okay
01:37:11 right mr dixon ready to keep going yes thank you thank you very much this was grange
01:37:15 grange yes a couple of times in your evidence this afternoon you mentioned that there was an email involving ryden where the celetex product had been mentioned early on
01:37:27 product had been mentioned early on can i just take you to a document this is ryd3037749
01:37:43 yeah and i think it's in the middle of that page the adam marriott email so this is adam marriott to simon lawrence copying in others at ryden so you weren't copied into this email
01:37:55 weren't copied into this email no and and he says morning simon and then he says so it's first of april 2015. so it's early on in the story of or your story of the window surrounds and he said everglades did not use any
01:38:07 and he said everglades did not use any four by two timber yesterday to overcome the aluminium track they laid celatex and then applied the upvc on top regards adam now is that the email
01:38:17 email you were referring to earlier in your evidence where you say it's clear that ryden themselves when the mock-up was done before you looked at that first mock-up had been
01:38:29 looked at that first mock-up had been using
01:38:29 using celetex there'd obviously been some sort of thought already given to that yeah now is it your evidence you're not copied into any of these emails when did you first see these email chains
01:38:40 you first see these email chains uh only in the last two weeks i've been preparing myself for this i see so you weren't aware at the time of these emails no but wait i'm sorry can i just interrupt
01:38:50 interrupt this means absolutely nothing to me at the moment are you able to explain what people are talking about here and what's the 4x2 timber doing uh nothing as far as i can tell perhaps
01:39:03 uh nothing as far as i can tell perhaps what they were thinking of doing is placing the 4x2 timber in between the cavity of the the window on the outside and then the concrete on the inside i can't see how that would have worked
01:39:14 i can't see how that would have worked because you've had to literally described every piece in yeah to do it and that's what i'm saying there's some comments between simon's emails and other emails that i don't
01:39:23 don't really think that they grasp what was going to actually be happening there and they say to overcome the aluminium track yes i was about to ask that i'm sorry sorry so in some instances the track stayed in so the aluminium track
01:39:35 track stayed in so the aluminium track is the outer frame of the window of the old yeah yeah so to use something like this would have lifted it up enough for you to sail over the top of the track which i think in a lot of cases
01:39:47 track which i think in a lot of cases the track remained in place where we was the celetex raised it up at the back and then by the time you'd stop the ball across the top onto the front existing board you could go across the top of the track
01:39:58 go across the top of the track thank you very much i think i nearly understand
01:40:04 yeah and i think we do see that this is entitled grenfield towers windows surround
01:40:08 surround so the combination of them talking about the celatex and the upvcc on top um when you read these recently you thought that they were referring to the windows surrounds we're dealing with
01:40:19 the windows surrounds we're dealing with here now yeah i i believe that's the case
01:40:22 case yeah when you inspected that um show flat for the first time that 145 was it clear that it was
01:40:33 that 145 was it clear that it was celetex
01:40:34 celetex insulation that was underneath the upvc no it was i'm not sure i can't really remember and i think even in one of my earlier statements i think one of them that we inspected
01:40:45 i think one of them that we inspected there was nothing underneath yeah so but there must have been a section somewhere we've stolen the idea from whatever better word to say well that seems to work and perhaps what we'll do is we'll support the windows using this method
01:40:57 the windows using this method so is it your evidence that you think that's where you got the idea of using the celetex product because it had been used in that mock-up i can't say for definite but in the back of my mind
01:41:08 of my mind i'm thinking that we've kind of replicated something that somebody else has already done yeah now just a couple of questions on the birch window surrounds um had birch window surrounds been used
01:41:20 had birch window surrounds been used would that have obviated the need for any packing or wedging around the outside
01:41:26 outside uh i have no idea of how they intended whether they were going to take the old ones out completely replace them or how they were going to fix them are they going to face fix them the thickness of it
01:41:37 thickness of it it didn't i as i say i've only picked up on the fact that these birch surrounds um were were the original intention via the
01:41:44 the information i've been given lately i think yeah so there wasn't there was no mention of this before this was as far as i was concerned the plastic was the way forward yeah now just picking back up where we
01:41:57 yeah now just picking back up where we were before we broke off we were discussing the plasterboard backers um and we saw in your email and then in your revised quotation that there was reference to plasterboard backers
01:42:09 plasterboard backers i think what you were then saying was well we didn't use them and it would have been obvious to ride an on-site that we hadn't used them is that right yes and your evidence is if they'd had a problem with that they could have told
01:42:21 problem with that they could have told you on site that that was unacceptable as i keep referring back to i think you can make one mistake you don't make a hundred and something mistakes in every single flat someone at some point is going to pick up on that process and
01:42:32 is going to pick up on that process and say well hang on build a controlled look to them
01:42:35 to them we've looked at them the architect i assume at some point has looked at them and everybody has come back and saying that this is this is fine this is what we're doing but just to be clear did sdp or you
01:42:46 but just to be clear did sdp or you yourself ever get express approval from rider not to use plasterboard packers did anyone say to you after those emails and the quotation
01:42:54 quotation we are okay with you not using plasterboard packers no it's a natural progression
01:43:02 and was a plasterboard packer ever used in any of the windows not to my knowledge i don't believe they were used anyway i think the method was finally installed was the most
01:43:13 was finally installed was the most appropriate method
01:43:19 now if we can go back to the email that you said in response you you sent on the 27th of may 2015 in response to mr lawrence's email if we this is ryd3042488
01:43:35 you say um towards the end of your message
01:43:39 message five lines up from the bottom
01:43:44 you say this you say we are still struggling to find our feet on the window details and i'm still anxious that taking on these works is going to give me additional headaches i could have done without and add in the time scales i'm not
01:43:56 and add in the time scales i'm not looking forward to it we are committed now so i need to find ways of making it easier and quicker before i add another team in before we have it under control do you see that there i don't now can
01:44:10 do you see that there i don't now can you just explain to us why at the end of may 2015
01:44:13 may 2015 sdp was still struggling to find its feet on the windows surrounds um it's making the process quicker it what it refers to is the sequence of events
01:44:23 events so you've got to remember when we go into a unit these are occupied which means that half of your job is going to be making sure that you can access each window so it was about trying to streamline the
01:44:34 so it was about trying to streamline the process that when we went in we could get on with it we could cut it perhaps quicker a different way we changed the method of cutting it but they're all around them sorry they're all around the mythology of doing it rather than
01:44:46 doing it rather than changing the specification i see so it's the configuration of how you did it rather than what materials you were using it's the sequence
01:44:55 sequence that we did in did sd plastering not have sufficient personnel to carry out the work at this time not the speed that they wanted to go at and and one of my concerns was not just
01:45:07 and and one of my concerns was not just let's put two teams in and go for it was access in a residential block access changes by the minute which means that you can plan for the best scenario of doing two streams of two flats one a day seven
01:45:19 two streams of two flats one a day seven units a week i think the aim was and you get two or three residents drop out now and you've got a lot of people standing still so it was more occasionally trying to convince them look you want to do this logically and in a
01:45:30 you want to do this logically and in a way that's controllably let's use one team yeah they do this in the morning that on the other one and actually there was there was kind of two parts to it one part was going in the first day the
01:45:41 one part was going in the first day the windows being taken out putting the celotex around taping it all out making sure it's ready for the next day
01:45:47 day where the next team comes in and then actually cuts every piece and puts it around and one of the things that we did to speed that process was team one would measure all the plastic so they had a cutting list for the next
01:45:59 so they had a cutting list for the next morning
01:46:00 morning so that was that kind of thought process of
01:46:03 of let's manage with one team let's be controlled in the manner that we do it but let's at least make sure that we're sequenced correctly so those were the constraints and pressures on you that meant you were not
01:46:14 pressures on you that meant you were not looking forward to carrying out the work and it would give you additional headaches is that right yeah it it there's no getting away from it working in residence houses is very disruptive for me it's it's not it's not always
01:46:26 me it's it's not it's not always welcomed and when you're trying to get to every window which has got all of their personal belongings stacked up against it it is it's not pleasant for a lot of people
01:46:36 people so um i very rarely look forward to that can we look at another email now this is
01:46:44 ryd3042487
01:46:51 this is an email from simon lawrence to daniel osgood and simon o'connor um dated 27th of may about the show flat now this wasn't sent to you you're not
01:47:02 now this wasn't sent to you you're not copied in here and he says uh gents i've sent an email tonight to mark explaining my thoughts and asking him to call me when he's on site tomorrow i thought it best not to copy everyone
01:47:14 i thought it best not to copy everyone in so hopefully it doesn't get defensive about the work and then he says i've also made steve blake away so aware so he isn't shocked when he visits tomorrow
01:47:25 tomorrow and then overall i'm extremely upset that we've got to today and in my opinion are nowhere near having the flat in a show condition shouldn't take me to visit and notice the issue straight away
01:47:36 the issue straight away apart from being unfinished in areas the bouncy window board is a disaster i still can't understand how it hasn't been noticed before and then he carries on um
01:47:47 and then he carries on um and then at the end of this email he says please ensure this happens it's our last chance do you see that there yes so mr lawrence was clearly um concerned about the works did you get
01:47:59 um concerned about the works did you get that impression at the time from ryden well this links this links into the other two emails that you looked at previously so this is the show flat so it's not the whole job it's the show flat there's a lot of pressure on the
01:48:10 flat there's a lot of pressure on the show flat because you want to get it looking right because they were ready to show the residents around i think they'd already delayed it once
01:48:16 once i think simon's frustrations are frankly based around the fact that they weren't going to have this ready for the opening day for the client to inspect and everybody else so it could have involved painting mastic
01:48:27 it could have involved painting mastic in and everything i think the bouncy seal
01:48:29 seal then leads back to one of the other emails where we changed the window board on that one window that was in the show flat
01:48:37 flat okay and is that why mr lawrence considered it the last chance to get the works right because it's all about the show flat and the pressure on that flat i think probably simon meant it's your
01:48:49 i think probably simon meant it's your last chance to reserve to his manager saying you need to get this right i think that's probably what he was intimating
01:48:58 yeah now i just want to ask you some more
01:49:01 more um questions about the the cost to sdp of doing the works and the time scale within which it had to do it if we can turn to ryd3040686
01:49:19 we've looked at this before this is where you sent to mark to adam marriott your first quotation and in the third line where you say this is nowhere near your allowance
01:49:32 is nowhere near your allowance and believe um that even our costs might be tight
01:49:37 be tight the team i was hoping to use wants considerably more money than i've allowed due to the risk element can you just help us as to what you meant there by the risk element um so
01:49:48 element um so let me just make sure i get this in the right context so
01:49:52 well the risk the risk element is i can't foresee how much furniture i've got to move when i go into a unit how well prepared the unit is what i'm going to face when i go in there we
01:50:03 going to face when i go in there we hadn't gone round and surveyed every unit at that time so i think one of the things we implemented in that strategic trying to make it better as well is i sent a document to them saying follow this sequence it will make our
01:50:15 follow this sequence it will make our lives a lot easier and one of those was to visit the unit both ryden's the rlo and one of my team one or two days before to make the resident aware of the disruption that
01:50:26 resident aware of the disruption that was going to happen but the risk was if i get there and i can't get in the risk is if i get there and this wind is completely different to all the others or
01:50:34 others or i've got to spend the first two hours of every day moving every every piece of furniture in and then placing it back at the end of the day so the resident doesn't feel like they've had their life totally disrupted
01:50:43 disrupted i see yeah and at the end of that paragraph
01:50:47 paragraph you say so i've built two lines up you say i've built a team using mostly employees to tackle this how did that team differ from the
01:50:58 how did that team differ from the original team you might have been hoping to use
01:51:00 to use the original team was a team of carpenters so this is more carpentry word than it is anything else it's the ability to measure cut and mastic and finish
01:51:09 finish the carpentry team that i wanted to get there um
01:51:12 there um whether it be the height of the building or location had just come up with a completely different because we tried to keep people on on price work as much as we can they just weren't interested so that meant
01:51:23 just weren't interested so that meant i had to readjust myself so i built andy and then i brought some other labour in that we use all the time and i built a team that i thought was most suited for doing those works yeah is it right that sdp engaged
01:51:35 yeah is it right that sdp engaged various subcontractors as part of the installation team yes and who sdp had responsibility for recruiting those subcontractors
01:51:46 those subcontractors that would have been conversations between me and andy yeah and what steps did sdp take to satisfy themselves that the individuals engaged to carry out the work had suitable
01:51:57 to carry out the work had suitable qualifications and experience uh well as as before the qualifications they needed were to be able to cut the boards fit the insulation so there is no qualification that such is experience so
01:52:09 qualification that such is experience so the individuals were used were people that we
01:52:11 that we were known to us yeah did you know at the time that ryden thought that harley and
01:52:17 and sd carpentry were going to be too expensive for this job uh not particularly it might have been mentioned somewhere but i don't really take much notice of that
01:52:28 don't really take much notice of that what steps did you take to ensure that the quality of the works completed by sdp was not compromised due to
01:52:35 to cost pressures there was only one way to do this
01:52:39 do this the way that we've done the show flat right which was to use the celestex use the plastic i couldn't come away from that
01:52:44 that because there was a set method there was only
01:52:47 only two stroke three components in it there's no way to cost save it so if we was going to make it work financially it was about our efficiency to install it and the methods were used
01:52:59 and the methods were used if we can now turn to ryd3042886 this is an email from you to james clifton
01:53:08 clifton of ryden
01:53:13 of ryden it's the one at the bottom of the the page there so this is the 2nd of june 2015 you to james clifton and copying in others at ryden and andy kohler sdp
01:53:27 others at ryden and andy kohler sdp and you say dear all i was on site today and counted the number of windows per floor which is 36 not 34 as stated by adam at the time of tender we will change the sheet and send
01:53:38 we will change the sheet and send revised sums in the near future do you see that there yep then if we look at mr um maynard's response to this at the top of the page zach maynard
01:53:50 at the top of the page zach maynard responds
01:53:51 responds and he says mark the labour time in each flat needs to stay the same so this element of the cost can't change appreciate that your materials cost might be under pressure but our budget costs remain the
01:54:04 pressure but our budget costs remain the same
01:54:05 same exclamation mark exclamation mark cheers zach do you see that there i do and then i just want to look at your
01:54:12 your response before asking you some questions this is
01:54:20 ryd304288
01:54:26 so what we can see from this is the following day on the 3rd of june 2015 you respond to zach maynard and james clifton
01:54:35 clifton and you say zach as it stands today these works are going to be difficult and this is not an element that we wanted to do and still don't so are carrying it out because no one else wanted to what i can't do is lose money on it i've
01:54:47 what i can't do is lose money on it i've already changed from my original team as the prices did not work for them and i'm wrestling with keeping the team in place that i have and had to increase their prices to keep them interested in wanted
01:54:58 them interested in wanted just wanting to stay perhaps we can ask the carpentry team that's on site to also cost the works these works have started much later than you planned meeting
01:55:10 you planned meeting i'm being asked to increase the program to two teams at some point which again gives me a lot of pressure i don't need at this point i'm happy for the other team to pick up half the units leaving me only one window
01:55:20 window short on my price please let me know how you wish to proceed so is it right from this that as uh june 2015 you're still very reluctant to be doing this work
01:55:32 doing this work i'm very reluctant to do this work at a loss
01:55:36 loss and i think the price reflected the fact that we did increase the cost accordingly and actually we did run it with pretty much one team as well because i think in the end they saw a sense that it was going to be very
01:55:48 sense that it was going to be very difficult
01:55:49 difficult to get the access levels that they needed so i think although there's a lot of touring and throwing which is a surveyor's job the outcome was that it was priced as it was supposed to be priced and it was done in the sequence it was supposed to
01:56:01 done in the sequence it was supposed to be done in yeah and have you already explained to us the reasons why you thought the installation works would be difficult that's the word you use in that first line is that for the reasons you've just explained to us
01:56:12 you've just explained to us it's occupied very far but it has it has its challenges
01:56:18 and is it right that it was your view that sdp risked losing money in completing these works
01:56:25 yeah i think as much uh as zac is playing his game i'm probably playing my game a little bit as well i don't want to
01:56:31 to dumb down everything and say yeah zach that's fine i'll take this this was also about both of us getting to the right level of deal what what steps did you take to ensure that sdp did not lose money on the work
01:56:44 that sdp did not lose money on the work we made sure that we ran it in an efficient manner by using the one team by making sure that we we measured on day one using all those techniques i made sure that my team was actually
01:56:56 i made sure that my team was actually running it as efficiently as they can did this ever impact on the materials that sdp
01:57:02 that sdp specified for this job no that wasn't an area that was ever going to look to gain on
01:57:07 on and did the cost pressure you were under ever have any impact in your view on the quality of the installation no
01:57:20 if we can turn now to ryd three zeros four
01:57:23 four four three three one and i want to pick up on page three of the chain
01:57:35 and i want to look this is an email from daniel osgood of ryden to you on the 22nd of june 2015 at 1209 and he says hi mark we need more manpower on the
01:57:47 mark we need more manpower on the trimming of the windows andy needs someone to refit the curtains we have tenants waiting and complaints will start do you see that there yep and if we scroll up to page two we
01:57:58 yep and if we scroll up to page two we can see
01:57:59 can see you reply on the same day
01:58:04 and in the first lines you say dan we will not be able to place more labor at this point on the window trims but have a new team starting on wednesday and several players will be coming out
01:58:15 several players will be coming out to go to another job i stated last week if we go to two teams i believe this will give us issues when appointments fail etc
01:58:23 fail etc can we please run with the new team for two weeks and then reassess if more labour is required
01:58:33 now is that what ended up happening that you just stuck with the new team rather than having two teams i i just increased the size of the team and it gave them different disciplines on the same line rather than trying to
01:58:44 on the same line rather than trying to go
01:58:44 go it's a lot more difficult to manage especially from a qa point of view where andy has then got to go to two different flats he just followed the sequence and it's been yeah and i think after this there are very
01:58:56 and i think after this there are very few if any emails indicate that we wasn't achieving what we set out to do yeah now we saw previously in email from you to mr osgood of the 29th of may that you talked about making recommendations to
01:59:08 talked about making recommendations to streamline the process if we've got a chance of hitting targets again have you already discussed those with us today it's things like making sure the measurements are taken on day one
01:59:18 one so that the day two people go in efficiently and install the upvc on day two is that what you're talking about yeah i believe the process was it was always going to be a lot easier if we had one controlled
01:59:30 easier if we had one controlled team yeah
01:59:36 if we could look at um ryd304288
01:59:51 this is the email actually we've looked at this before later the third of june and if we look in the sixth line down
02:00:03 you say picking up the sentence these works have started much later than you planned
02:00:09 planned meaning i'm being asked to increase the programme to two teams so can you help us is it right that work to the window surrounds was was behind schedule i think they were i think they were due to start
02:00:20 think they were due to start several weeks earlier and did the work therefore remain behind schedule throughout the time you were
02:00:27 were installing those windows no i think somewhere along the line we must have picked up the pace a little bit or we was finding the process that we'd actually set out to do was working even more efficiently
02:00:38 was working even more efficiently because i wasn't getting a lot of negative feedback i mean there were a lot of units there i think probably five or six a week and and as i say i think if you work your way through the emails there's nothing there's nothing at the end that says
02:00:49 there's nothing at the end that says you failed miserably in hitting the target dates okay now just having looked at those emails in the last five ten minutes is it fair to say that sdp was under
02:01:00 sdp was under time pressure to get the work done uh everybody's under time pressure all the time but i resisted that and actually did what i thought was right to do
02:01:08 do i see did those time pressures ever contribute to sdp needing to put together a team of installers which he felt was not ideal for the project they were ideal for the project and in
02:01:21 they were ideal for the project and in your mind did those time pressures ever lead to a compromise in the quality of the work
02:01:25 the work undertaken no now supervision of the works
02:01:30 works is it right that the windows surround works were supervised by mr andy cole of sdp
02:01:35 sdp on site and was mr cole himself ever supervised in terms of what he was doing on site yeah i was i was acting as the kind of go-between so i would have
02:01:46 go-between so i would have on many occasions i went there i would have caught up mandy check progress check what was doing walked a couple of units
02:01:52 units so it would have been a combination of me taking fulfilling the contracts managers role being the director um and andy doing the actual day-to-day install yeah if we can look at paragraph 38 of
02:02:04 yeah if we can look at paragraph 38 of your inquiry witness statement that's sdp 50196 at page nine
02:02:13 you you talk about um this phase of the works and that's the the window install i think being completed by what you refer to as sdpl's lead
02:02:24 sdpl's lead team and you say who that consisted of yeah and you've got at 38.3 an individual called carl gellard who's described as work experience
02:02:35 described as work experience can you just help us with that can you help us why you had a work experience he he actually came from the training course that was that was held on grenfell so he was identified someone who actually
02:02:47 identified someone who actually wanted to work he wanted to be part of the team and he was looking for more work experience i see was he actually carrying out any of the fitting to the interior window revealed no you would have it the lead team just purely helped
02:02:58 have it the lead team just purely helped do the stripping out putting the celotex in place so he may have cut some of the celotex and it would have been mainly peter and andrew that actually gone around and installed it i see
02:03:09 now inspections if we can then look within your witness statement on page 10 at paragraph 44-45
02:03:19 you say there that there were a number of individuals from ryden that would inspect and sign off the works and you list
02:03:25 list that what you call the the sign-off team mr martin
02:03:29 mr martin chris holt daniel osgood and then you say it had originally been envisaged that one of the sign-off team would carry out their inspections on the day on which
02:03:40 day on which the works in the relevant units had been completed
02:03:43 completed however it transpired that the sign-off team was not doing so and myself and andrew cole had to chase the sign-off team
02:03:50 team on a number of occasions to undertake their inspections do you see that there yes now just in terms of what the sign-off team were inspecting were they
02:04:01 team were inspecting were they inspecting once the finishers were in and the upvc was in are they inspecting the final install of the windows uh the final install so we're talking
02:04:12 uh the final install so we're talking more about there the the acceptance as a finished product yeah yeah the the team of
02:04:18 team of players you see there would have been in and out of the units all day long so they would have been in at different stages so and because we split the two stages up by putting the celotex in on day one the capping board today too that means that
02:04:29 capping board today too that means that there was this 24 hour period for people to actually look and see what's going on and see behind the plastic so it became more apparent to everybody so are you saying that this same team gary martin chris holt and
02:04:40 same team gary martin chris holt and daniel osgood would have had opportunities and and did take those opportunities to look at the install before the upvc went on i would certainly assume so yes you assume so or you actually know that
02:04:53 you assume so or you actually know that they did on the project i wasn't there every day but i know andy for talking to andy they were certainly in and out of the units on countless times during the day yeah now given what you've said there at paragraph 45 of your statement about
02:05:05 at paragraph 45 of your statement about it being envisaged that they'd carry out their inspections on the day on which the work was completed but they didn't do that and you had to chase um
02:05:15 um in your experience was it usual or sorry was it unusual for sdp to have to chase its main contractor to carry out
02:05:23 carry out their inspections of the work it's more of a case of self-preservation if i'm being honest so the longer we leave the finished product unchecked
02:05:31 unchecked the more likely the accidental damage could happen to it and then they go and check a week later after it was finished and they said well the scratches all over it that's down to you so it it trying to
02:05:43 that's down to you so it it trying to get them to sign off almost immediately after we finish means it gives them a chance to say you've not done this bit very well or the resident has also inspected with us we need to look at this again so it's just about
02:05:55 look at this again so it's just about trying to keep on top of it really the longer you leave it the more chances that
02:06:00 that it can it can be knocked or not heavily or
02:06:04 or scratched or whatever and then it's trying to recall who did that scratch yeah to your knowledge was ryden always behind schedule in terms of their carrying out of inspections of sdp's work no
02:06:16 inspections of sdp's work no i think once we'd we'd kind of done this and put the firework in place they were a lot more kind of proactive in making sure that happened mr gary martin has said in his oral
02:06:27 mr gary martin has said in his oral evidence the inquiry that he was responsible for inspecting the work to the windows surrounds after mr osgood's departure in july 2015 and that he would speak to you every
02:06:38 and that he would speak to you every time he was on site and that he worked very closely with your team do you agree with that um i i would suggest that gary had a lot of contact with andy on-site
02:06:49 contact with andy on-site with andy cole on twitter we've only got one time yeah did you understand that mr martin was responsible for inspecting the work on behalf of ryden it changed on several occasions but we
02:07:00 it changed on several occasions but we certainly knew someone was overseeing at any one point
02:07:05 if we can then turn to ryd3042593
02:07:16 this is a grenfell internal work sequence
02:07:20 sequence sheet sent we think by sdp to ryden on the 29th of may 2015 we've got the date at the top left-hand corner
02:07:32 corner and i we think this followed on from the discussions about the work in the pilot flat
02:07:37 flat with mr lawrence in at the end of may is that right yes now and at stage five of the work there so on the left hand column we can see
02:07:49 so on the left hand column we can see stage five sign off and then if we read on the right it says this will take place with danny on the end of the second day where an sdp qa sheet will be signed by stp
02:08:00 stp and ryden saying all works completed if minus
02:08:04 minus snags cannot be undertaken in two day period refer to comments below do you see that there yes now did did the work actually follow was that procedure actually followed on
02:08:16 was that procedure actually followed on site in the most as i say from the email previously is that they fell behind slightly doing some of those final inspections and sign-offs but andy would produce his qa sheets hand into them and say
02:08:27 hand into them and say is there any further comments on it or any snacks and i think during the whole process we've probably emailed perhaps two or three times to say can you go back and rectify this bit here or can you do that yeah
02:08:42 now it's right isn't it that ryden did raise a number of concerns about sdp's workmanship on site uh i'm aware of a couple
02:08:53 uh i'm aware of a couple if we can look at an example if we look at ryd
02:08:56 at ryd three zeros five five eight three five
02:09:01 and i want to look at the bottom of page one and on to page two
02:09:08 right at the bottom of that page on the 28th of october 2015 at 1633 we can see chris holt has written to andy and then if we go over the page and see
02:09:20 over the page and see what he says at the next he says as per our conversation earlier today i've checked the window trims in flat 53 fitted today and there are several issues
02:09:28 issues issued that need addressing top trim and middle bedroom needs to be doing in the living room bottom trims along the windows are not straight and then excess mastics left on the
02:09:41 and then excess mastics left on the trims in the living room and then at the end of that email he says this is not not a good workmanship and i have been told by the tenant that the operatives have tried to rush through the job and therefore we have this result could
02:09:53 and therefore we have this result could you organize for this to be rectified next week please bear in mind that we need to make an appointment with the tenant as he's not always in the property
02:10:01 property and we can see from the top of this chain on page one that you were cc'd into this email chain
02:10:12 i thought i responded didn't i
02:10:17 you may have done i don't think that's in this particular chain but we can see at the very top that you do get looped into this chain
02:10:27 i i i thought i responded right okay but just and again sorry just for a moment did receipt of that email give you any cause for concern about mr cole's ability to manage the works
02:10:39 cole's ability to manage the works no this unit was completely different to any other unit we'd been in they created some detailing in around the windows that wasn't apparent anywhere else so they had to think on their feet they'd
02:10:50 they had to think on their feet they'd done a pre-survey they got in there it still wasn't quite working early on and chris had picked up on this because the friends have obviously done some work themselves it wasn't interfacing very well with their works
02:11:01 works so he asked to rectify it and change it which we did i see
02:11:07 but i think after this don't think that what happened here when mr holt is saying that sdp was rushing through the work to meet deadlines you wouldn't accept that that was representative of the way in which the
02:11:19 representative of the way in which the work was carried out on site are there any further emails from chris holt to us
02:11:26 i'm just asking you whether you understood that sdp had been rushing through the work to meet ryden's deadlines
02:11:33 deadlines in many of these flats no it took exactly the same time scale that we planned for it to take it didn't take any less or any more
02:11:43 now you've referred at paragraph 47 of your witness statement to the fact there was a clerk of work john white was appointed by the employer to carry out
02:11:54 to carry out inspections of the refurbishment work generally including the works and mr kohler said at paragraph 24 of his witness statement these inspections were carried out regularly can you help us as to how
02:12:06 regularly can you help us as to how frequently mr john white inspected the works carried out by sdp to the windows surrounds no i can't i i believe the clerk works was on site a couple of times a week so
02:12:17 was on site a couple of times a week so if they did a walk around with him i assume as part of that walk around communal's externals internal so perhaps twice a week but it's very difficult to say for certain but obviously andy refers to the fact
02:12:28 but obviously andy refers to the fact that he did see him on a regular basis do you know whether mr white saw the way in which the gaps between the new windows and the old timber window surrounds were being filled again because it was a two day
02:12:39 filled again because it was a two day process you've got the progressive i would assume that he's seen both of those and i believe he must have been shown the show flat as well
02:12:50 did mr white ever provide feedback to sdp on the work being carried out to the windows surrounds not to my knowledge if we can now turn to ryd
02:13:00 to ryd 30441
02:13:05 and i want to look at the bottom of page one and over to page two so we start at the bottom of page one
02:13:12 one there's an email from simon o'connor 18th of june at 15 18 right at the bottom there to mr osgood if we go over the next page
02:13:24 osgood if we go over the next page we can see at the top of that page that you're cc'd into this email mark dixon and andy cole and it's the subject is windows sign-offs and he says afternoon danny following a
02:13:36 and he says afternoon danny following a conversation with andy cole sdp this afternoon he is concerned that we are plowing ahead with internal window trimming and currently none have been signed off by cow is this correct please can you
02:13:48 cow is this correct please can you update me on this urgently as we should be getting these signed off on a weekly basis
02:13:53 basis now do you remember seeing that email at the time
02:13:57 the time i was copied into it so i must have seen it at some point
02:14:03 if we then look at the mr cole's response
02:14:06 response um in the second email in the chain from the top
02:14:10 the top on page one
02:14:15 so if we look yes in the middle of that page on so on the 18th of june 2015 mr cole responds and he says hi all again
02:14:25 again friday count will be 17 but i have signed off 15 units and two are sitting on the desk and i will check them monday but please be aware by wednesday 24th of june there'll be another four units to be
02:14:37 there'll be another four units to be signed off it would be better if they were done each week so not to have a backlog of units thanks andy cole um so is it right that at this point
02:14:51 so is it right that at this point the the clerk of works was not inspecting the work on a regular basis so that there was a backlog that had built up
02:14:58 built up i think he was inspecting them i just don't think they were doing the final sign-off paperwork i see so it's more of a case that he was still doing his duties looking in the flats checking things i think possibly what does not happened
02:15:10 think possibly what does not happened is the final document if you like which goes to ryden's that we can refer back to and said it was signed off on this date yeah
02:15:16 date yeah okay did you ever take any steps to ensure that the clerk of works inspections were more regular for for the works you were carrying out did you ever initially probably this is instigated by me
02:15:27 instigated by me right andy's emails yeah i would have asked andy how many are signed off he would have said we're still waiting for some sign offs i would have said can you send an email let's prompt everybody to get back to the process would you agree
02:15:39 get back to the process would you agree that this email chain might suggest that the clerk of works was inspecting only the finished and final windows surrounds rather than inspecting the installation process as
02:15:50 inspecting the installation process as it progressed uh possibly because the sign off for me was the final sign off the progressive inspections didn't necessarily need a
02:16:02 inspections didn't necessarily need a sign off but we needed to make sure that as many bodies as possible we're looking at them as we went through the clerk of works wasn't there every day so he would have taken a percentage view on everything what does that mean he took a percentage
02:16:14 what does that mean he took a percentage view on everything he can't see every single one at every single stage he might be able to be there on the day after they've installed so let's say we finished it on a thursday he might come in on a monday and go
02:16:25 he might come in on a monday and go round five units and expect the final bit
02:16:28 bit but the day before he might only be able to inspect the install that's taking place on that day because it's only exposed for 24 hours the subframe that's it coming out look at ryd3082733
02:16:44 this is a site inspection report which is
02:16:47 is authored by mr john white of john rowan and partners and it's dated the 16th of june 2015. do you see that there yes and if we can go
02:16:58 go within this report at page three
02:17:04 and look at the second paragraph down in the right hand column
02:17:11 can we just blow that up the no it's the photograph sorry uh if we blow up the the second row of photographs if we could blow those up
02:17:22 yes we can see on the right hand side in the
02:17:25 the in his report he said flat 145 internal window trimming has been finished and casey tmo has agreed the finish as from today nine flats have been finished including old frames out
02:17:37 finished including old frames out new glass and trims fitted do you see that there now do you know what he means by kctmo has agreed the finish what would that mean uh
02:17:48 what would that mean uh it's not like kensington chelsea tmo yes but i mean does that mean anything to you as to whether anyone from the tmo was agreeing the finishes of the windows
02:18:00 was agreeing the finishes of the windows surrounds oh yeah but i don't know who that refers to specifically but that indicates to me that he's shown more individuals and that's the show flat as well 145. were you aware of any tmo employees individuals
02:18:13 of any tmo employees individuals inspecting the windows surrounds
02:18:17 so far as you were aware did rbkc building control ever see the work to the windows surrounds as it progressed yes as andy's statement that they saw
02:18:28 yes as andy's statement that they saw them on a regular basis whether they'd be once or twice a week and we would have been we would have been at both stages at any one day so one day you'd have had the inner frames exposed the second day you'd have
02:18:39 frames exposed the second day you'd have seen the plastic on but i'm talking now not about the clerk of works about rbkc building control officers or inspectors uh no i don't know you don't know
02:18:51 uh no i don't know you don't know you can't help us as to whether or not building control did ever go in and see the windows surrounds including what was underneath and the upvc no i'm not even sure i'd known
02:19:02 the upvc no i'm not even sure i'd known who it was from building control that came to sign
02:19:09 final topic now um complaints if we can turn to ryd3085892
02:19:24 this is an email from emma kelly at ryden
02:19:32 to harley copying in individuals at ryden and what's happened in this email is she's compiled a list of issues relating
02:19:44 she's compiled a list of issues relating to the
02:19:46 to the list of outstanding defects relating to the windows in this now do you remember ever seeing this email or anything like it at the time no
02:19:57 time no now if we look in the fourth line up from the bottom in the table on that page
02:20:04 there's a description there it says on the left hand side gaps in the windows 85 grenfell tower and in the final line drafty window
02:20:15 and in the final line drafty window were you ever made aware of complaints about gaps or drafts around the windows no not to my knowledge i'm assuming that that refers to the actual window itself rather than the
02:20:27 actual window itself rather than the surround but it's difficult to tell from the limited information you've got there so you weren't made aware of gaps or drafts
02:20:34 drafts around the world through our section of the works yeah no and again one of the things we did i think there might have been in the early stages we might have noted that there was some
02:20:45 we might have noted that there was some cold air around that so hence why everything was taped in so if you look at any of the windows around and when we foil taped it and that would have acted as a vapor barrier or a better air seal were you ever made aware that there were
02:20:58 were you ever made aware that there were a number of complaints made by residents about the windows surrounds after completion of the works um if we was we would have rectified them but i'm not i'm not aware that we ended up going
02:21:09 i'm not aware that we ended up going back to many times too many flats can we just look at one more document this is iws four zeros one two nine six
02:21:24 this is the witness statement of a lady called mariam yusuf adam who is a resident at flat 14 of grenfell tower
02:21:33 tower and if we can just look on page four at paragraph 20.
02:21:42 she says this i further raised a concern with the polystyrene material that was being used on my ceilings and in between the window frames i was told that this material was water resistant but flammable
02:21:54 resistant but flammable i complained because this material retained heat and i was already too warm in my flat i mentioned this to my in my statement to the mps no one addressed my concerns about the materials and it turns out that my
02:22:05 materials and it turns out that my concerns were legitimate were you ever made aware of any concerns about
02:22:11 about the material being used around the side of the window she's talking here about a polystyrene material used on the ceilings and in between the window
02:22:22 ceilings and in between the window frames
02:22:23 frames uh no we wasn't made specifically about anybody saying a resident saying this is not the way we want it done right okay mr thamer those are all my
02:22:34 right okay mr thamer those are all my questions right thank you very much if we could just um have a short break and then sweep up anything else how long do you think you might need for that purpose i wouldn't have thought any more than 10 minutes right
02:22:46 minutes right um mr dixon when cancer got to the end of her questions we need to have a short break to
02:22:52 break to take stock and to see whether any questions need to be added uh particularly from that from people who are watching from elsewhere so we're going to have a short break now we'll come back at 25 to 5
02:23:04 we'll come back at 25 to 5 and we'll see if there are any more questions at that stage all right say would you like to go with the usher and we'll come back then
02:23:17 thank you
02:23:21 thanks i'm grateful thank you
02:35:02 yes would you ask mr dixon to come back in please
02:35:17 all right mr dixon well we'll see if there are any more questions for you ms grange
02:35:21 grange yes just one um email chain i want to take mr dixon to in in fairness to him so
02:35:26 so if we can bring up ryd three zeros five five
02:35:29 five eight six zero and i want to start by looking at the top of page two
02:35:39 so um i think you said in your evidence early on that you had responded to the problems that have been identified in flat 53
02:35:49 flat 53 and if we look at the top of this email i think this is where you come into the email chain and you say to chris holt and andy cole on the 29th of october 2015
02:36:00 october 2015 if there are workmanship issues then fine but this is not as it has been explained
02:36:04 explained if the issues can be resolved with yourself in attendance then all are aware of what has been agreed my understanding is that this unit is not the same as all the others hence the adaption
02:36:13 adaption andy can you confirm that the issues raised are down to poor finishing so i think as you explained earlier you seem to be saying in this email that this was a rather unique it was flat with some
02:36:24 rather unique it was flat with some special issues and then if we can go one up to mr holt's response
02:36:35 um we can see there he says hi mark same day 29th october 2015. thank you for your email the way it looks to me it is down to poor workmanship on this section of the property
02:36:46 property and then he said in general the standard is very good if there is an issue fitting any materials i normally go to the property and discuss with the operatives and agree with the resident there's no other way to do it and ensure that the client
02:36:58 way to do it and ensure that the client will accept this please advise on the way forward so i think to be fair to you he's saying it is down to poor workmanship but he then says in brackets in general the standard is very good i just wanted to give you the
02:37:09 i just wanted to give you the opportunity to see that email chain since you'd asked yes before to be shown it is there anything more you want to say about that no no no no thank you mr chairman those are all my questions thank you
02:37:21 are all my questions thank you thank you very much well mr dixon those are all the questions we have for you thank you very much for coming to give your evidence it's been very useful to hear from you and we're very grateful so thank you very much and now of course you're free
02:37:33 very much and now of course you're free to go
02:37:34 to go excellent okay thank you
02:37:50 and that's it for the day ms granger yes thank you that's right and tomorrow we have
02:37:55 have mr john hoban and mr millett will be back
02:37:58 back in this yes seat all right thank you very much and before we go i just like to say thank you to a transcriber who i think had a particularly challenging day and uh i'd like you to know that we're
02:38:09 and uh i'd like you to know that we're very grateful for all your work thank you right we'll stop now 10 o'clock tomorrow please thank you
02:38:41 you