Rydon Evidence - Thursday 23rd July 2020 (1/2)

Full transcript

00:00:14 we

00:00:20 good morning everyone welcome to today's hearing

00:00:23 hearing today we're going to hear evidence from mr simon o'connor who for a time was ryden's project manager for the refurbishment of grenfell tower following an

00:00:34 of grenfell tower following an application made to me last year i directed that mr o'connor should not be visible while he gives his evidence although his voice will be heard in the usual way

00:00:45 voice will be heard in the usual way when he replies to questions therefore those watching on the live stream will see only the plain blue background with the inquiry logo yes mr bullet good morning mr chairman

00:00:58 yes mr bullet good morning mr chairman i now call mr simon o'connor please

00:01:22 and sincerely and truly declare and affirm that the evidence i shall give shall be the truth the whole truth and nothing but the truth good thank you very much mr o'connor sit down make yourself comfortable

00:01:38 right yes mr chairman thank you mr mr o'connor

00:01:42 o'connor can i start by saying thank you to you for attending today to give evidence to the inquiry we very much appreciate it if you have any difficulty understanding any of my questions then i will rephrase them if you ask me

00:01:54 then i will rephrase them if you ask me to do that or ask the question in a different way if you feel you need a break at any point please just tell us and we can take a short break can i also just ask you please to keep your voice up

00:02:05 please to keep your voice up for the transcriber who sits to your right

00:02:08 right so that she can get down into the transcript what you're saying very clearly

00:02:13 clearly okay and also just one other tip on that score a nod of the head or a shake of a head doesn't go onto the transcript so you have to say yes or no if that's your answer okay now you've

00:02:24 if that's your answer okay now you've made

00:02:24 made one witness statement dated the 28th of september

00:02:28 september 2018. it's on the desk in front of you to your uh to your left there but it'll appear on the screen as well it's at ryd3094221

00:02:47 is that your witness statement it is can i ask you to turn to page 12 please is that your signature it is have you read this witness statement recently yes are its contents true yes

00:03:00 yes are its contents true yes and have you discussed your evidence uh that you were you you are going to give today with anybody else before coming here to give evidence thank you now i'm going to start with a few questions relating to your

00:03:11 few questions relating to your experience and your background before moving

00:03:13 moving to ask you about some detailed questions uh in relation to your involvement in the grenfell tower project all right um so far as your background is concerned starting with that we can see from your statement that you

00:03:25 we can see from your statement that you work for ryden between september 2002 and september 2015. i did and during that time i think you worked your way up from foreman to site

00:03:36 worked your way up from foreman to site manager

00:03:37 manager and then took on some project management roles is that right yes and i think one example you give is the childcare's estate project in camden in north london yep yes and you also had been employed

00:03:49 yep yes and you also had been employed as a site manager on the george's estate project with a with ryden immediately moving on before moving on to the grenfell tower project i was yes yes uh was this and george's

00:04:00 i was yes yes uh was this and george's estate project an external refurbishment it was but not with any cladding but not with any cladding but it included i think three high-rise blocks it did uh and uh

00:04:11 it did uh and uh you were involved at the childcare as you said were you site manager at the childcare's estate one of many yes one of many how many i think there must have been seven maybe eight right

00:04:22 eight right uh now the chocolates estate was also a high rise

00:04:25 high rise project wasn't it it was and that all saying that did include the fitting of or involved the fitting of over cladding to the exterior of those blocks it did specifically i think it did

00:04:37 it did specifically i think it did involve

00:04:37 involve fitting acm cladding yes i believe so now i wouldn't be aware then it was nothing to do with the cladding

00:04:44 cladding i see you you weren't aware then right from your start on the grenfell tower refurbishment product in may 2014 were you occupied

00:04:55 in may 2014 were you occupied exclusively on that project until august 2015. i believe so right

00:05:06 can i ask you to look at your statement ryd300

00:05:11 ryd300 as we have in front of us and turn to page seven i'd like to look at paragraph 14 with you please you say there there were design team meetings throughout my time working on

00:05:23 meetings throughout my time working on the project i would be present for most of these meetings but not all of them so that i was aware of any discussions taking place from a logistics programming and progress perspective and

00:05:34 programming and progress perspective and so that as project manager i could make sure things were happening at the right time on site there were deadlines for the different stages of the project and i needed to know if

00:05:44 know if if a design decision was going to affect a deadline drawings would go through various revisions i was aware of this from the design team meetings once the drawings were marked approved for construction

00:05:55 marked approved for construction arrangements would be made for that work to go ahead it is at this stage that i would get involved because i needed to coordinate the works now that the drawings have been approved

00:06:06 drawings have been approved so can we take it from that mr o'connor that you were aware of all design decisions not all design decisions no like i said i didn't go to all the meetings um i was purely there from a logistics

00:06:19 um i was purely there from a logistics and sequencing point of view right but you didn't make any design decisions yourself no no and you say and it's a passage i read to you it's at this stage that i would get

00:06:30 it's at this stage that i would get involved that's once the drawings were marked approved for construction

00:06:39 and then if you look at the start of paragraph 15 you say i had seen the drawings

00:06:43 drawings for the exterior modifications but i would not have considered any other information about the components being used for example from the manufacturers i was focused on when the materials or

00:06:54 i was focused on when the materials or components would be arriving on site from a logistics and programming perspective i was not involved in the design or selection of materials for the works to the exterior of the building including the rain screen cladding

00:07:05 including the rain screen cladding panels and insulation now in the light of what you say there mr o'connor is it fair to say that you considered your active role

00:07:14 role only really started after the design had been approved for construction yes i mean when i joined the uh the the project

00:07:23 project um from memory i believe the materials had already already been chosen there was only some confusion regarding face fixing or cassette and some colors yes

00:07:39 and just examining a little bit further your

00:07:42 your involvement in what you did with the designs

00:07:47 designs is it right that what you did in practice in general terms was to take the finalized drawings which you got stamped approved for construction as the basis for you to coordinate the

00:07:59 as the basis for you to coordinate the work

00:08:00 work so that the project ran on time and to budget

00:08:03 budget on time yes right but you not not to budget

00:08:08 budget i wasn't in control of the budget right did you have any role or input in relation to setting the budget or sticking to the budget no not really um that was a surveyor's

00:08:19 no not really um that was a surveyor's team job

00:08:20 team job i see now the finalized uh designs took the form i think you're telling us of approved for construction drawings

00:08:30 drawings drawings which had approved for construction stamped on them is that right that's what i recall yes is it right then that you wouldn't see any drawings which didn't have that stamp on them um no i would see drawings move backwards

00:08:41 no i would see drawings move backwards and forwards during copied into emails right um but i wouldn't be commenting on them i would just know that if a drawing had gone off from studio e to say harley's it might come back with a comment on it

00:08:53 it might come back with a comment on it um right

00:08:55 um right that was a i wouldn't particularly look at them in depth until i was actually given them to construct can you help us with with this did you see uh any drawings

00:09:08 did you see uh any drawings to the best of your recollection which came from harley's marked approved for construction before they had been seen by studio e i don't recall at the time i don't recall

00:09:19 don't recall okay when you received drawings marked approved for construction did you take any steps yourself to check whether the designs complied with ryden's contractual requirements

00:09:31 ryden's contractual requirements i wasn't qualified to do so were you aware even in general terms of ryden's contractual requirements and obligations not really no not really did sorry no

00:09:42 not really no not really did sorry no that's that's very fair to take out the qualification did mr lawrence ever give you any kind of instruction or briefing as to even an outline what the contents of ryden's obligations to

00:09:54 contents of ryden's obligations to the tmo were what can contractual obligations contractual obligations did he ever give you any briefing or outline instruction as to

00:10:04 as to what any subcontractors obligations were to ryden

00:10:09 to ryden not that i recall now no

00:10:15 does it follow that you didn't take any steps yourself to check whether the designs complied with the building regulations yes yes you did or yes no i didn't no you didn't i was saying yes to your gift

00:10:27 you didn't i was saying yes to your gift okay

00:10:29 okay now when you saw drawings approved for construction so far as you understood it mr o'connor who had approved those drawings uh the architects the specialists

00:10:41 architects the specialists who we employed um now there's a number of designers and specialists i.e architects that have been trained to do this kind of thing

00:10:51 when you received information about which materials were being ordered to site

00:10:57 site or delivered to site where did that information tend generally to come from sorry can you ask the question again yes let me try a different way

00:11:09 when materials were ordered to come to site we were you responsible primarily for ordering them onto site as the project manager it would have been a supply and um

00:11:20 been a supply and um package so this the subcontractors would order their own materials and they would book them in through the gateman at the front as your as the occupant of the role of project

00:11:31 as the occupant of the role of project manager

00:11:31 manager throughout this period did you have any role

00:11:35 role in the selection of materials to go into the refurbishment no no can i ask you to look at a document please sea 50189

00:11:47 sea 50189 this is an email from simon lawrence to john hoban of rbkc building control dated the 3rd of september 2014

00:11:59 september 2014 and i'd like you to look at the sentence starting at the end of the first line uh you can see that you're copied into this email as is neil crawford and bruce sowns both from studio e

00:12:11 and bruce sowns both from studio e and in the second sentence at the beginning at the end of the first line uh mr lawrence says to mr hoban i understand that you dropped into our site office recently and had a brief introduction to the

00:12:23 and had a brief introduction to the project and drawings from our project manager

00:12:25 manager simon o'connor do you remember having a discussion with mr oh with mr hoban at about this time

00:12:33 time i don't but um if there's a good chance he would have come in just to introduce himself so i could put a face to a name right mr lawrence says that you had had a brief introduction or he

00:12:45 you had had a brief introduction or he had a brief introduction to the project and drawings from our project manager simon o'connor do you remember introducing mr hoban to the drawings i don't you don't so you can't help me

00:12:58 i don't you don't so you can't help me about which drawings you showed him i can't

00:13:05 do you remember asking mr hoban or having any kind of discussion with him at this time whether at this meeting or around this time whether the details of those drawings

00:13:16 whether the details of those drawings were compliant with the building regulations no i wouldn't have had that conversation you say you wouldn't have had that conversation does that tell us that you you you weren't in a position to have that

00:13:28 weren't in a position to have that conversation or that you don't recall having it i don't think i'd have been in a position to have that conversation with the building control officer right did you

00:13:39 in general terms ever have any conversations with john hoeven or anybody else from

00:13:46 rbkc

00:13:51 well it it in terms well in relation to anything in relation to this project do you remember any conversations with with john hogan of rvkc not particularly no not the ones that stand out okay well we'll come

00:14:04 ones that stand out okay well we'll come back i think and look at that perhaps in a little bit more detail later on can i go back to your witness statement

00:14:11 statement ryd3094221 and i'd like to go to page eight please at the top of the page let's look together at paragraph 15 you say there i know now although i did

00:14:23 you say there i know now although i did not know at the time of my involvement in the project that the types of materials used in the modifications to the exterior of the building were very commonly used i do not know why certain materials may

00:14:34 i do not know why certain materials may have been chosen my role as project manager did not involve deciding if materials were fit for purpose now you know now i think that the materials used

00:14:45 materials used in the exterior modification uh modifications at grenfell were very commonly used as what you say yes does that include specifically

00:14:57 yes does that include specifically the insulation uh i think all of the materials were fairly commonplace all of them say insulation and the rain screen cladding yes

00:15:08 screen cladding yes but you didn't know that at the time no this was my first cladding project uh now you told us earlier that you'd worked on

00:15:16 worked on childcards had you worked on ferrier point no

00:15:19 point no no so but you worked at chalcotes is it right that even by 2014 15 and your involvement on the grenfell tower refurbishment project you

00:15:29 you did not know at that time whether the materials used at grenfell were commonly used i didn't know did you ever think about it at the time not really that wasn't my role i mean

00:15:41 not really that wasn't my role i mean there was

00:15:41 there was a number of people around me the designers and architects and you know to specify this stuff day in day out i'm not qualified to do that yes so can we take it from that

00:15:52 yes so can we take it from that that you never asked any questions or familiarized yourself with the detailed properties of for example aluminium composite rain screen cladding

00:16:05 aluminium composite rain screen cladding no

00:16:06 no right

00:16:09 so is this right at no stage of your of your career actually before the grenfell tower fire did you think i wonder what this material is honestly no right and it would therefore

00:16:21 honestly no right and it would therefore follow

00:16:22 follow i suppose is this right that you never thought to yourself i wonder if this is safe

00:16:27 safe i saw conversations regarding you know building rigs and stuff like from between studio in and harley's and different parties i just presume they had all covered that base and being bearing in mind

00:16:39 base and being bearing in mind they're the specialists yes now can i ask you to turn to ryd3094208 and what i'm going to do mr o'connor is to show you

00:16:51 to show you part of a witness statement of alan grint

00:16:54 grint before i do can you confirm that alan grint was a site manager employed by ryden on the grenfell tower refurbishment project yes he was can we look at page two

00:17:05 yes he was can we look at page two please

00:17:07 please paragraph eight

00:17:13 and you can see there at the top of the page he says as a site manager my main role was to ensure that the work was carried out by the subcontractors in accordance with the program of works my instructions came from simon o'connor

00:17:27 my instructions came from simon o'connor now pausing there and looking at the bottom of the page at paragraph 16 i just want to focus with you on the last sentence there he says if building control were on site during my time on the project i think

00:17:40 during my time on the project i think simon o'connor would have dealt with them

00:17:43 them first do you agree that your role included the management and instruction of the site managers on site employed by ryden on this project yes but is it fair to say that an

00:17:54 yes but is it fair to say that an important part of that role was the provision

00:17:58 provision of design information to these site managers so that they could coordinate the works

00:18:02 the works taking place on site yes and also is it right that that role would include ensuring the quality of workmanship

00:18:13 not not just solely me no i mean i wouldn't be out looking at everything myself because it was a big project and there was number of managers um that responsibility would be passed on to the likes of alan

00:18:24 on to the likes of alan but they would be given the the correct paperwork to be able to do that uh you say there were a number of managers where there are a number of project managers in the same position as you on this project right so

00:18:36 position as you on this project right so when you say there were a number of managers

00:18:38 managers what are you referring to site managers so i see site managers okay but just to just to press you a little bit on the question uh is it not right that your role

00:18:50 is it not right that your role was to ensure the quality of of workmanship even if there were site managers themselves who who are watching the workers

00:19:01 who are watching the workers not entirely my role now i mean i i would oversee the site managers yeah so i suppose in reality it would fall to my remit but i can't be everywhere always so i am relying on their their professional

00:19:12 i am relying on their their professional opinions as well indeed do you see your job as as monitoring and supervising them so far as the quality of workmanship is concerned yeah yes

00:19:23 and the ultimate purpose of you supervising that exercise was to ensure that the project ran on time yes and uh in accordance with the approved designs

00:19:34 approved designs yes in accordance with the draw drawings yeah yes

00:19:39 yeah yes so did you have conversations or give instructions to your site managers on site when you looked at the drawings together pointed parts out and gave them instructions as

00:19:50 parts out and gave them instructions as to how to go about constructing what the drawing said should be constructed and we had especially subcontractors to do that um i would give the drawings to tuner managers and ask if they had any comments on it

00:20:01 comments on it and then we would generally beforehand probably sit down with the subcontractor as well

00:20:07 as well yes is mr grint correct in paragraph 16 when he says that if building control were on site

00:20:17 simon o'connor would have dealt with them

00:20:21 them i would have welcomed him onto site and probably done the making of tea and you know just chewing the fat for a minute and then he would have gone out with the relevant managers

00:20:31 managers i used to go on the master climbers with other managers to look at various things i wouldn't have gone always i see when you say other managers you mean other site managers sorry the site

00:20:42 other site managers sorry the site managers you were responsible for supervising yes yes you say i wouldn't have gone always did you ever go i would go out on occasion yeah right

00:20:53 i would go out on occasion yeah right and when you did get on those occasions did you have detailed conversations with the building control officer not detailed we was just walking around looking at the progress

00:21:04 looking at the progress um i would generally go internally if i was going to go i wouldn't go up in a mass climate because it just takes too much time out of my day to do that that's why managers are there i see okay

00:21:16 that's why managers are there i see okay on those occasions do you remember ever having any discussion or conversation with

00:21:22 with mr hoban about whether or not what he was looking at complied with the building regulations

00:21:28 no can i then go to a document art402087

00:21:39 this is the tender documentation submitted by ryden for the grenfell tower project dated 13th of february 2014. uh first of all do you remember ever

00:21:51 uh first of all do you remember ever seeing this document at the time no i think it's the first time i've seen it right well let's take it quickly then let's go to page 36 which is a a version of your cv

00:22:03 which is a a version of your cv um it sits within the tender documentation did you compile this cv no did you have any input into its compilation this would have been someone like the bid writers or

00:22:14 bid writers or marketing team not i see me okay

00:22:20 if you look at the top right hand side the role within the team it says simon is responsible for managing the smooth delivery

00:22:25 delivery of the project he is responsible for all operations on site including delivery to program and budget coordinating design and management of subcontractors you see

00:22:36 and management of subcontractors you see that

00:22:37 that do you agree with that summary of your role no i don't which parts do you not agree with coordinating design right how is that wrong because i i wouldn't be qualified to coordinate

00:22:48 wouldn't be qualified to coordinate designers and i wouldn't i wouldn't know where to start

00:22:52 did nobody from ryden ask you to approve this cv before it was put in the tender documentation i i never saw the tinder documentation right

00:23:02 right this was these cvs were built up of sort of you know back jobs you've done in the past

00:23:11 right well let's uh let's look and see what else

00:23:14 what else uh it says it says simon produces the works program is that correct yes and is responsible for compiling the health and safety plans for client approval is that correct health and safety file

00:23:25 correct health and safety file yeah right construction phase health and safety plan yes okay and managing health and safety on site yes yes and then it sets out the qualifications you have there i'm going to assume they're correct unless you tell me otherwise

00:23:39 um i didn't complete the hnc right okay and then benefits to the project

00:23:48 project uh simon is passionate about the site team working well together to ensure site management is to the highest standard and i'm certainly going to assume mr o'connor that that's correct absolutely uh

00:23:58 uh he confidently leads the on-site team in terms of design technical requirements health and safety subcontractor management and customer care is that correct

00:24:08 correct i would not agree with the design part no right

00:24:11 no right he is able to positively contribute technical expertise and facilitate informed choice for clients and residents

00:24:17 residents during value engineering and decision-making processes is that correct i don't think i've ever been part of a value engineering process

00:24:28 i've definitely been part of the residence choices and stuff like that but i don't think i've ever been part of a value engineering process right it goes on this applies to projects at both pretender and pre-start

00:24:39 projects at both pretender and pre-start stages

00:24:41 stages with the qualification you've made in relation to value engineering is that is that correct this applies to poverty

00:24:50 yeah i was very rarely involved in pre-pretender right

00:24:59 can you explain how this cv which was presented

00:25:02 presented uh to the tma in order to win the project by ryden contains so many inaccuracies in respect of your cv i can't no

00:25:13 in respect of your cv i can't no okay uh

00:25:29 okay uh you say in your witness statement uh and it's paragraph 13 if you need it i don't think we need to go back to it that you wouldn't have been qualified to form a view on the compliance of designs is that correct correct

00:25:51 were you involved in any way with the value engineering process on this project

00:26:00 were you aware that ryden did have to find cost savings for its client the tmo on this project i i was aware that value engineer has

00:26:12 i i was aware that value engineer has been talked about yes right can i ask you to look at your statement please uh ryd triple zero nine four two two one

00:26:27 and i'd like to look with you please paragraph

00:26:30 paragraph 17 this is at the end of paragraph 17. patron this is page and you say there

00:26:42 uh second line from the top however i was aware from meetings i attended you see that yep uh that there was a significant cost saving to be had for kctma

00:26:54 kctma i recall that there were discussions ongoing regarding the choice of color and the method of fixing of the cladding panels but not the choice of aluminium or zinc

00:27:04 or zinc were you involved in those discussions or aware of those discussions while design changes were being

00:27:11 being discussed sorry well were you involved in any of the meetings when the design changes were being discussed this this would be discussed at a monthly meeting so it would just be

00:27:23 monthly meeting so it would just be like an item but there would be separate meetings on that with a surveying team i see and you say there that

00:27:30 that there was a significant cost saving to be had

00:27:34 be had for kctmo

00:27:37 now given that did you appreciate that a change in the cladding rain screen from zinc to acm was a value engineering decision

00:27:45 decision at the time no right and i think from what you've told us before you yourself made no contribution so far as technical expertise is concerned

00:27:56 expertise is concerned to this to this value engineering discussion that you refer to did you yourself ever raise during these discussions the issue of fire safety

00:28:10 the issue of fire safety i don't think so i don't recall right [Applause]

00:28:25 did you take any steps in your role as project manager to ensure that the budgets were met we touched on this before

00:28:36 not particularly no i mean i was i was there for programming and sequencing i mean there was people running the budget and they would generally hire the subcontractors you know after like like a mini tender

00:28:49 you know after like like a mini tender ipad presume so um that part of the budget would already be done before they got to site right uh onsite were you involved in any cost-cutting decisions no so far as you're aware as project

00:29:03 no so far as you're aware as project manager

00:29:03 manager were any cost-cutting decisions made on-site

00:29:07 on-site not aware of no can i ask you to turn back to page two of your witness statement please and at the top of that page we can see paragraph

00:29:15 paragraph three you say five lines down i decided to leave ryden in july 2015 to work for another company i believe the last day i was the project

00:29:26 i believe the last day i was the project manager on site was thursday the 23rd of july 2015. so precisely five years ago apart from a few days during the first week of august 2015 when i was

00:29:37 the first week of august 2015 when i was asked to return to grenfell to provide holiday cover i was transferred to another project at lee bridge between july and september 2015.

00:29:46 2015. i left the company in september 2015 after working out my notice period why did you leave ryden mr o'connor i was given the opportunity to go some of the there was a lot of pressures

00:29:57 some of the there was a lot of pressures at the project at grenfell it was falling behind program and there's a lot of pressure and i was given the opportunity to join another company for significantly more money um

00:30:08 significantly more money um and another another opportunity you say there was

00:30:12 there was a lot of pressures at the project at grenfell

00:30:16 grenfell is that in the summer of 2015 yeah i just think leading up to i mean i'm sure you've seen you know start to fall behind program um and you know but when that happens

00:30:27 and you know but when that happens pressure pressure happens when you try and meet programs right can you can you help us with what other pressures uh were uh present on site during this

00:30:39 were uh present on site during this project

00:30:40 project um at that time extremely long days um yeah just a lot of a lot of pressure i was

00:30:47 i was you know this it was affecting my home life

00:30:51 life um when i was given the opportunity to to leave

00:30:55 to leave i i didn't take it easily i've been there a long time yeah but the opportunity i was given was i couldn't really turn it down did you feel at the time that you were being given uh support and

00:31:06 being given uh support and uh help uh to to be able to execute your role to the best of your ability at that time yeah i was being given support i mean you know i think

00:31:17 you know i think we would all agree we can all do we can have more support but um i was doing the best to complete my job

00:31:25 now can i turn to a completely different topic and i want to ask you about your awareness

00:31:30 awareness uh of different types of cladding and other fires at the time of the grenfell tower project were you aware of the different kinds of cladding panels that were available in the uk no so you weren't aware that cladding

00:31:43 uk no so you weren't aware that cladding panels were made with a variety of different materials including metals and metal composites at the time no no

00:31:53 at the time have you heard of the expression acm aluminium composite material

00:31:58 material no i hadn't even though you had been involved uh on the childcare estate project

00:32:03 project yeah i didn't i had nothing to do with the cladding at all i didn't even go on the scaffold right so does it follow from that that you wouldn't know and didn't know at the time

00:32:12 time that acm material frequently contained a core

00:32:15 core made from polyethylene or pe at the time now

00:32:18 now right and also the panels came with some some of them came with fire retardant cores which were less combustible again at the time

00:32:30 to your knowledge was there any general awareness within ryden as the company about the availability of these different panels and different kinds of core i don't know you don't know

00:32:45 were you aware of any major fires that had occurred in residential buildings either in the united kingdom or or elsewhere in the world involving cladding

00:32:59 i don't believe so were you aware or had you heard of the fire at lachnal house in southwark in the summer of 2009. yes you had yes can you explain how that you came to

00:33:13 yes can you explain how that you came to be aware of that fire a lot of news by the news at the time of the fire

00:33:19 the fire or i think it would have been at the time of the fire that's been probably on the news

00:33:22 the news right i think as well we had um that there might have been something sent around in the company um i can't be sure of that right

00:33:33 um i can't be sure of that right when something i know you can't be sure of it no i'm asking you to remember more than 10 years ago but when something can you remember when something was sent around within the company i can't

00:33:44 sent around within the company i can't it would have been a memo um but i couldn't tell you when or even if it happened right so you couldn't tell me what the memo said absolutely not was there any training or continuing

00:33:56 was there any training or continuing professional development organized by ryden

00:33:59 ryden in the aftermath of the latino house fire do you remember not aware of now that was 2009. were you aware that there had been a a spate of fires in high-rise buildings

00:34:10 a spate of fires in high-rise buildings in the uae in 2012 and 13. no i wasn't away or a fire in france in ruby in france in 2012. no

00:34:23 ruby in france in 2012. no no

00:34:26 and do i take it from that you were also unaware of the history of high-rise fires in the uk stretching back to 1991 noseley heights 1999

00:34:37 1999 gone at court none of them are none of them ring a bell to me at all right you've heard of them since have you them two you just mentioned no right okay um

00:34:50 i want to ask you about panels and see how much you knew at the time about that at the time of the project and your involvement in it did you did you know that

00:34:57 that the fire performance of acm polyethylene panels

00:35:01 panels when made into cassettes performed significantly worse than the fire performance of panels in the flat sheet riveted

00:35:10 i want to get back to your contractual obligations or rather ryden's contractual obligations we touched on this earlier on i think you've said you'd had very little familiarity of that

00:35:23 very little familiarity of that looking at your role as project manager leading the on-site team do you accept that you had to be at least familiar

00:35:30 familiar with the main contractual obligations that ryden owed to its client

00:35:36 oh well i wouldn't say i would need to be familiar with it my role was on site health and safety you know sequencing coordinating i wouldn't be quoting the contract to anybody right you wouldn't be quoting the contract to

00:35:48 you wouldn't be quoting the contract to anybody i quite understand but would you want to make sure that you knew at least an outline what ryden had promised its client it would do by way of this refurbishment

00:35:59 by way of this refurbishment i probably should have done yes but you didn't right was the contract physically held on site in one of the site offices i couldn't

00:36:10 in one of the site offices i couldn't tell you

00:36:10 tell you i don't recall it being on site but right

00:36:18 so so during your time on site did no occasion arise when you thought you needed to look at the contract to make sure whether you had to do something or didn't have to do something i would ask

00:36:31 to do something i would ask simon lawrence steve blake i wouldn't ever refer to the contract myself right can you remember any occasion when you did ask steve blake or simon lawrence about what the contract said you had to do or didn't have to do

00:36:43 you had to do or didn't have to do i don't recall all right

00:36:46 did you understand that

00:36:50 as the design and build contractor ryden as a company retained ultimate responsibility for the design of the grenfell tower refurbishment and the works related to it

00:37:02 the works related to it at the time no i presume that was that responsibility would be passed on to designers

00:37:08 designers and architects i didn't believe that was devastated ryden at the time oh i see

00:37:17 so from that answer you say i presume at the time what was your understanding about ryden's responsibility sorry i don't understand

00:37:30 responsibility sorry i don't understand well you said in the last answer but one i presume that responsibility would be passed on to the designers and architects i don't believe that stayed with ryden at the time so at the time was your understanding

00:37:41 so at the time was your understanding that ryden actually had no responsibility at all because it had appointed subcontractors i wouldn't said that it had no responsibility at all but i thought that that responsibility was shared

00:37:53 that responsibility was shared throughout the especially subcontractors um to be compliant with with what it needed to be compliant with right so was it so would it follow from that that you didn't think at the time

00:38:05 that that you didn't think at the time that if the subcontractors had done something wrong nonetheless ryden would be responsible to the tma for the error i suppose as the principal contractor probably yes right did you understand that ryden was

00:38:18 right did you understand that ryden was responsible for carrying out and completing the works in a proper and workmanlike manner

00:38:25 yes and did you understand that ryden was responsible for carrying out and completing the works in accordance with statutory requirements yes

00:38:36 with statutory requirements yes and in accordance with good building practice

00:38:39 practice i think that that forms part of the statutory requirements isn't it now you were responsible for monitoring the inspection process i think so uh

00:38:51 you did you know at the time that there were various bodies within the construction industry produced which produced guides to establishing good practice good building practice i would have been

00:39:03 good building practice i would have been aware

00:39:06 yes did you read any of those guides well you were familiar with them not that recall right

00:39:16 now statutory requirements would include the building regulations wouldn't it yes so did you understand at the time that

00:39:25 that ryden was fully responsible in all aspects for the design of the works probably not i thought that would be you know did specialist designers to ensure that all of the drawings and

00:39:37 to ensure that all of the drawings and designs they put forward comply with the legislation at that time

00:39:46 and what was ryden's role in that do you remember ryden's role in what sorry in ensuring that all of the drawings and designs that these specialist designers put forward complied with the legislation

00:39:58 forward complied with the legislation um i would presume that would be part of the the contract between the designers and the architects and everyone else i i would imagine there'll be a line in there to say all your designs must

00:40:09 there to say all your designs must comply with x y and z right

00:40:18 now can i take you to your witness statement paragraph 14.

00:40:29 now you say that

00:40:33 that there were design team meetings throughout my time working on the project i would be present

00:40:40 present for most of these meetings but not all of them so that i was aware of any discussions taking place from a logistics programming and progress perspective and so that i as project manager i could make things sure things were happening

00:40:51 make things sure things were happening at the right time on site i read that to you earlier on uh slightly different question did you yourself ever investigate whether ryden was complying with those obligations

00:41:03 was complying with those obligations with the obligations we've discussed i didn't

00:41:07 didn't do you remember or no whether any other employee of ryden involved with this project

00:41:11 project uh was investigating whether ryden was complete complying with those obligations i don't know

00:41:23 i'm going to ask you a number of questions about the advocacy of drawings but i suspect these won't be very long questions

00:41:31 questions when uh stu when uh ryden came into the project in the spring of 2014 uh and i know you joined the project in

00:41:42 uh and i know you joined the project in the may of that year and just for your benefit the uh tender had been successful and ryden had been notified in the middle of march 2014

00:41:53 middle of march 2014 and then the contract terms began to be discussed in the april of 2014. that's the background when you came into the project what stage did you believe design had reached

00:42:05 of of the whole refurbishment or just just the external the whole of the refurbishment um 60-70 percent right in in are you able to tell us what that is in

00:42:17 are you able to tell us what that is in our iba terms what stage stage cdf are you familiar with those are aba stages no right

00:42:28 now at paragraph 13 of the statement your statement if you can go uh back a little bit please you you say there

00:42:36 there in the first sentence by the time ryden became involved in the project the design by kctmo and studio e was at an advanced stage now

00:42:48 when you came into the project had you seen or did you see any one to five scale drawings

00:42:57 there are a number of drawings yes

00:43:02 yes uh did you see any one to five scale drawings

00:43:06 drawings i can't remember the scale surprised do you remember seeing any let me put this way

00:43:13 this way big detailed drawings produced by studio e

00:43:17 e showing for example the details of cavity barriers around the windows i don't specifically remember seeing them uh what is the basis for your saying

00:43:30 uh what is the basis for your saying that when ryden became involved in the project the design was at an advanced

00:43:35 advanced stage what gave you to think that the design wasn't at an advanced stage because the majority of the work for me would have been the

00:43:43 been the you know the external i i overcloud which i believe had already been decided as to what it would be

00:43:50 would be it was just basically a color and vixens point of view and i believe that js wright were working on design that's why i said

00:43:57 i said 60 70 sent through which i think is quite an advanced stage

00:44:06 right

00:44:10 did you think that the drawings you saw at that stage was sufficient for you to be able to progress or coordinate the progression of the works

00:44:21 the progression of the works on site um i don't recall do you ever recall thinking that the designs were inadequate for your purposes

00:44:34 no i don't recall that either you never had an occasion to wonder about whether the drawings actually helped you or not i mean if there was glaringly obvious

00:44:45 i mean if there was glaringly obvious things missing from the drawing then yes but um no other than that do you remember any occasion when you did see something that to your eyes was glaringly obviously missing from a

00:44:56 glaringly obviously missing from a drawing

00:44:56 drawing um i think there was once a door missing from a room right if i'm honest that was that was it right and what do you say glaringly

00:45:07 right and what do you say glaringly obvious is that an example of the kind of thing you you mean yeah right

00:45:14 i mean is the reality mr o'connor that you weren't sufficiently qualified to assess what stage the design had reached or to notice any material or important emissions other than those that are glaringly obvious in

00:45:26 than those that are glaringly obvious in the way you described yes can i then talk about i'll ask you about workmanship were you familiar with ryden's con even in outline ryden's contractual obligations relating to workmanship and materials

00:45:39 materials in what manner well i don't want to go back to the contract but um were you aware that ryden was obliged

00:45:48 obliged and for our purposes this is clause 2.2.1

00:45:51 2.2.1 to make sure that all materials goods and workmanship used in the execution of the works shall be of such kind and of such quality as are unnecessary to enable the contractor to comply with his obligation under this contract

00:46:03 under this contract i know that's a bit of legalese but were you aware

00:46:06 you aware at least in outline that that was an obligation ryden has had assumed to the tmo i wasn't aware of that

00:46:13 that clause or that wording um workmanship to me is

00:46:17 me is you know finishes and making sure it's done in line with the drawings not i don't recall that contract clause at all what was your understanding about whether ryden could make substitution

00:46:29 whether ryden could make substitution for any materials or goods or workmanship which had been set out in the employer's requirements i think that made back to studio e

00:46:37 studio e if there was going to be some sort of change right mtmo

00:46:45 so in outline can we take it as far as you understood any substitution of materials goods or workmanship could only happen with the permission of studio e into the tmo yes i don't know if it works in your mouth but i'm just

00:46:56 if it works in your mouth but i'm just trying to

00:46:57 trying to just clarify or crystallize your answer i see

00:47:03 so far as you are aware what system was in place

00:47:06 in place within ryden to make sure um that any substitution that i've just asked you about

00:47:14 you about happened so that the tmo and studio e knew about it and could give their consent maybe there was a change tracker right

00:47:26 did you yourself uh put in place or or did you know that there was in place any system for monitoring whether materials were being substituted in the order chain or on site no

00:47:41 did was there a process in place for obtaining the consent from the tmo for materials substitution that would again be the change tracker imagine right

00:47:52 imagine right was there a system in place for checking that any new materials complied with the statutory requirements when i say new i mean substituted materials complied with the statutory requirements i would envisage that to be something that studio e would have looked at

00:48:05 that studio e would have looked at when we when a new material was put forward but that's not something you looked at

00:48:09 looked at it's not something i looked at now was there a system that you knew of that whereby it could be checked where the building control were kept

00:48:18 were kept informed of changes to material onsite i don't recall they may have been sent the change tracker by simon i don't recall you don't know

00:48:29 recall you don't know can i ask you this who was responsible for checking materials coming onto the site it would have been the subcontractors so they ordered their own materials it would have been brought in through

00:48:40 would have been brought in through through the rear gate um by one when the marshals yeah but if if you're asking if one of the managers was there to sign it off as it come in no yeah well

00:48:51 sign it off as it come in no yeah well that is what i was asking because what was going through my mind was um

00:48:56 was um if a lorry load of the substitute material came in who would be aware of that and who would control it but your answer i think is it would be the subcontractor yes thank

00:49:07 it would be the subcontractor yes thank you

00:49:12 does that tell us that even though the subcontractors would know that a lorry load of substitute material had come in there was no system for them reporting that to the ryden site managers and from them

00:49:24 to the ryden site managers and from them to you i don't believe there's a system in place but they would as i've understood it they were tried and tested trusted subcontractors so if there was going to be a change then it would have

00:49:35 going to be a change then it would have been discussed with simon studio and the cmo

00:49:42 yes um really what i'm trying to get at just to pursue the the chairman's question a bit is is whether there was a is how high uh within the ryden uh chain of command

00:49:53 uh within the ryden uh chain of command knowledge of what was coming onto site through the rear gates went but i think you're telling us it didn't come as high as you not generally no i mean i wouldn't be there to to you

00:50:04 i mean i wouldn't be there to to you know just for someone to say i would just have a loyalty to this turn up um right that wasn't my my role right

00:50:15 uh i'd like to ask you some questions about the employer's requirements and to begin with the preliminaries can i

00:50:23 i ask you just in general terms were you familiar with at least in passing with the employer's requirements for this project imparting yes and passing

00:50:34 and is it fair to say that it was your role as project manager to coordinate the works

00:50:39 the works yes yes can i ask you to look at tmo one double zero four one seven nine one please

00:50:51 and go to page one two eight in that this is part of i should just tell you mr o'connor the contract the formal contract and you can see page one of this document uh on the screen i think we've

00:51:03 uh on the screen i think we've there it is we went past it but there it is

00:51:07 is just looking at it now is this the document you've ever seen before do you think

00:51:13 it doesn't look familiar no no and that's

00:51:16 that's really what you told us earlier in your evidence but let's just look if we can see

00:51:21 see page one two eight and see if this is something you saw at the time this is the section of the preliminaries entitled a32 management of the works

00:51:34 did you at the time familiarize yourself with the requirements set out there and particularly paragraph 110 supervision

00:51:48 i don't i don't recall if i read this or not right

00:51:51 not right let's just see if it jog's a memory uh i mean you could see that it's 128 pages into a pretty dense legal document and it's entitled supervision general accept responsibility for coordination

00:52:03 accept responsibility for coordination supervision and administration of the works including subcontracts coordination arrange and monitor a program with each subcontractor supplier local authority and statutory undertaker and obtain and supply information as

00:52:15 and obtain and supply information as necessary for coordination of the work uh that was ryden's obligation to the tmo

00:52:24 tmo can you can you confirm that it was your responsibility within the chain of command at ryden to ensure that ryden complied with it

00:52:36 yes can you tell us what you did to arrange and monitor a program with each subcontractor supplier local authority and statutory undertaker

00:52:47 authority and statutory undertaker you can see in the second bullet point i wouldn't have particularly dealt with the local authority um i'm not sure what a statutory undertaker is somebody supplies water or gas all right so

00:52:58 so okay fine um yes i i wouldn't i would have dealt with them um i would have arranged and monitored the program um and i would have pretty coordinated

00:53:11 um and i would have pretty coordinated the subcontractors yes right so when you say you would have arranged and monitored a program with each subcontractor how did you go about that we would sit down with

00:53:22 down with subcontractor and development manager

00:53:27 and an agree a monthly or weekly meeting i wouldn't particularly go to these um it was to monitor sort of their their progress against program um and ask them to put it in sort of

00:53:41 um and ask them to put it in sort of almost like a mini report to us right and you can see in the bullet second bullet point it says uh that part of your job was to obtain and supply information

00:53:52 and supply information as necessary for coordination of the work

00:53:56 work what did you do to do that

00:54:00 i would get the drawings and pass them on to the relevant managers right what about information relation relating to materials that would be on the drawing

00:54:12 were you only reliant on the drawing to find out

00:54:15 find out what materials had to go onto the building when you were obtaining and supplying information as necessary for coordination of the world i think most people had a copy of the end is it the mbs spec

00:54:26 end is it the mbs spec i recall i think most people would have a copy of that on their computer so if there was any queries that you can go to that right well we're going to come to the nbs spec in due course

00:54:37 in due course but i know the answer if you uh look at the foot of the page 119b building control the contractor will be responsible for providing additional

00:54:48 responsible for providing additional construction stage information to building control that yep um did you appreciate at the time that that was a part of something you were responsible for no

00:54:59 for no right

00:55:04 was there any process in place as far as you knew

00:55:07 you knew to make sure ryden had possession of any or all

00:55:11 or all additional construction stage information so that it could be passed on to building control i believe that was being done by um studio e

00:55:19 studio e simon lawrence

00:55:23 uh right so it wouldn't wouldn't pass through your hands it might it might pass through my hands in a cc on an email but it's not something that i i don't recall ever sending that

00:55:35 i don't recall ever sending that building control construction stage information right uh can we look at page 135 of the same document please this is the section uh a33 entitled quality stroke standards

00:55:47 entitled quality stroke standards control

00:55:55 and

00:55:58 if you look at paragraph 170a two-thirds of the way down the page manufacturer's recommendations and instructions and there it says general comply with the manufacturer's printed recommendations and instructions current

00:56:10 recommendations and instructions current on the date of the invitation to tender changes to recommendations or instructions submit details ancillary products and accessories use they supplied or recommended by main product manufacturer agreement certified products comply with

00:56:21 agreement certified products comply with limitations recommendations and requirements of relevant valid certificates can you tell us what systems ryden had in place to make sure that ryden's employees such as yourself

00:56:32 that ryden's employees such as yourself and

00:56:33 and your site managers and the subcontractors were aware of the manufacturer's printed recommendations and instructions i wouldn't be able to tell you that we we we relied on

00:56:46 we we relied on like i've said before this specialists the architects to to ensure that whatever they're putting forward right is in line with that i see so would it follow from that that you

00:56:57 so would it follow from that that you also had no well you can't help us as to whether there was in place a system for making sure that ryden employees and subcontractors complied with manufacturers printed instructions

00:57:08 with manufacturers printed instructions and

00:57:08 and recommendations i can't guarantee that no no

00:57:12 no no um if we look on page 139 please let's look at paragraph 510

00:57:18 supervision this is under the title supervision stroke inspection stroke defective work that fell within your remit didn't it yes and you can see it says general in

00:57:30 yes and you can see it says general in addition to the constant management and supervision of the works provided by the contractor's person in charge all significant types of work must be under the control of competent trade supervisors

00:57:42 control of competent trade supervisors to ensure maintenance of satisfactory quality and progress replacement give maximum possible notice before changing person in charge or site agent

00:57:50 agent now the contractors person in charge that we see there was was that the project manager are you the principal contractors that is that we're referring to

00:58:01 is that we're referring to well 510 i'm looking at 510 and the reference to the contractors person in charge it would have been me or simon yes i see did

00:58:12 did you understand that that role was occupied by you when you say it was me or simon do you mean you alternated in that role or that you're not sure whether the role was yours or his um

00:58:25 i think this role probably would have been passed on to a site manager because they were out on on the ground so to speak um checking quality alongside the clerk of

00:58:36 checking quality alongside the clerk of works

00:58:39 were there any processes in place at writing to make sure that significant types of work would be under the close control of competent uh trade supervisors there was competent trade supervisors for most of the

00:58:50 trade supervisors for most of the contractors yes what what do well what are competent trade supervisors what what who are they in this context um i think from memory we had ben bailey

00:59:02 um i think from memory we had ben bailey from harley am i okay naming these people

00:59:06 people yeah yes you can of course yes um so ben bailey from harley i don't remember richard from jsw

00:59:16 um

00:59:20 and i can't remember the name of the electrical taking ben bailey ben bailey was the younger bailey at harley wasn't he he was

00:59:26 he he was uh uh and in the role of a competent trade supervisor he would be essentially supervising the work of his own company wouldn't he yes how would that be proper and

00:59:37 yes how would that be proper and adequate supervision well we also had external managers as well right

00:59:44 okay uh did ryden and specifically you assess the competency of trade supervisors in this context

00:59:55 supervisors in this context no they would uh especially harley as far as i aware they've they've worked with ryden for a number of years and were

01:00:02 were considered competent at the time

01:00:06 you refer to external managers who are you referring to daniel osgood was one of them um he's a ryden employee isn't he yeah there was a few that come and come and come and go it was quiet

01:00:20 come and go it was quiet yes i understand that but to taking daniel is good as an example he's a ryden employee so are you saying that um by external uh managers those were

01:00:32 uh managers those were ryden people super being trade supervisors yeah so basically what would happen is um they would install a section of work it would then be snagged by them

01:00:43 snagged by them um and then it will be offered to a ryden supervisor or manager site site manager sorry um and then it would then be offered to the clerk of works for inspection prior to it being covered

01:00:55 for inspection prior to it being covered up or anything coming up i see can i ask you to look at page 141 and paragraph 630 in this same document

01:01:07 and paragraph 630 in this same document quality control you see that there and it says procedures establish and maintain

01:01:12 maintain to ensure that works including the work of subcontractors comply with specified requirements records maintain full records keep copies on site for inspection and submit copies on request

01:01:23 copies on request and then content of records and you can see the four bullet point requirements set out under there identification of the element item bachelor lot all including location nature and dates of inspections tests and approvals nature

01:01:34 inspections tests and approvals nature and extended non-conforming work found details of corrective action were there any procedures in place at ryden for establishing and maintaining uh a system where works complied with

01:01:49 uh a system where works complied with these

01:01:50 these specified requirements so the dates and the

01:01:54 the everything you've just read yes there was it would be on the rms system um and it would be just a log of when it was inspected by us when it was inspected by building control

01:02:05 was inspected by building control if there was any negative or positive comments from building control um and that that would have been kept on site

01:02:13 site what is the rms system rider management system

01:02:16 system was that an electronic database yes did you have it did you have access to that everyone did yeah right did you use it yes did you use it regularly yes

01:02:30 what did you do when using it there were sections in there that i needed to do on a daily basis um to keep the records up to date right i can't i can't recall exactly what they

01:02:41 i can't i can't recall exactly what they were it was a long time ago i see so what would you input into that system generally speaking um probably like a like a daily diary maybe

01:02:50 maybe um from my point of view um subcontractor performance maybe how many member on site for you know just it was general general data that i would be putting putting

01:03:01 data that i would be putting putting into there right

01:03:07 now can we leave this document and go to paragraph 20 of your witness statement

01:03:17 statement you say uh there that you you would and this is you say the process for the inspection of works was as follows ryden's site managers would be

01:03:29 ryden's site managers would be inspecting the area of work that they were responsible for on a daily basis and then you go on to give a bit of detail about what they did and then two-thirds of the way down that

01:03:40 two-thirds of the way down that paragraph you say i would try to do a couple of rounds of the site each day looking at the site in general checking progress overall the contractors working in the areas that they should be and looking out for any health and safety issues

01:03:52 any health and safety issues however as the project manager it was not part of my role to inspect in detail the work being carried out did you make any records of your inspections that you refer to there

01:04:06 i don't recall i know there was email sent after some of them because we had seen stuff that we wasn't happy with um but i wouldn't have come back and wrote a report each time i went out right i see did you keep a daily log or daily

01:04:18 i see did you keep a daily log or daily diary or diary or report of your own either yourself or on the rms system about what you did on your rounds there would have been a handwritten diary yes right a handwritten diary yeah okay

01:04:30 right a handwritten diary yeah okay do you know what happened to that it was on site when i left right

01:04:37 and was that a diary personal or private to you or was that a diary that was shared by others on site it was just it was just my diary for the day just so as i could record i think anything of importance

01:04:49 record i think anything of importance okay um still on the subject of inspections and quality control can i now turn to the nbs specification that you referred to before which we'll find at sea 50169

01:05:03 which we'll find at sea 50169 and i'd like to go within it to page 68 please

01:05:07 please this is section 892 this one is dated the 30th of uh january 2014. this is the last edition of it

01:05:14 of it um before ryden won the tender um just looking at the first page of this you can see it's nbs specification let's get back to that just jog the memory this is the document you were

01:05:25 memory this is the document you were referring to earlier can we go to page 68 then please which is section 892

01:05:33 under general requirements straight preparatory work uh and um you can see the the very bottom of the page this is h92 rain screen cladding yes

01:05:46 yep this is part of the mbs spec that deals with rain screen cladding now you can see at paragraph 232 at the bottom quality plan

01:05:58 bottom quality plan requirement submit during detailed design

01:06:01 design content in accordance with bsen iso 9001 and including the following and you've got the name of the quality manager quality assessment procedures and inspection procedures to be adopted

01:06:14 and inspection procedures to be adopted in checking the work and then if you go a little bit further down to the second from one entry at the bottom

01:06:21 bottom certification that completed work complied with the specification you see that i do

01:06:28 that i do did those things full within your responsibility as project manager i don't believe so whose responsibility or whose remit did

01:06:39 whose responsibility or whose remit did they fall within i think there would be various um

01:06:50 so there's things like procedure for registering and reporting non-compliances that could be any of the managers

01:06:57 managing procedures and calibration records again that could be any other managers

01:07:01 managers right um

01:07:05 statistication that completely works for club specification um i've not seen a certificate like that right okay were you familiar at the time with bsen

01:07:16 at the time with bsen iso 9001 at the time now

01:07:22 it says their name of the quality manager who was or who were the quality manager or managers quality managers would have been in someone from the office that would come down and audit audit the site i see someone from the

01:07:34 audit the site i see someone from the office

01:07:35 office during your time do you remember who that was i want to say barry rutley

01:07:41 okay and how often did barry come down to audit the site

01:07:48 i couldn't be sure it it might have been monthly it may have been bi-monthly do you know what he did um he would come to site with a template check sheet which he needed to go

01:07:59 check sheet which he needed to go through

01:08:00 through which i think went through the drawings as long as we had all the rams for the um subcontractors they were up to date i think he would check the yeah the electoral certificates and

01:08:12 the yeah the electoral certificates and stuff like that um right but i don't recall much more than that

01:08:19 did he look at individual instances of workmanship or was he auditing the records

01:08:23 records he was always in the records so he didn't go and look at anything physical on the side he would have done just for his own knowledge but he wouldn't i don't think he would have commented on it what was he looking for do you know um i think it's just just to see the

01:08:34 um i think it's just just to see the progress really i see so right i see um was it your job to ensure that quality assessment procedures were put

01:08:45 quality assessment procedures were put in place in accordance with en iso 9001 uh but we did have quality quality assurance in there but i wouldn't i wouldn't know if it would be in line with bsen

01:08:55 with bsen no but was it your job to ensure even if you didn't know about bsen uh was it your job to ensure that quality assessment procedures were in place for the project yes yes i see uh was it your job to

01:09:07 yes yes i see uh was it your job to check that those quality assessment procedures were carried out yes essentially yes yeah and carried out adequately well i mean i i would go on what

01:09:18 well i mean i i would go on what you know managers would take to do clarke works or building control whoever out

01:09:23 out they would come back with a report and i would have a chat with the relevant person when they come back to the office um and then that would be noted

01:09:34 and then that would be noted you know um in a relevant place i see it was it your job to ensure that proper inspection procedures were in place

01:09:43 place um it wouldn't be my job directly it would be stupid it'd be someone that i would

01:09:48 would if if it's an external manager then there would be a procedure in place for inspecting the externals it wouldn't be me doing it would you be you supervising those inspections i'll be overseeing the people doing them yes right

01:10:01 yes right you say external manager do you know who the external manager was who was responsible for the inspection for establishing the inspection procedures to be adopted and checking the work

01:10:11 the work at the time it would have been daniel's good daniel i was good so just just so i'm completely clear on your answer if you look back at the document 232 quality plan third bullet point down inspection procedures to be adopted and

01:10:23 inspection procedures to be adopted and checking the work who who was it who established those inspection procedures well i i would have sat down with the subcontractor and the relevant manager and i had put a plan forward

01:10:34 and i had put a plan forward i you know inspecting the every week or every few days or whatever it would have been required did you ever give any written

01:10:46 did you ever give any written instructions to site managers in relation to inspection of the works i did yes you did

01:10:52 did and how were those written instructions they were minuted um it was it was a meeting on the externals with harley and i requested um

01:11:03 harley and i requested um marked up elevations on a weekly basis to go to the relevant manager marked up by whom marked up by harley

01:11:14 what kind of markup what do you say elevations um you mean do you mean drawings yeah

01:11:24 so marked up what sort of markups would harley put on the drawings on a weekly basis i would color code where where they'd been and each color would have a different um

01:11:35 and each color would have a different um color blind so you know but each color would be like you know

01:11:40 you know insulation was on here or rails were on here or brackets were on there right so the marked up elevations were it sounds as if you're what you're telling us is that the markup marked up

01:11:51 telling us is that the markup marked up elevations that harley produce we're about progress rather than about the design itself yes so did you ever see any marked up drawings

01:12:00 drawings where design was changed no right not a recall i see did you produce a method statement on inspection of the works

01:12:14 not a method statement no it's not something we ever did did you give any training to site managers who are reporting to you uh about how they should go about

01:12:25 uh about how they should go about inspecting any part of the works not not actual training i'm not qualified to train people how to inspect stuff i mean they've been with a majority of people there other than i

01:12:36 a majority of people there other than i think the two people we mentioned have been with the company for a while

01:12:42 can you look at paragraph 21 of your witness statement please so we just go back to that this is a page 10

01:12:49 page 10 you say there was also a system for inspecting works on completion of a particular section

01:12:57 in relation to the external cladding works for example completed areas of substructure would be inspected before the installation of the cladding the subcontractors supervisor would first inspect their work against the relevant drawings before it was handed over to

01:13:08 drawings before it was handed over to ryden's site managers see that there yep the sub the i was not involved

01:13:14 involved in the inspections myself but i know from my time as site manager that the ryden site managers also would also inspect the subcontractors work using the relevant specifications and

01:13:25 the relevant specifications and drawings just pausing there is it fair to say that your understanding was that all works would be inspected by subcontractors under their internal processes

01:13:33 processes after it was completed at the relevant stages not after it was completed okay and and then at those relevant stages ryden would then conduct its own inspection

01:13:45 inspection yes yes and then building control and the clerk of works would be offered to come and inspect that work as well yes

01:13:53 well yes and just to confirm you what you say in the second line at the top of page 11 the checks were made against the relevant specifications and drawings yes generally yes to what extent were you involved yourself

01:14:05 extent were you involved yourself in remedying workmanship issues which might arise from those inspections uh i wouldn't have been involved particularly unless it become a problem um them inspections our comments would

01:14:16 um them inspections our comments would go back to the um relevant subcontractors and they would be asked to resubmit the inspection once they completed the works i.e the stuff that needed to be

01:14:28 i.e the stuff that needed to be put right i followed and and

01:14:34 i see when we talk about the drawings here

01:14:41 uh are we talking about the as built drawings issued by studio e after revisions from the design team or other drawings they wouldn't be as built going to get them at the end um it'll be construction drawings construction drawings

01:15:02 and is it right that the relevant drawing to be used by whoever was undertaking the inspection would be identified by a unique number given to each each drawing yes

01:15:13 number given to each each drawing yes right and probably checked with the drawing registers as well prior to going out which drawing register the drawing registers that were in the files who was responsible for compiling and

01:15:25 who was responsible for compiling and maintaining the drawing register and what was in your files simon lawrence i see

01:15:33 during your time on the project was there always a drawing register that you've just referred to yeah do you know when it was first established i don't it would have been pre-me because i

01:15:44 pre-me because i think um studio e obviously started the process of drawings and drawing registers

01:15:49 registers um alongside the original contractors so yes mr chairman it's 11 15 and i've got about

01:15:56 about four questions left on this topic well why don't you finish them and we'll break then very good mr lawrence

01:16:02 lawrence uh mr o'connor i'm so sorry mr o'connor can i just ask you to go back to paragraph 21 where you say in the third line if anything was snagged during this

01:16:14 anything was snagged during this inspection it would be de-snagged and then re-inspected before the work was handed over to the clerk of works

01:16:19 works to inspect on behalf of kctmo as far as i'm aware the clerk of works followed exactly the same process of comparing the works with the drawings and specifications if anything was snagged by the clerk of

01:16:30 if anything was snagged by the clerk of the clerks of works ryden would ask the relevant subcontractor to rectify it the clerks of works would then either reinspect the work or ask for the photographic evidence to show what had been done in the light of that

01:16:44 what had been done in the light of that statement is it fair to say that it was your understanding at the time that quality inspections beyond those undertaken by the subcontractor during the initial construction such as by the clerk of works

01:16:56 by the clerk of works were also conducted against drawings yes which drawings were they the as built drawings or were they drawings at an earlier stage construction drawings construction

01:17:07 construction drawings construction drawings

01:17:09 drawings and just to say that we're clear the construction drawings are those the ones marked

01:17:13 marked uh approved for construction by harley when we're looking at the external cladding at least yeah i mean i would expect to see it stamped by studio e as well yeah can i

01:17:26 as well yeah can i then just ask you to look at a witness statement of jason north and before i do just get you to confirm jason north was a site manager working

01:17:36 working for ryden on the grenfell tower project wasn't he he was uh and was he answerable to you he was he was this is ryd ryd3094233

01:17:50 this is the first page of his statement i'd like you to go to the second page of his statement please and paragraph 13 within it

01:17:57 within it and he says there the contractors undertook

01:18:00 undertook the work my role was to ensure that they did it on time to budget and safely there was a quality control system in place once the work was complete the formal of the contractor checked for snags and

01:18:11 the contractor checked for snags and remedied these then the work was handed to me and i checked for further snags which were remedied by the contractor if identified the clerk of works then checked the work and lastly building control carried out its own inspections where required

01:18:23 its own inspections where required mychexi also included checking health and safety and that the work adhered to the drawings does that accord with your understanding of how ryden's site managers conducted

01:18:34 of how ryden's site managers conducted quality inspections of the works yes yes thank you uh mr o'connor i'm going to ask the chairman if we can take the break now yes that a convenient thought yes thank you we're going to have a break now mr

01:18:46 you we're going to have a break now mr o'connor

01:18:47 o'connor thank you um and i'm going to ask you to go with the usher in just a moment before you do that can i just say please don't talk to anyone about your evidence while you're out of the room yeah no worries all right thank you we'd like to go we'll come back at

01:18:59 like to go we'll come back at 25 to 12. thank you very much

01:19:11 good thank you 25 to 12.

01:37:10 yes would you ask mr o'connor to come back please thank you

01:37:27 [Music]

01:37:32 ready to carry on mr o'connor yes good thank you very much yes sir thank you mr chairman mr o'connor you told us this morning earlier that you are responsible for health and safety on site is that right that's correct yes um

01:37:46 is that right that's correct yes um how could you ensure health and safety on site

01:37:49 on site if you did not know yourself what by way of materials was being delivered to sight at any given time that's not really relevant to health and safety as in my my role in health and

01:38:01 safety as in my my role in health and safety was is you know is the work being carried out in a safe manner you know are they doing what they support what's in their risk assessment method statements um that was my sort of role in health and safety

01:38:12 and safety was your role in health and safety uh not

01:38:15 not also to include ensuring that there were no dangerous materials stored on site i wouldn't say so now

01:38:24 so now right how if you were responsible for health and safety on site were you to discharge that function carry out that role if you didn't know whether there were or weren't any dangerous materials on site

01:38:36 weren't any dangerous materials on site um like i said my my role was around the construction work not you know um what was coming on to site as far as i knew we had no dangerous materials on site how could you be sure that suppliers

01:38:48 how could you be sure that suppliers were supplying material that did not present

01:38:51 present an unreasonable health and safety risk sorry i don't understand that question if you were responsible for health and safety

01:38:57 safety on the site but you didn't know what was coming onto site how could you be sure that suppliers were supplying materials to site that did not present

01:39:09 to site that did not present a health and safety risk um because i would presume that that would be that risk would have been taken out during the design stage

01:39:18 so i don't i don't really understand your question particularly so you assumed that everything being delivered to site was safe

01:39:28 yeah right now i think you said that you didn't do a method statement to be clear is that does that mean that you didn't do a risk assessment method statement

01:39:37 statement rams for the site no there was one done for the site it wasn't one what i said was there wasn't one done for the inspection process i see forgive me there wasn't done one done for the inspection process but you said

01:39:49 for the inspection process but you said there was one done for the site yeah yes i see paragraph 13 of your statement i think you said we don't need to go to it unless you want to that you believe

01:39:57 believe the specialist subcontractors engaged by ryden who designed the works would have been selected for the project from an approved list held by ryden is that right yes

01:40:08 held by ryden is that right yes and i think your understanding was that the subcontractors had to be vetted first before being added to the approved subcontractor list yes that's right is it

01:40:15 it yes now i don't think you've shown us the approved list is there an actual list written document yes right and you were familiar with it

01:40:27 yes right and you were familiar with it at the time were you yeah i would have been here do you know where it was held in ryden would have been on on the rms right

01:40:40 did you yourself personally check that any of the subcontractors used for the grenfell tower project were on the approved list no that would have been done by the surveyor prior to them being engaged the surveyor being who

01:40:52 being engaged the surveyor being who uh adam marriott zach maynard i think there was one other as well i can't remember the name you said zach maynard adam zach maynard there was a few

01:41:04 there was a few right so when you came into the project did you ask either adam marriott or zach maynard or this third person or fourth person perhaps whether they

01:41:15 or fourth person perhaps whether they had checked that the subcontractors being used for this project were on the approved list i hadn't but i knew that js wright and harley's had worked for ryden on a number of occasions right

01:41:28 i think you've referred to a vetting process

01:41:32 process what was the vetting process what did that involve do you know i don't know right

01:41:40 did you yourself take any steps to check and ensure that each of the subcontractors that was chosen by harley to work on this project were competent and suitable for the work that they were to carry out

01:41:51 for the work that they were to carry out chosen by harley sorry yeah chosen by by ryden

01:41:55 ryden i'm sorry you're right i said chosen by harley i meant chosen by ryden i'm sorry no no

01:42:03 would it follow that you and indeed ryden didn't take steps to check and make sure that each subcontractor or sub-consultant was actually carrying out their obligations fully properly and competently

01:42:18 obligations in in what sense are obligations under the contract that each subcontractor and sub-consultant had with writing um i would imagine that they would have been

01:42:28 been that's why we was doing our checks um

01:42:33 so the inspection process is yeah i see can i then ask you to go back to the nvs specification uh sea 50169 and go to page 69 this time

01:42:47 sea 50169 and go to page 69 this time this is the nbs specification part dealing with the rain screen h92 mr o'connor and let's look together at paragraph 235

01:42:58 and let's look together at paragraph 235 at the top of the page information to be provided mr i'm not sure this is part of the rain screen cladding i think that may be um

01:43:09 a heading which goes on to the next page now we've gone on to the next page now have we uh it should be page 69 mr chairman

01:43:16 chairman yes right thank you um so just to be clear h92 i get from the bottom of the page mr o'connor rain screen cladding uh and it starts some pages earlier two three five information to be

01:43:27 two three five information to be provided uh and it then says under that submit the following cladding particulars and there are six bullet points detailed drawings to fully describe

01:43:38 detailed drawings to fully describe fabrication and installation detailed calculations to provide compliance with design straight performance requirements project specification project specific fabrication handling and installation method statements

01:43:50 method statements certification for incorporated components manufactured by others confirming their suitability for proposed locations in the rain screen cladding

01:43:58 cladding recommendations for spare parts for future repairs or replacements recommendations for safe dismantling and recycling or disposal of products

01:44:08 now i've read those all out to you

01:44:11 what processes were in place as far as you

01:44:15 you understood at the time to make sure that ryden gathered each of those elements of required information and passed those to the tmo

01:44:27 i wouldn't i wouldn't know that wouldn't be part of my process wouldn't be part of yours your process who within ryden would that fall to that would probably fall to

01:44:38 fall to steve blake simon lawrence someone that was part of the design intent

01:44:47 were you ever asked to provide or obtain detailed drawings to fully describe fabrication and installation i don't believe so were you ever asked to provide any of this information

01:45:00 to provide any of this information i don't believe so

01:45:04 let's look lower down the page together paragraph 342 contractors design of rain screen generally

01:45:14 and if we look at the second bullet point it says design standard to cwct standard for systemized building envelopes

01:45:22 envelopes structural and fire requirements and then they're set out there and then underneath that design complete the dissolves the third bullet point there design complete the

01:45:33 bullet point there design complete the design in accordance with the designated code of practice to satisfy specified performance criteria and then functional requirements as specified in this section with fire stopping to the requirements of the building regulations

01:45:47 requirements of the building regulations now did you read that paragraph in the nbs spec

01:45:51 nbs spec at the time do you think i don't recall

01:45:57 you don't recall okay do you uh recall seeing at the time any mention of the cwct standard for systemized

01:46:08 of the cwct standard for systemized building envelopes no at the time do you think had you ever heard of the cwct standard for systemized building envelopes at the time no

01:46:19 envelopes at the time no time no so can we take it that you wouldn't have read it no and you wouldn't be familiar with any of its details right so had you worked on any other project where the cwtc standard had been a

01:46:30 where the cwtc standard had been a contractual standard for cladding not i'm aware of no that was my first clutching project what about childcare i had nothing to do with cloud and charcoals right

01:46:41 with cloud and charcoals right you saw you said that earlier but but you do you remember you don't remember any reference at all to cwct on child cuts

01:46:48 cuts no

01:46:49 no [Applause]

01:46:53 now

01:46:56 i'd just like to ask you then about building regulations

01:47:03 as we can see um there there's a reference to the building regulations i know you didn't read this but at the time and in general terms as of may 2014 were you familiar with the building regulations

01:47:15 with the building regulations no i was aware they were there but i wasn't familiar in detail now you weren't familiar in detail let's see how far your familiarity extends were you familiar with schedule one to the building

01:47:26 with schedule one to the building regulations and something called the functional requirements no no so you didn't know about b fire safety no at the time no no

01:47:40 was there any system in ryden to educate project managers about the requirements of the building regulations

01:47:51 regulations i don't believe so right

01:48:02 the next question i i suspect will be an obvious one but i feel i do have to ask you

01:48:07 you were you familiar at the time with approved document b no that's forming part of the building

01:48:16 regulations

01:48:24 were you aware of the existence of any industry

01:48:28 industry guidance about uh external wall construction such as and i'll just give you one or two examples the building control alliance's technical guidance note 18 from june

01:48:39 technical guidance note 18 from june 2014 and

01:48:41 2014 and june 2015.

01:48:44 and what about uh uh the um uh right all right well let's ask then some questions to look together at the

01:48:55 some questions to look together at the question of fire risk assessment i'd like you to go to ryd3094213

01:49:05 this is mr hughes's witness statement david hughes he's coming to give evidence to the inquiry next week i just want to ask you about one paragraph

01:49:14 paragraph this is paragraph 106 please page 24.

01:49:27 uh he says here project fire risk assessments fras are part of ryden group safety health environmental and quality

01:49:39 safety health environmental and quality sheq

01:49:40 sheq procedures the original one would have been done by the project manager simon o'connor

01:49:45 o'connor at the start of the project on site its main focus is how to carry out the contracted works within the site residential properties communal and public spaces and comply with the current regulations it covers the scope of the works and

01:49:57 it covers the scope of the works and those that might be affected by those works including site visitors and residents i just want to focus on

01:50:04 focus on where he says comply with the current regulations as you can see there in the second from last sentence is what mr hughes says here a fair assessment of the purpose of project fras i wouldn't say it would

01:50:17 project fras i wouldn't say it would take into account the current regulations right so he's wrong about that is he i'm not saying he's wrong answer that i would i would view it differently what how would you

01:50:28 how would you view the scope of project fire risk assessments then in relation to current regulations so the project fire risk assessment that i did alongside simon camps

01:50:39 did alongside simon camps was for the bottom four floors of construction area

01:50:47 so you didn't you didn't do a project fire risk assessment for the upper floors there would have been overall one um which would be a template but that wouldn't take into account regulations that would take into account

01:51:01 regulations that would take into account resident interaction probably more than regulation i see and uh do you know who carried out that project fire risk assessment um probably myself and simon camps

01:51:12 um probably myself and simon camps i'm talking i'm sorry we may be at cross purposes i'm talking about um the fire project fire risk assessment for the rest of the building including the upper

01:51:19 the upper floors yeah it would have done by far imagine but they would have been separate documents it would have been done by they we would have done both i see but they would have been separate documents i see

01:51:30 documents i see that's some let's just see a document

01:51:36 ryd3032404 just so that we're clear this is a ryden project fire risk assessment dated february 2015

01:51:47 february 2015 and you can see from page one it says initial document completed by scsoc is that simon camps and you yes is this the document you're referring to do you think

01:51:58 referring to do you think this would probably be the overall one yes

01:52:02 yes let's go to page two

01:52:07 project fire risk assessment and we can see there in the first box responsible person named for the project contract manager or project manager

01:52:17 manager simon o'connor so you were the responsible person weren't you for this during the construction period yes and the risk assessor

01:52:25 assessor was simon camps yes yes february 2015 and now if we turn to page seven please let's look together with at um that and look at paragraph 4.2 or

01:52:37 that and look at paragraph 4.2 or section 4.2 under the heading rapid fire and smoke spread through the building or through building 4.2 says the occupied units within the

01:52:48 4.2 says the occupied units within the tower are rated to one hour fire protection existing fire stopping is in place where new penetrations are open they have fire stopping installed by the end of the shift

01:53:00 installed by the end of the shift does where permanent fire stopping is missing

01:53:04 missing ryden to inform the client immediately now the same words appear as you can see under 5.3

01:53:13 under 5.3 under the heading occupied premises and this is under the overall heading fire spread to adjacent properties do you see that yes so can we take it from this document that you

01:53:24 that you were aware of the need for fire stopping on the project i was aware that if we was drilling holes that go from the common parts into the into the flats which we was they needed to be fire stopped

01:53:35 to be fire stopped right did you let me ask you this way you see the word fire stopping had you heard of the expression cavity barriers yes yes did

01:53:46 expression cavity barriers yes yes did you know that did you know that there was a difference between or did you know there to be any difference between fire stopping and cavity barriers at the time i wouldn't have classed them i wouldn't have called them cavity

01:53:57 i wouldn't have called them cavity barriers

01:53:58 barriers um they were what it would be referred to as fire breaks fire breaks would there be a difference in your mind at the time between a fire stop and a fire break yes and what was the difference a fire

01:54:11 yes and what was the difference a fire stop was installed to small areas where um so pipes and stuff were cut through in from common parts into flats and that would be

01:54:21 would be i don't know some sort of rockwool intermission maybe um performed by a company that's qualified to do so

01:54:28 to do so um a fire stop or cavity barrier as we're calling them um would be externally i believe uh and what would fire back fire

01:54:39 uh and what would fire back fire barriers or cavity barriers before sorry what would be their role what would the cavity barriers roll apartmentation

01:54:51 barriers roll apartmentation yes now um can i ask you to go back to page three of this document and look at section three

01:55:05 section three uh this part of the fra requires you to assess

01:55:09 assess sources of fuel and oxygen doesn't it

01:55:14 yes now if we look at page five this is your assessment or yours or mr campsy's assessment of section three if we look under flammable solids

01:55:28 if we look under flammable solids you see flammable solids on the middle section in the middle section there you can see uh that building materials have not been ticked a number of things

01:55:40 have not been ticked a number of things have been ticked but building materials have not been ticked just the second from entry from the bottom there you see that yep um

01:55:52 is that how did you decide uh that no building materials presented a source of fuel i think the building materials that we was referring

01:56:03 building materials that we was referring to are bricks blocks concrete um things things like that i wouldn't consider them to be a source of fuel

01:56:12 of fuel no i just wonder what building materials means in this context does it not include

01:56:17 include the materials which are coming onto the building as part of the refurbishment

01:56:23 uh i i don't know did you think about that at the time no this would have been this would have been a point in time so i don't even know if there was materials on the site at that point i don't know

01:56:34 at that point i don't know this is february 2015 uh and whether the materials were yet on-site or not uh by this time we know that celetex

01:56:45 we know that celetex was coming onto site at some point to form the insulation in in the rain screen system and acm polyethylene core panels were coming onto site to form the

01:56:57 panels were coming onto site to form the rain screen as part of that system my question is that given that those were going to be coming on did you think at the time that they should be accounted for within the expression building materials

01:57:08 within the expression building materials when conducting this risk assessment i weren't aware at the time of their combustibility no but that wasn't my question the question was uh given that those materials were going to be coming on to the building

01:57:20 to be coming on to the building did you think at the time that they should be accounted for within building materials when doing your risk assessment um no i said i see this as a point in time

01:57:32 so when you say i see this as a point in time do you say i look at the building as it stands today and look at what building materials are on site well i think that's that's what this is this is a in at this moment is this is what the risks

01:57:45 at this moment is this is what the risks are and it gets introduced it gets upgraded as and when things move on so this is a snapshot is it

01:57:51 it has it that's the way i understand it so do we take it from that that you didn't at the time at least of this report think that the cladding materials coming onto site were not a source of fuel

01:58:01 fuel i didn't believe there was none right did you actually think about that at the time

01:58:06 time i don't recall it's all right

01:58:11 did you make any investigations either at this time or when this was later updated

01:58:16 updated to make sure that the building materials that did come onto site and particularly the insulation and the rain screen materials uh didn't present a source of fuel

01:58:27 uh didn't present a source of fuel i don't recall right how often was this document updated do you know i don't know i can't i'm not going to say a monthly i'm going to say a weekday

01:58:38 say a monthly i'm going to say a weekday i don't know you don't know

01:58:42 how much work went into producing a project fire risk assessment like this um a fair amount between me and simon what did you do to do it what the site

01:58:54 what did you do to do it what the site i see so you just tell me in terms of the process you walk around site with a clipboard and do you tick it off while you're you're going it looks like it's

01:59:03 it's it's done on a on a yeah we would have had an old template we probably would have this this would have just been a template

01:59:08 template um we would have had a hard copy with us and it would probably just be a tick exercise as you can see um and that's yeah that's that's kind of how it was put together

01:59:20 how it was put together right and when when asking the question what are building materials in that middle column there how do you work out what's on site so that you can tick or

01:59:31 tick or untick that box accordingly well we was walking around site so right

01:59:41 and if there was a material which comes onto site you didn't know never seen before or which wasn't commonly used such as acmp rain screen as you told us

01:59:53 such as acmp rain screen as you told us you didn't think was commonly used what would you do to satisfy yourself that it didn't present a source of fuel

02:00:04 it didn't present a source of fuel i don't recall to be honest all right i mean if you've presented with an assist a material you've never seen before and don't know what it is but you've got

02:00:15 don't know what it is but you've got your clipboard in front of you and you're trying to work out does this present a source of fuel how would you go about finding that out we're in hindsight you probably go and google it i can't say i did that right now

02:00:29 turning to a slightly different question uh can i ask you to turn to

02:00:38 seven four ryd3043746

02:00:46 this uh is an email from claire williams to you dated the 10th of april 2015. just wait for it to come up so we can see it together

02:01:00 let me let me try the number again ryd three zeros four three four seven six yes there it is claire williams 10th of

02:01:11 yes there it is claire williams 10th of june 2015

02:01:13 june 2015 1639 to you urgent urgent urgent grenfell fra outstanding items and she says

02:01:25 and she says and this is the second email down uh 17 19. uh

02:01:31 19. uh simon i've gone back through the list and need just a few more bits and if you look at the bottom of the page

02:01:39 under item five she says i would recommend that the contractor provides and then she sets out i think four things and they go over the page one the scope of works covering how this

02:01:50 one the scope of works covering how this cladding

02:01:52 cladding how will the cladding be fixed to the building

02:01:56 two what fixings will be used three the fire rating of the cladding and the fixings

02:02:02 fixings four the building control officer's acceptance of this fixing and the cladding used now we've been unable to locate any response to this request from you do you think you did respond uh i

02:02:14 do you think you did respond uh i probably would have forwarded this on to someone that could answer them questions well let's just go back to the first page and the email

02:02:25 after this see she sends you this email on the 10th of april the 10th of april 2015 at 1719 and then she sends an email on the 10th

02:02:37 and then she sends an email on the 10th of june

02:02:38 of june 2015 to you urgent urgent urgent simon i think you could polish this off quickly don't you see you at 9 30 tomorrow

02:02:47 tomorrow can you remember what happened between april 15 and june 15.

02:02:55 so as to ask so as to prompt her to ask you to polish this off quickly i don't recall

02:03:04 it looks from this as if you didn't answer her questions in the two months or so between the 10th of april and the 10th of june 2015. would that be right i can't i can't

02:03:16 would that be right i can't i can't answer i don't know when she asked you to polish this off quickly do you remember what you did no now

02:03:25 no now she says is going back to the top of page two

02:03:29 page two under item three uh the fire rating of the cladding and the fixings that's what she wants to know about did you ever investigate those matters

02:03:41 did you ever investigate those matters the fire rating of the cladding and the fixings

02:03:44 fixings no like i said i would i would probably afford something someone that was competent to answer the question

02:03:52 who would you have forwarded that too to answer the question probably neil crawford

02:03:58 crawford you don't remember doing that do you i don't remember doing it but that would work

02:04:02 work i would generally do if i got a question i couldn't answer i would afford it on someone who could right see we haven't got we haven't been able to find a response either to the april email or the 10th of email or

02:04:14 the april email or the 10th of email or any

02:04:14 any forwarding of by you of these emails on can you can you explain that i can't

02:04:23 i'd like to ask you some questions next about celetex can we go please to ryd three zeros three nine four nine nine

02:04:42 this is an email uh from you to simon lawrence of the 22nd of april 2015 which we looked at with mr lawrence when he was here giving evidence and it says psy the insulation type is

02:04:55 and it says psy the insulation type is as follows celatex rs 5080 aluminium foil facing class bs476 bs 8414 uh 2 2005. puen 9165 2012 warehouse celetex

02:05:09 puen 9165 2012 warehouse celetex ipswich regards simon o'connor project manager

02:05:13 manager do you remember the circumstances in which you sent this information to mr i don't do you know where you got the information from that you were passing

02:05:24 information from that you were passing on to him

02:05:25 on to him in this email i probably copied and pasted it from somewhere

02:05:31 it doesn't look like the sort of thing i would write or know it just to help you this isn't in the nbs specification uh where one would expect to find it

02:05:43 uh where one would expect to find it namely page 73 we don't need to look at that

02:05:46 that so you say you would have copied and pasted it from somewhere do you do you know or can you remember even roughly where you would have cut it and paste it from i don't to be honest

02:05:56 honest do you know or can you remember why you sent this information to mr lawrence i would imagine he'd ask me a question

02:06:04 it's not just sort of the email i would just send to him for no reason right do you know what bs 476 is then at that time no i didn't right

02:06:15 is then at that time no i didn't right did you know what bs8414 was at that time no

02:06:23 did you understand there to be any difference between rs 5000 and rs 508 i don't i i don't recall at all you can't really help us

02:06:34 can't really help us i don't call this email at all and it doesn't even look like something i would write

02:06:38 write do you recall even in general terms getting into the specifics of the um specifications for insulation material not not particularly known

02:06:49 particularly known not particularly at all

02:06:53 i don't i don't believe so all right can we look at ryd30

02:06:59 ryd30 [Music]

02:07:08 this is an email from simon lawrence to you

02:07:13 you mr o'connor and danny osgood of the 20th of may 2015 and you can see the subject matter is grenfell rain screen ewi funding

02:07:26 grenfell rain screen ewi funding and there's an attachment rs 5000 product data sheet march 15 pdf you see that i do and

02:07:38 he says gents please see my responsibility to the client energy funding broker uh and you can see the rest of what he says there that and the topic

02:07:47 topic just to put this in its context is obtaining

02:07:50 obtaining uh funding essentially green funding and and the email below it is from simon lawrence to david brissenden of the 20th of may same day earlier in the day uh

02:08:02 same day earlier in the day uh in relation to ewi funding um do you remember whether you you read or opened the the product data sheet when you received this

02:08:14 when you received this i don't recall opening it now can we look at it it's ryd3039507

02:08:31 did you read this document at the time i don't recall reading it no leaving aside mr lawrence's email of the 20th of may 2015

02:08:42 20th of may 2015 did you ever read this document while you were involved in the grenfell tower project

02:08:47 project i don't recall reading it now

02:08:52 did you ever ask for it

02:08:57 i wouldn't imagine so

02:09:09 it says in the pink strap line at the very top of the document suitable for buildings above 18 meters in height i know you say you didn't read this at the time

02:09:20 didn't read this at the time did anybody ever tell you positively that this material our celetex rs 5000 was suitable for buildings above 18 meters in height

02:09:31 buildings above 18 meters in height it wouldn't even cross my mind because it you know i would have presumed everybody all the specialists had gone through this right did you or anybody else that ride into your own knowledge at the time

02:09:42 into your own knowledge at the time talk directly to celetex about whether the insulation material from celetex was suitable for this project i don't remember talking to cell text at all

02:09:54 text at all i don't know if anybody else did

02:10:03 i want to ask you some questions about a different insulation product kingspan cool

02:10:08 cool firm k15 have you heard of that product yes had you heard of it at the time i'd heard a kingspan but i wouldn't i wouldn't i wouldn't put the k15 behind it right okay

02:10:20 k15 behind it right okay um if we can go back to the email that we were looking at a minute ago which mr lawrence sent to you and attached the data datasheet it's

02:10:31 ryd3042091

02:10:39 and he says there uh to both of you you and mr osgood uh he says in the last two lines can you also ensure the attached external works

02:10:50 also ensure the attached external works inspection sheet is used obviously you'll need to add to the checklist comments did you understand from this that you needed to make sure external works inspection sheets like the one that's

02:11:02 inspection sheets like the one that's attached

02:11:02 attached were filled in

02:11:06 no i think that comment would have been aimed at daniel not me i see well let's have a look at the checklist

02:11:12 checklist it's ryd3042087

02:11:24 it's ryd3042087 and if you look at the fourth tick box

02:11:29 i think you'll need to go yeah that's right

02:11:32 right look at the for it's not really a tick box itself it's an entry you can see that it says check correct product is used yes no you see that yep

02:11:44 yes no you see that yep and what tells you or danny osgood for that matter whether the product is correct

02:11:54 uh the brand didn't i imagine the branding

02:12:02 where would you get that from on the actual installation board and what would you check the actual product against to make sure it was correct against the

02:12:13 to make sure it was correct against the drawings

02:12:14 drawings against the drawings because the drawings would be annotated wouldn't they

02:12:18 they with the drawings you saw be annotated with specific product information i i can't recall if they actually were but that's that's general building

02:12:32 when the documents of this nature were filled in as per mr lawrence's instruction who was

02:12:43 mr lawrence's instruction who was responsible for actually putting pen to paper and ticking the boxes whoever was checking and who would that have been

02:12:52 have been yeah this is externals it would be one of the external managers um daniel or whoever else was looking after external at the time right just to be clear about your use of the word externals i mean i think you don't mean external

02:13:04 i mean i think you don't mean external to writing you mean external on the site i mean yeah the external facade yeah external facade yeah right so to answer my question i think you mean the site manager's responsible

02:13:15 you mean the site manager's responsible for that

02:13:15 for that part of the project dealing with the exterior yes right and and they were answerable to you yes you were their line manager yes yes

02:13:26 yes you were their line manager yes yes so

02:13:27 so what did they do physically when ticking the yes or no box in respect of a particular product that comes in to make sure that it was or wasn't correct

02:13:38 wasn't correct they would be out looking at the actual work installed i would imagine but what documents in ryden's possession did they

02:13:45 did they look at to check whether it was correct or not like i said in pedroians nothing else um possibly the dnbs spec as well but i can't i

02:13:56 the dnbs spec as well but i can't i can't recall that was the case or not

02:14:01 is it fair to assume that at least from the 20th of may 2015 well let me ask actually a prior question we see this attached to mr lawrence's email of may 2015 was this

02:14:14 email of may 2015 was this format quality control list in operation ryden on this project before may 2015 or was this the first time that it was being used on and from the

02:14:25 that it was being used on and from the 20th of may it doesn't look like a document that i've seen before does that mean that you can't help me with my question uh yes right

02:14:38 did you ever come across an occasion when

02:14:41 when you saw a quality control checklist either in this form or any other form that said that an incorrect project had been installed or had arrived um

02:14:53 arrived um i don't recall to be honest right

02:14:59 at what stage in the ordering and physical arrival and installation process did this checklist uh intercept incorrect products being

02:15:11 uh intercept incorrect products being used

02:15:13 used um i would say at the time of the work being offered to us because the subcontractors with all the materials never be delivered to site they wouldn't like i've already said earlier they wouldn't have

02:15:24 earlier they wouldn't have particularly been checked by a rider manager

02:15:27 manager we was using trusted and you know tried and tested contractors there was a bit of trust there when you say the work being offered to us what does that mean

02:15:37 mean offered to us for snagging off to you for snagging well not snagging you know like

02:15:41 like um inspection at certain points i see let's just look at the rest of this because there's a context on the document

02:15:49 document the other things to be checked are setting out is that correct what's setting out it means if the rails need to be sorry if the rails need to be 400 centers

02:16:00 the rails need to be 400 centers then he would look at the drawing it would tell him that the rails should be 400 centers he'd put a tape on it if it was 400 seconds then the setting is correct right and then check fixings are installed according to manufacturer's

02:16:11 installed according to manufacturer's guidelines and design so here we have the drawing in front of him and it would say maybe i don't know four screws per bracket and then you have count the screws per bracket yes i see and then you've got fixing pull test

02:16:22 see and then you've got fixing pull test if appropriate and then check correct product is installed it looks as if from this document and from what you're saying as well that this quality control checklist would only be used after installation yes i see

02:16:37 after installation yes i see were there any checks made in in the process any earlier on at the either at the ordering stage or the delivery stage about whether the correct product is coming onto site and being installed i

02:16:48 coming onto site and being installed i don't believe so

02:16:53 were you aware that kingspan cool firm k15 insulation was used on grenfell tower as well as celertex rs 5000 as an insulation product i wasn't there no you weren't

02:17:05 no you weren't uh now

02:17:10 uh now were you aware that uh king's back well he wouldn't have been aware i think that kingspan cool firm k15 was ordered in may 2015 and delivered in june 2015 to site

02:17:20 site i wouldn't have been aware of that now

02:17:26 right you see we we can't find any record uh of that product being installed and as different from the specified insulation product

02:17:38 insulation product can you explain to us why that is i don't know why are you asking why it was installed or why it was brought to site or

02:17:49 site or well i'm asking you why it was brought to site first of all i don't know no we know it was installed um but we don't find a quality control checklist saying

02:18:00 checklist saying incorrect product is installed in relation to k-15 can you explain why that is i can't

02:18:13 now i know you don't know when it arrived or even whether it arrived but who at the time was responsible for overseeing the order and delivery of

02:18:24 for overseeing the order and delivery of k-15 so this is may june 2015. yeah it would have been subcontractor do you know how and where it was installed on site prior to installation

02:18:35 installed on site prior to installation installation no do you know anything about the process

02:18:40 process for calling that material off from where it was stored on site so that it could go onto the building when you say calling it off um what do you mean taken off a pile and put on the building

02:18:52 building it wouldn't be a process it'd just be people picking it up and put on a mask climber

02:18:56 climber right and who oversaw that physical process

02:18:59 process that would have been ben bailey ben bailey so harley yes and anybody at ryden on site supervising that process at the time yeah i mean there would there would have been a manager going around the building

02:19:11 been a manager going around the building um on a daily basis so yeah i mean i would expect it to be picked up if it was there i see so somebody from ryden would have seen k-15 arriving and being installed

02:19:23 k-15 arriving and being installed quite possibly yes well i'm putting that to you i'm asking you is that is that correct

02:19:29 yes i suppose they would have done yes was there anybody from ryden ensuring that the manufacturers installation guidelines whether k-15 or indeed any other product

02:19:41 whether k-15 or indeed any other product were complied with

02:19:44 that that would have been part of the um the snagin process i imagine

02:19:50 but from ryden's perspective nobody before that stage

02:19:55 well we can't in if we can't inspect it if it's not been installed because you just ask if the installation process was anybody from ryden present on site

02:20:06 was anybody from ryden present on site and supervising

02:20:09 the subcontractors installation and making sure that the installation was in accordance with the manufacturer's installation guidelines um probably not but at snake stage they were they would have checked the fixings

02:20:22 were they would have checked the fixings i see because if we can't look at things when they're half finished they have to be

02:20:25 be you know we have to look at them and they're not going to complete can you tell us what stage the installation of the insulation had got to in may or june 2015.

02:20:37 2015. i couldn't do you know whether there were any records kept of where the kingspan cool firm k15 insulation was installed on the building i didn't

02:20:49 was installed on the building i didn't know it was so no no

02:20:56 and what i'm really trying to get to the bottom of is whether there was any kingsmen k15 around flat 16 on the eastern elevation of the tower

02:21:08 i don't believe uh what i don't believe i was there when when it got that low it was quite high when i

02:21:15 when i left when you left what where had it got down to

02:21:19 down to i can't recall i think it's in my statement but i can't require

02:21:28 now you tell us in your statement that your role on site as project manager included managing the day-to-day running of the project that's para three and monitoring the sequencing of the works as well as subcontractor

02:21:39 works as well as subcontractor efficiency yes yes yes and also you also say monitoring when materials were arriving on site that's paragraph 15 of your statement yes you stand by that

02:21:50 yes you stand by that yes yes how did you monitor the arrival of materials on site because they were booked in with the uh marshall on the front um and the idea of them booking them in

02:22:02 um and the idea of them booking them in so we didn't have a road full of big lorries it was more logistics than what was actually coming

02:22:10 right

02:22:15 and in your statement to be fair to you you do say that it's from a logistics and programming perspective yes so your monitor can your monitoring was limited to timing of

02:22:26 your monitoring was limited to timing of arrival of lorries and where you were going to put them yeah i mean it was a small dead-end road so you know we could only have one at a time so right a matter of booking them in logically right how did you mon

02:22:40 right how did you mon how did you actually monitor the arrival of materials onto site it was done by the marshall at the front that he would he would record they'd be booked in maybe 48 hours in advance

02:22:50 advance um and then there would be time slots i see and the marshall was here ryden or she a riding person or a a harley question agency who were they

02:23:01 a harley question agency who were they what was the name yes i can't remember all right

02:23:05 all right how did you monitor the programming and sequencing of materials arriving onto site

02:23:09 site well i personally wouldn't have i oversaw that that would be the managers are looking after the areas so during the meetings with the subcontractors they'll be saying you know deliveries need to be more

02:23:20 you know deliveries need to be more timely or you need to give us more notice of delivery you know

02:23:31 would you describe your role as including

02:23:35 including the responsibility to ensure that sufficient quantities of materials were onsite in order for the works to stick to program it wouldn't be my responsibility to make sure there's the the quantities are on

02:23:47 sure there's the the quantities are on site it'd be my responsibility to make sure the subcontractors are ordering in a timely fashion how would you go about discharging that responsibility well when he when the weekly monthly meetings would go

02:23:58 meetings would go what happened with the subcontractors and the managers um they would ask about materials on site

02:24:07 and when your next delivery is and is that quick enough do you have enough men you know would it be your job to know what products or materials were arriving at site and where they were going to go on the

02:24:18 where they were going to go on the building

02:24:20 building no whose job was that the various managers

02:24:25 managers when you say various managers here the external manager order in it depends on what

02:24:29 what what was being delivered um so if we're talking externally then it yeah it will be one of the external managers they would you know make sure there was enough room for the materials to come in for one because it was a very tight site

02:24:41 for one because it was a very tight site so that's a ride in person yes for whom you were responsible yes yes and and when when you were supervising their work in that respect

02:24:53 supervising their work in that respect what did you do what do you mean well your job is to supervise

02:24:58 supervise their work to make sure that the right products arrived and went on to the right

02:25:05 the right point on the building i don't quite follow where you're where you're going well you see you've got external managers who you told us what you knew what products were arriving at site and where they were going

02:25:16 were going and my question is what did you do to supervise them and monitor them um it wasn't my job to supervise what materials come to sight that was what the managers are doing yes um and i think the drawings tell you where the where the material is going

02:25:27 where the where the material is going yes and my question was you say it was for the managers to do and my question is what did you do to supervise and make sure that the managers were getting it right i could tell by the quality checks i

02:25:38 i could tell by the quality checks i could tell by the clerk of works inspections if they weren't getting it right then i'd be getting um reports back from building control and you know clock at work saying if this isn't correct which

02:25:49 isn't correct which was it your job to stay in close communication with the relevant subcontractor about the supply of products coming onto site no again whose was that was that the

02:26:00 no again whose was that was that the external site landing yeah one of the managers yes and who did you or they perhaps liaise with at harley with

02:26:07 with specifically harley in respect of cladding materials arriving on site it'd be pretty ben bailey and ray bailey and who was it who liaised

02:26:18 ray bailey and who was it who liaised with them about that matter it would have been at ryden dixon a manager again yes do you know who can you give me a name probably daniel osgood but it depends on the timings

02:26:30 osgood but it depends on the timings of when you're talking about uh um specifically you're quite right and that was a general question let me ask it again in a specific time frame may june 2015. it's been daniel what could i imagine

02:26:41 it's been daniel what could i imagine right and if there was a problem with the delivery or lead times were strained there was pressure would you have been the contact point for the subcontractors oh that would probably would have been

02:26:52 oh that would probably would have been simon because he had a better relationship with him or a more detailed relationship with him simon lawrence yeah he'd worked with them on

02:26:59 them on numerous projects i hadn't

02:27:04 right so

02:27:07 given your answers in relation to the site managers and what they would do did the site managers have product specific knowledge so that they could make sure

02:27:17 make sure that what was coming onto site they would be aware of what what should be going on because they would have the drawings

02:27:23 drawings right okay i don't think they would have pacific like each delivery wouldn't say this lorry's carrying this it would just be a time slot

02:27:31 slot right but your evidence is that it would be the drawings that would give them the information against which they could cross-check the materials coming onto site but nothing other than the drawings

02:27:44 but nothing other than the drawings probably the spec as well but i think the drawing would quite generally be quite detailed okay did ben bailey or anybody else at harley for that matter

02:27:55 anybody else at harley for that matter tell you in may 2015 that there was a delay

02:27:58 delay in the delivery of celetex rs 5000. i don't recall that now you didn't right you didn't get wind of that right were you consulted at all about the delay

02:28:09 the delay in the supply chain in relation to insulation at that time i don't recall but they would have gone straight to simon lawrence not to me right can you give us an idea of how

02:28:23 right can you give us an idea of how behind the project was at this point

02:28:29 in june sorry yes in may or june 2015. uh late may early june possibly nine weeks

02:28:37 weeks right is that was concerned conservative as well

02:28:42 as well yes is it fair to say that at that point late may early june that time was pretty critical

02:28:51 critical days counted i think the whole time was critical yeah yes

02:28:58 now we've looked at a specific time slot for k-15 are you aware from your recollection whether there was any any other occasion when uh kingspan

02:29:11 any other occasion when uh kingspan cool firm k-15 was ordered as a ordered as a substitute for celetex rs-5000

02:29:22 for celetex rs-5000 now

02:29:26 i take it from your answers that you've given me this morning already about kingspan k15 that you didn't know anything about the specification and and specifically it's fire performance is that right that's right

02:29:37 performance is that right that's right so you never got to see any of the spec for that material or any of the certificates i don't recall seeing any certificates but material now

02:29:48 right did you ever see a king's something called a kingspan declaration of performance

02:29:56 at the time no no let me just ask let me put this to you and ask you who would have done um it's sig

02:30:06 60703 sig 703

02:30:20 uh this is the declaration of performance produced by kingspan for cool firm k-15

02:30:30 and here is uh to put it generally a lot of technical detail about this product did you ever see this document no

02:30:43 did you ever see this document no i don't recall seeing it but i'm going to say no

02:30:47 to say no would anybody to the best of your election your your recollection at ryden have seen this document do you think

02:30:57 [Music] um probably simon simon simon lawrence right okay

02:31:16 we've already been over the question of approvals for substituted products did you understand at the time that if a product was going to be changed then ryden had to get the permission

02:31:28 ryden had to get the permission from the tma before substituting one product for another i don't think it was a tmo i think it'd be studio e as well as as lead architects yes do you remember

02:31:39 yes do you remember any occasion when so far as you remember ryden did go to the tmo

02:31:46 the tmo or studio e and ask for permission before substituting k15 for rs 5000 no

02:32:00 if a decision had been made by well let me ask you this whose decision

02:32:06 decision in the chain of command would it have been to make the substitution from rs 5000 and instead have k-15 well i think the change needs to be

02:32:17 k-15 well i think the change needs to be put forward to the architect yeah but whose decision would it have been made initially then um

02:32:26 probably harley would have put it to someone like simon lawrence um who would have then put it to harley i see

02:32:34 i see we say harley would have put it to simon lawrence who would have put it to harley so does it go around in a circle uh harley would have put it simon lawrence sorry in some launch would have put it studio studio e right okay sorry so the

02:32:46 studio e right okay sorry so the to the best of your understanding any change of material would have been signed off by studio e i think that's what you're telling us yeah i think student and and the tmo at the time do you remember any occasion

02:32:57 any occasion in which you became involved in the question of substituting one product for another on this project

02:33:04 um not particularly i mean it was not particularly not that any stands out right

02:33:17 do you have any recollection about whether building control were told that king's band coolthorn k15 had been proposed as an alternative insulation product to the rs-5000

02:33:28 product to the rs-5000 okay i wouldn't be able to comment i don't know

02:33:32 and i want to ask you some questions about infill panels um when i say infill panels does that mean anything to you it's the panel that involves between the windows is that what you're

02:33:43 windows is that what you're referring to yes between the windows and above the cladding spandrel panels that's what i'm going to be asking you about all right now can i ask you to turn to har four zeros three nine five

02:33:54 har four zeros three nine five one please

02:33:59 hor four zeros nine

02:34:04 this is an email dated the 6th of march 2015

02:34:09 2015 from neil crawford to paul hanson and it's copied to john hoban they're both

02:34:16 both rbkc control and it also goes to simon lawrence at ryden and you simon o'connor see that yep and if you look at the top of the page

02:34:29 and if you look at the top of the page you can see uh that mr crawford has attached a number of drawings

02:34:35 and uh when you got this email do you remember do you think that you would have opened it open the attachments quite possibly

02:34:48 is it possible to see one of the attachments i'm going to show you one yes if you go please uh to har403953 one of these drawings was an

02:34:59 was an elevation drawing

02:35:10 har-403953

02:35:15 now this is a harley drawing authored by kevin lam [Music]

02:35:22 [Music] as you can see from the box second from the right and the smaller box

02:35:29 box on the left drawn by kvl do you see that and there's a little little lamb and picture in the box so we can we can see that it's kevin land

02:35:40 see that it's kevin land and it's marked approved for construction but there's no studio e stamp on it and i want to zoom in with you to the left hand side of the window arrangement if we can please

02:35:51 arrangement if we can please because you'll see there there are two areas of the infill panel which are identified the the first one is a large hatched area can you see that yeah and that's got

02:36:02 that's got well that's not terribly clear on the screen it's got a p1 in the corner yeah can you see the p1 you can now can you confirm that that is the

02:36:13 now can you confirm that that is the panel that sits between the windows of the kitchen and the bedroom in this particular arrangement i don't know if that's the bedroom but it's a panel that sits between them two windows yes yes all right

02:36:25 windows yes yes all right and that's what we call the infill panel now there's a second smaller hatched area which in on the left hand side beyond the window

02:36:33 window and above the smaller window which has p2 in the top left corner can you see that i can and is that the panel within the window itself which has the kitchen extract fan yes

02:36:47 kitchen extract fan yes do you remember reviewing this drawing particularly when it came to you in the pack

02:36:51 pack which we'd seen attached to the email no do you remember whether you made any investigations into which materials made up p1 and p2

02:37:02 into which materials made up p1 and p2 these infill panels in these two separate locations no now if we uh we don't need to go back to the email but

02:37:13 but mr crawford also attached to the email we looked at a document called specification notes i'd like to look at that with you that's har403955

02:37:33 that's har403955 and again just to help you uh with this with the origins of this document it's again it's authored by kevin lam

02:37:44 kevin lam it's dated the 15th of january 2015. if you look at the bottom right hand corner of the document

02:37:52 document and and in fact this one is a slightly later revision if you look at the

02:37:58 the box on the left it's revision a of the third of march 2015. you see that i can

02:38:06 i can so this is i think what comes to you as attached to that email do you remember looking at this document

02:38:12 not specifically known not specifically in the context of that email or not at all it doesn't i i'm not looking at it thinking i remember this right so you don't remember this

02:38:24 right so you don't remember this document at all from your involvement on the project no right not that i recall all right um let's see how far we get then

02:38:35 um let's see how far we get then uh if you look at the left hand column about halfway down can you see that it says p1 glazing p1 panels

02:38:48 glazing p1 panels can you see that okay and can you see that

02:38:52 that the outer is 1.5 aluminium skin and then the core is 25 millimeters of styrofoam

02:39:03 of styrofoam now is styrofoam familiar to you as a product

02:39:08 product yes it is now it is now was it a familiar product to you then not really no did you know that it it was a trading name for extruded polystyrene or xps no no have you come across

02:39:21 or xps no no have you come across extruded polystyrene as an insulation material

02:39:25 material in your experience as at this time as at this time yeah um no so as that march 2015 no uh immediately below

02:39:39 no uh immediately below what we've just been looking at we can see glazing p2 panels and then again outer 1.5 millimeters aluminium skin and then core 25 millimeters kingspan tp10 rigid

02:39:52 25 millimeters kingspan tp10 rigid insulation

02:39:55 uh had you at that stage come across kingspan tp10 rigid insulation well i said i was wearing this trade named kingspan but i wouldn't have been able to give you a tp10

02:40:06 tp10 reference did you know that that was an insulating product for use on the external surface of a building i knew it was used for insulating buildings so i didn't know the ins and outs of it okay can we

02:40:19 the ins and outs of it okay can we then look at a different document which is har

02:40:25 is har four zeros two four seven seven

02:40:33 this is an email

02:40:37 uh from ben bailey to acp at panel systems do you know who panel systems were

02:40:50 acp panel systems no right uh okay um now you don't get this email at the time so i'm not going to ask you about the detail of it i just want to ask you about the attachment to it

02:41:02 about the attachment to it you can see that he attaches purchase order it's po113 c1059 that's grenfell panel systems curtain wall panels pdf and he you can find that at we can

02:41:14 pdf and he you can find that at we can find that purchase order at h50445

02:41:27 and the date of the purchase order is the 10th of september 2015. and i think by this time is it right you had already left the project the project yes did you know

02:41:41 yes did you know that harley curtin wall had gone into administration by this stage

02:41:47 stage um i knew via another member of staff yes right again i actually didn't know they'd gone into administration i knew they had problems right okay and now i know

02:41:59 problems right okay and now i know you've left the site at this at this time um but uh do you know who had taken over responsibility uh at the site um for monitoring

02:42:10 uh at the site um for monitoring the purchase order process that process would always be a surveyor right

02:42:19 [Applause]

02:42:22 now i just want to see if you can help them i know you'd left at this time and it may be that you can't but if we go to page six of this document we can see a schedule of panels

02:42:34 can see a schedule of panels p2 p3 p4 and p5

02:42:39 uh where we can see that they are all kingspan optical p2 p3 p4 are kingspan tp10 rigid insulation

02:42:54 p4 are kingspan tp10 rigid insulation in fact our experts have found from their site inspections after the fire that the panels used at p2 did not have a kingspan tp10 core but a styrofoam core

02:43:05 styrofoam core are you able to shed any light on why that might be no let's say i wasn't at the project then and

02:43:12 then and unfortunately no i can't help did you leave the project before the p2 panels

02:43:19 panels that had been delivered were checked to make sure that they were formed of the right product in accordance with specification i'm unsure whether i was gone but then or not i'm honest

02:43:34 right

02:43:40 can i uh ask you to look at a document uh which tells us a little bit about ryden's relationship with x over

02:43:49 over so i'm going to turn to that topic i think quite briefly and it's ryd3017870

02:44:01 this is a set of minutes of the second progress meeting uh progress meeting number two on the on the 19th of august 2014 and we can see that you were

02:44:14 august 2014 and we can see that you were present

02:44:16 present and simon lawrence was not but these minutes were for his information were you

02:44:23 you there in his place do you think no you were there though weren't you yeah i was there yes right if we

02:44:35 right if we uh go through we can see various references to sl if we just turn to page two please i think we can see we can see that from actually let's let's do 1.1 well let's

02:44:46 actually let's let's do 1.1 well let's go back a page sorry 1.1 it's the first one i think while we've got it there in this is under minutes of previous meeting uh and you can see in the second line sl

02:44:57 uh and you can see in the second line sl confirmed that the decision will have no implication on programming is required by early october should we read s instead of sl soc no because he wasn't there so he

02:45:08 no because he wasn't there so he couldn't have done done anything or said he would have he would have forwarded anything he needed to answer to probably zach right let's just turn the page then to paragraph 1.5

02:45:20 the page then to paragraph 1.5 top of page 2 sl to appoint other consultants to include fire dda acoustic etc

02:45:28 etc after the main subcontractors are on board do you remember there being a discussion at this meeting about the appointment of other consultants to include fire i don't particularly remember that

02:45:41 fire i don't particularly remember that no

02:45:42 no i mean it says sl to a point can you account for how that gets into the meet the minute as sl uh

02:45:48 uh uh not soc because it wouldn't be rsd it would be my role to appoint anybody um so it definitely wouldn't isn't supposed to say soc right when it goes in the next paragraph

02:46:00 right when it goes in the next paragraph to say sl confirmed that his m e subcontractors are on board an investigation's underway given that he wasn't there and you were why does it say sl because like i said previously he'd

02:46:11 because like i said previously he'd probably sent meeting notes forward i see that okay right so can you help at all

02:46:18 all with the first paragraph was there any discussion at this meeting to the best of your recollection about the appointment by ryden of other consultants to include fire

02:46:28 fire i i don't particularly remember that conversation but i know there was conversations about appointing people not just fire people i think it was various people dda can you help with

02:46:39 various people dda can you help with that

02:46:41 that um disabled disability isn't it the disability discrimination act yeah do you remember specific discussions about whether you should appoint a consultant to assist ryden uh with

02:46:55 a consultant to assist ryden uh with meeting obligations under that legislation i don't i don't remember that at all but i i know the toilets in the boxing club or maybe the nurse know maybe the nursery

02:47:06 know maybe the nursery um we're down to be dda compliant right but i would expect a qualified uh architect to be able to do that i see you you give a specific example

02:47:17 you you give a specific example um can you think of any other examples where

02:47:21 where dda expertise was considered possibly the boxing club right um

02:47:38 [Applause] can i ask you to look at a document which did involve x over this is issue three of the outline fire safety

02:47:49 three of the outline fire safety strategy report which is at cst five zero six zeroes i'm so sorry six zeros eighty five

02:48:00 cst6085

02:48:05 now this mr o'connor is issue three of x over's uh outline fire safety strategy dated the 7th of november 2013.

02:48:19 the 7th of november 2013. have you ever seen this document before yes

02:48:22 yes where you were aware of this report during your time as project manager on the grenfell tower i was aware of it because i remember the picture you remember the picture did you

02:48:33 picture you remember the picture did you see it at the time then it was definitely on site it was definitely on site did you ever read it not that i recall right do you remember that

02:48:43 that the circumstances in which you saw it you say you remember the picture can you casting your mind back tell us the sort of circumstances that you can recall whereby you might have had a chance to look at this document

02:48:55 chance to look at this document this would have been that as you went into the site office on the left there was a load of boxes where documents were kept yeah that would have been one of them

02:49:06 it would have been in one of them right what would have given you the occasion to take the box down which had this document in it oh sorry it wasn't boxes it was a wooden structure um so it would you could see documents in

02:49:19 so it would you could see documents in it it was almost like a multi-story like post box if you like i see

02:49:24 see do you remember any occasion when you pulled it out of its little structure and

02:49:28 and looked at it i don't recall no

02:49:33 do you remember any occasion on site when other people you could see or hear did that

02:49:43 i don't recall seeing anybody reading it right

02:49:50 apart from an exchange of emails which we're going to come to in the september of 2014 between xover and studio e among other people which we're going to come to shortly

02:50:01 come to shortly can you remember x over ever giving any fire safety advice in relation to the rain screen cladding facade at grenfell tower

02:50:10 tower no it's not it's not a conversation i would have had i don't think i ever spoke to anybody for mixover casting your mind back to your own experience on the chalcott's cladding i think you you say you weren't

02:50:21 cladding i think you you say you weren't involved but um do you remember whether uh ryden engaged the services of a specialist safety engineer fire safety engineer for that project i wouldn't know

02:50:34 that project i wouldn't know mine was all internal right

02:50:41 i'm going to ask and i'll come back to those emails but i'm going to ask you for the moment about carl stokes does the name mean anything to you it does yeah

02:50:50 does yeah uh in in paragraph 16 of your statement you say that you saw emails um we'll perhaps be able to just look at it ryd-3094221 this is your

02:51:03 look at it ryd-3094221 this is your statement

02:51:05 statement and a paragraph 16

02:51:09 you say

02:51:12 about eight lines down from there you say

02:51:16 say i was also aware the consideration was being given to fire safety and compliance with the building regulations throughout my involvement in the project because i saw emails involving harley's studio e rbkc building control

02:51:27 studio e rbkc building control building control and c.s stokes and associates limited cs stokes an independent fire risk assessor engaged by

02:51:33 by kctmo who has allowed uninhibited access to the construction site and that just moving on in your statement to page 10 please we can just skip two pages forward to paragraph 19.

02:51:45 skip two pages forward to paragraph 19. you also say there i was aware you see that inspections were carried out by ryden harley's js wright studio e clerks of the works cs stokes curtains and building control

02:51:56 curtains and building control during my involvement in the refurbishment project and then you say page 11 paragraph 22 if we can just look at that you say regular inspections were carried out by c.s stokes

02:52:08 were carried out by c.s stokes who i believe would be provided with information by kctmo confirming any areas they should they thought should be inspected i've shown you all of those

02:52:17 of those parts of your your witness statement first of all who what did you think c.s stokes's role was

02:52:25 was to look at fire safety in as a whole on behalf of the ktmo fire safety as a whole in relation to the building or in relation to the project or both in relation to

02:52:37 project or both in relation to to the project really um he would quite often just turn up on site and we would walk the construction site first and then we would go

02:52:48 then we would go up to various floors um and he would quite often pick up you know just little items that he wasn't i won't say not happy with but he would report back to the tma

02:53:00 report back to the tma and did you go with him on these visits not always at first i'd i did um because i believed it was good to get a relationship um but after that it would have been um jason or whoever was

02:53:11 would have been um jason or whoever was looking after the areas he was going to

02:53:16 did you uh ever read his reports yeah you did did you rely on his reports in any way um when you say rely i mean if there was something in there we needed to correct

02:53:27 something in there we needed to correct then then we would correct them uh yes when i say rely what i mean is in making any decisions that you made yourself

02:53:36 yourself did you use mr stakes's reports as the basis for making those decisions um i don't understand the question sorry right well did you do anything uh in reliance on anything he said in his

02:53:48 reliance on anything he said in his reports

02:53:49 reports only if only if it concerned us if not the reports would generally come from the tmo so um he would be looking at various items that the tmo would do to be carrying out um and then that

02:54:02 do to be carrying out um and then that would then overlap with our work slightly by saying right you need to do this but you know that's not part of whatever you're doing so right now in his witness statement mr stokes says that he wasn't retained or

02:54:13 stokes says that he wasn't retained or appointed to undertake any supervisory role of the refurbishment does that accord with your recollection of his role i didn't really know what his full role

02:54:24 i didn't really know what his full role was um

02:54:26 was um i knew he was employed by a tmo um and i knew he would come to site to look at fire safety did you ever speak to mr stokes about the cladding to be used on the building

02:54:37 the cladding to be used on the building no not that i recall did mr stakes ever give you or anybody else at ryden any advice or any assurances in respect of the fire safety of the

02:54:48 in respect of the fire safety of the rain screen facade i don't think we discussed it

02:54:53 did you ever tell mr stokes that the rain screen facade was fire rated that doesn't sound like words i would use so no did you

02:55:04 use so no did you ever tell mr stokes words to the effect that the rain screen facade was safe from a fire safety perspective i don't believe so

02:55:21 can we look at art403597 please

02:55:28 these are minutes of a housing management liaison committee meeting on the 16th of february 2015.

02:55:40 on the 16th of february 2015. and we looked at these yesterday i think with

02:55:43 with mr lawrence in a slightly different context

02:55:49 the meeting was attended by as you can see you

02:55:53 see you uh christina stefanu and linda prentice from ryden and janice james and siobhan rumble from the tmo as well as claire williams yes yep uh if you go to page three please

02:56:06 yep uh if you go to page three please i'd like to look at paragraph or item 14. communal lobby duct panels yep and it says there some of the duct panels were

02:56:17 says there some of the duct panels were broken and found to be various materials for example chipboard ryden's fire strategy consultant had been on site and met carl stokes tmo's fire risk assessor

02:56:28 tmo's fire risk assessor and agreed that these panels did not need to be fire resisting on the basis that the services were fire stopped at floor and ceiling slab level and so there would be no fire spread within the ducts

02:56:41 uh who did you understand to be far ryden's fire strategy consultant

02:56:50 i don't know um i don't know i mean we've seen that you were at this meeting did you see these minutes after they after the meeting more than likely yes

02:57:03 after the meeting more than likely yes would you have seen then or would you would you have read them carefully i would have read them yeah would you not therefore have seen that there was a reference

02:57:12 reference in them to ryden's fire strategy consultant yeah i can't tell you who that would have been um did ryden have a fire strategy consultant not aware of

02:57:24 consultant not aware of who could it have been then who met carl stokes and made the agreement referred to

02:57:29 to i don't know

02:57:33 i i honestly don't i don't know

02:57:43 were you present at any meeting between any person who could conceivably be described as occupying the position of a fire strategy consultant and mr stokes i don't recall being in a meeting with

02:57:54 i don't recall being in a meeting with anybody the ride and fire strategy consultant i don't recall at all

02:58:06 do you remember any discussion between either you or anybody else at ryden with mr stokes about the subject of whether

02:58:17 stokes about the subject of whether these panels did or didn't did not need to be fire resisting

02:58:22 resisting um i i recall a conversation um about what they were what they were made of they were i think they were adjacent to the lift shaft um i recall having the conversation

02:58:33 um i recall having the conversation about what they were made of but there was no one else sort of involved and i think that's what probably sparked this this meeting if it happened

02:58:47 this meeting if it happened do you recall a conversation with mr stokes about what the panels were made of

02:58:51 of yeah was that a conversation on site yeah it would have been yeah were you qualified to and make an agreement with him about whether they did or didn't need to be fire

02:59:02 they did or didn't need to be fire resisting

02:59:03 resisting no

02:59:07 who was it who attended on-site and met carl stakes who would have been qualified or was qualified to agree with him that the panels didn't need to be fire resisting

02:59:19 need to be fire resisting i think i've already answered that i don't know right

02:59:24 who was responsible for drawing up these minutes

02:59:27 minutes um you can look at the look at page one to see who was there if we could if we could please just to remind you you can see that it's you christina

02:59:38 you can see that it's you christina stephanie and linda prentice and others from

02:59:40 from the tmo do you know whether it was ryden or the tmo who drew up these meetings i think would have been the the housing officers

02:59:47 officers the housing officers when you say the housing officers you mean actually this one i've just spotted that claire williams claire williams would have done that i see so and we know this is an art document an artelia document

02:59:59 document an artelia document but um how many of these meetings did you go to these housing management liaisons um a fair few they were more they weren't about

03:00:10 about this is quite a rare one actually but they were more about um residents and access because um there was a few access problems

03:00:17 problems at the time and were meetings produced for all of these meetings were minutes produced for all of these minutes i would imagine so i i i couldn't clarify this definitely were but i would imagine there was yes

03:00:29 but i would imagine there was yes right and do you remember who was responsible in general terms for drawing up the minutes and circulating them uh i would say claire williams is that a guess or is that a recollection no that's

03:00:41 recollection no that's you know if claire was there she would definitely be the one that would be producing these minutes yes thank you uh mr chairman that's a convenient moment i'm about to turn to another topic

03:00:50 topic in that yes well mr economy we'll have a break now so we can all get some lunch thank you please don't talk to anyone while you're out of the room about your evidence or anything to do with it

03:01:01 evidence or anything to do with it and we'll come back at two o'clock please perfect right you thank you let's give the usher

03:01:17 good two o'clock please thank you

03:01:40 you