Continued evidence from Simon Lawrence of Rydon examining insulation products, fire safety compliance, and the substitution of Kingspan K15 for specified materials.
00:00:17 yes could you ask mr lawrence to come back please
00:00:35 all right mr lawrence yes ready to continue a minute uh mr chairman uh mr lawrence uh just picking up a thread that we let drop before the lunch break um on this project
00:00:49 the lunch break um on this project was there a project lead in the sense of uh well were you the project lead within ryden
00:00:57 ryden uh well obviously obviously responsible for the delivery of the contracts oh yes contracts manager yeah but i wasn't site based
00:01:05 based project lead on site with simon o'connor yes and
00:01:08 yes and but in your role are we to understand that you yourself did not have a personal assistant great right uh so you had nobody with experience of administering administering construction programs
00:01:20 administering construction programs deliverables rfis to act as your second pair of hands uh no i mean simon o'connor would pick up um we'd pick up some of that but um but no i didn't have a
00:01:32 no i didn't have a sort of a pa or or a contracts manager's assistant tonight was there a work package or wp design lead um
00:01:44 lead um we'd split the team so so project manager so simon o'connor will be the project manager for the site so concentrate purely on um on that project as in grim phil so so site based
00:01:58 as in grim phil so so site based um he would oversee i mean a lot of our roles would um
00:02:04 would overlap um but he obviously was only concentrating on on grenfell and no other at the time and then from that we would then have our management who would look after it
00:02:15 management who would look after it either be divided into subcontractors or work areas or or um yeah it varies depending on the on the works
00:02:24 the works right and who would it be within ryden who would have as it were their finger on the pulse of the work of the sub-consultants or subcontractors
00:02:36 subcontractors probing them monitoring supervising them and making sure that the work individual work packages were keeping um on track it would be a combination of me and simon i see okay now can i then
00:02:50 me and simon i see okay now can i then turn to
00:02:51 turn to the next topic which is rs 5000 information uh can i ask you to look at the rs 5000 data sheet first of all this is
00:03:02 ryd303950
00:03:10 and
00:03:14 this is the uh rs 5000 issue one data sheet as you can see from the top right hand corner thank you uh first of all uh issue one august 2014
00:03:29 uh first of all uh issue one august 2014 can you see that yes did you do you remember reading that document to dennis at any stage uh i had yes i had seen it but um i think
00:03:38 think like the um the bba certification we were talking about earlier it's it's it's not something i would have pulled apart on every single word but yes i had seen it and i think there
00:03:50 but yes i had seen it and i think there might have even been a sales brochure promoting the use for suitable for range green over 80 meters now let's look at page one of the document we can see that it says
00:04:02 document we can see that it says with seletex rs 5000 you are specifying an insulation board that first bullet features a super low lambda value of 0.021 offering enhanced
00:04:14 lambda value of 0.021 offering enhanced thermal performance is the first pir insulation board to successfully test the bs
00:04:20 the bs a414 meet the criteria set out in br135 and therefore is acceptable for use in buildings above 18 meters in height has class naught fire performance
00:04:32 has class naught fire performance throughout the entire product in accordance with bs 476 when you read this document did you read that
00:04:40 that those statements in there i probably yeah i probably would have focused on the on the introduction part of it um more than anything
00:04:52 um more than anything so i was going to say cursory look but that sounds right inappropriate knowing what's happened but um yes it would have been a high level look at the document let's just pin you
00:05:04 look at the document let's just pin you down a bit more on what you mean by introductory part or introduction part did you notice what was said in the big red banner at the top uh i'm
00:05:16 red banner at the top uh i'm i'm sure i would have done including suitable for buildings about 18 meters in height
00:05:20 in height yeah how much further i got past that and probably the first paragraph right and you'll see in the first paragraph the last sentence concludes and therefore is
00:05:31 sentence concludes and therefore is acceptable for use in buildings above 18 meters in height did you focus on that did you notice it i would have noticed that part of it yes right
00:05:39 right okay do i take it from that that you didn't notice or didn't pay as much attention as to the three technical bullet points i've set out below i've read out to you as set out
00:05:52 below i've read out to you as set out below
00:05:54 no probably not no let's look at page three of the document because we find here further information about the
00:06:04 certification it says certification and then there's some details set out there did you look at that do you remember uh i don't remember looking at that [Applause]
00:06:18 right
00:06:22 did you let's look at this look at the last
00:06:27 last few lines in there just to see if this triggers some kind of recollection the fire performance and classification report issued only relates to the components detailed above any changes to the components listed
00:06:38 any changes to the components listed will need to be considered by the building designer do you think you read that statement i wouldn't have noticed it now you wouldn't post it right obviously since
00:06:48 since um and preparing for it yes i have yeah this has obviously been flagged up at the time now but as a reasonably competent uh contracts
00:06:59 reasonably competent uh contracts manager on a project like this would it have been normal for you to have read that in full and understood it um no i don't think it would have been
00:07:10 think it would have been normal no because there's technical information in there that i that i couldn't interpret and con could interpret
00:07:17 interpret right um again it would be more of a um
00:07:25 is there some sort of certification you know
00:07:28 know is it a i was going to say a suitable product without going into the in-depth technical side of it um right to your knowledge did the designer of the cladding system for grenfell
00:07:40 of the cladding system for grenfell tower
00:07:40 tower whoever that was ever actually consider the actual components of the cladding system to see whether they were comparable to the system tested by celetex uh for
00:07:51 to the system tested by celetex uh for the purposes of eight four one four uh the answer is i don't know i would have assumed that harley's would have the knowledge of celetex right other designers
00:08:07 uh to the extent that the actual components of the cladding system as applied to grenfell tower were different from the cladding system as tested for the purposes of bs8414 did
00:08:18 tested for the purposes of bs8414 did you would you accept that no reliance should have been placed by you or anybody else involved in this project on this uh on this certification in hindsight and now knowing this thing
00:08:29 in hindsight and now knowing this thing yes i said that yeah do you recall either you or anybody else at ryden talking directly to celetex about the suitability of this product fr
00:08:41 about the suitability of this product fr 5000 and then rs 5000 as insulation at grenfell don't recall anything nice
00:08:51 now let's just look at the system specification involving this for the moment can i ask you to look at an email ryd50421 please
00:09:02 ryd50421 please this is an email from you to mr brissenden of the 22nd of april 2015.
00:09:15 this is where you sent it to him and we can look at the email but this is the system specification first of all does this document look familiar to you sitting here now the document does yes
00:09:27 sitting here now the document does yes yes when do you think you saw it when i given you a date of april 2015 but yeah i'll have to tell you a word for that i don't know all right well maybe that doesn't matter you confirm that you saw it at the time
00:09:38 you confirm that you saw it at the time can i ask you to look at the system as shown on the left-hand side of the second line there that it says
00:09:52 uh it says system
00:09:57 metal technology high thermally broken aluminium windows and then rhino bond composite rain screen cassettes do you remember where you got this
00:10:08 do you remember where you got this document from
00:10:11 uh well it would have come from from harley's so right well let's just let's i'll take you back to the email just to see if i can just pin this down in time it is ryd of 3039517 please
00:10:32 it is ryd of 3039517 please um here's the email you sent to mr briston on that date and you sent the rs 5000 product data sheet and the general system spec notes and we've checked those out and and the the
00:10:43 and the the the specification is indeed the one that you say you got from harley's and you don't need to understand anything in the text of the email
00:10:55 but it gives you a date as to when at least you had seen it do you remember the circumstances in which you got the the system specification document from harley
00:11:05 harley uh in which i got it i mean the the conversation with david brisson is he's all reliant on on the eco funding as we were talking about prior to the break but um whether i whether we had
00:11:17 whether i whether we had that product or whether we had that document on file from harley's whether that was the latest revision we had on file or whether i specifically asked them for it they said to me i'm not i couldn't be
00:11:28 they said to me i'm not i couldn't be sure all right can we just go back to it please ryd 5041
00:11:38 just have a look at uh the specification did you when you saw it notice that the specification notes didn't specify any insulation
00:11:52 um i don't know you don't know i don't recall right uh you don't recall i mean sitting here now it's clear that
00:12:04 i mean sitting here now it's clear that the specification notes don't specify insulation give you any reason or explanation as to why that is uh no do i take it that you didn't pursue that issue with harley
00:12:17 pursue that issue with harley i don't recall not noticing it did mr brisenden not ask you about it when you sent him the rs 5000 data sheet and the specification dates which doesn't refer to it
00:12:28 doesn't refer to it um i don't recall him asking does it follow from that you didn't put the two documents he was sending mr brissonden together specification sheet and the specification notes and notice that
00:12:40 specification notes and notice that we've compared the two probably not no no uh
00:12:48 if you go next please to ryd ryd-3039499 this is an email the same day 22nd of april 2015
00:13:00 to you from mr o'connor where he says psy the insulation type is as follows celitex rs 5080 aluminium foil facing
00:13:13 celitex rs 5080 aluminium foil facing class bs476 bsa414 and then puen 9165 2012 warehouse celetex
00:13:22 celetex ipswich do you know why he sent that to you
00:13:27 you uh no have you asked for it you think i don't even recall this email at all what was
00:13:33 was when he was when he saw it what did you think he meant by class bs476
00:13:40 bs476 um
00:13:44 well i i don't recall this email and quite what was asked for but um i think if i was to read it again without hindsight i think i would just
00:13:55 without hindsight i think i would just be focusing on the celetex rs part of it right and the
00:14:03 sort of model number i mean on the face of it it looks as if simon o'connor is assuming that you would understand that bs 476 and bs 8414 would mean something to you
00:14:16 and bs 8414 would mean something to you i think he's copied and pasted off something i would suggest
00:14:22 i i mean it doesn't it doesn't mean anything to me i can't tell you what that
00:14:25 that british standard classification is right did you know the difference between rs 5000 and rs 5080
00:14:36 5000 and rs 5080 um i think that might be the thickness i think the atom might have been a thickness
00:14:43 thickness yeah did you know that at the time did you understand that i can't recall if i knew that at the time or or known that since maybe did it occur to you to think about whether the test denoted by those numbers
00:14:55 denoted by those numbers particularly bs8414 identified there had been carried out on the same system that you were proposing for grenfell tower
00:15:06 is there any reason why not
00:15:10 i don't know the context in what the email was sent or why he's even thought it to me excuse me or i've asked for it um but i would imagine
00:15:21 um but i would imagine we would focus or i would have focused on the
00:15:24 on the the celetex takes the model number
00:15:34 i want to turn to ask you some questions about kingspan's cool therm k15 you've heard of that product i take it i've heard of the products yes yes um as contracts manager were you
00:15:45 yes um as contracts manager were you aware of what materials were being ordered
00:15:47 ordered onto the site and stored on site at any given time um was i aware of them i didn't go and i didn't go and check them i didn't go and look at them
00:15:59 them i didn't go and look at them um i didn't do the quality control part of the installation so would i have walked past a bundle of
00:16:10 would i have walked past a bundle of insulation possibly i don't know um but i wouldn't noted i didn't know that kingspan was on there no were you on top of what orders were coming in even just from a documentary
00:16:21 coming in even just from a documentary review remote from site no because the materials predominantly are ordered by the subcontractor and they control their materials um you know the amount they
00:16:34 materials um you know the amount they need when they need them et cetera et cetera so
00:16:36 cetera so we wouldn't have a system where we booked in their materials and checked off
00:16:40 off how much was on site how much was it on site right so if for example harley had ordered on to site a quantity of for example king's band cool firm k-15
00:16:53 king's band cool firm k-15 on a date you wouldn't know whether yeah it'd be very unlikely that i know yeah
00:16:59 yeah i know and who at ryden would have their fingers on that information it would be one of the site team one of the sides so either simon o'connor or whoever's dealing with that element at that time
00:17:09 that time okay do does that tell us that at any given time you personally at least weren't aware of what quantities of what insulation was stored on site yeah correct i couldn't tell you i'm
00:17:20 yeah correct i couldn't tell you i'm okay yeah do you do you know what the usual lead time for ordering insulation on this project was no idea right um can i then go back to a different
00:17:31 um can i then go back to a different topic which is your contractual relationship with harley um we've discussed already your role in involving managing contractual relations we looked a paragraph
00:17:42 relations we looked a paragraph at paragraph 45 of your statement i just want to pursue that a bit more and i think you you agreed just to set it in context that it was your responsibility to know what responsibilities other parties owed to writing
00:17:53 to writing under their contracts yes and vice versa to ensure that ryden and those other parties complied with their contractual obligations yes yes now can we look then please at
00:18:05 yes yes now can we look then please at the letter of intent that you sent to harley curtin wall limited at har five zeros one two zero
00:18:16 and if we can turn to page four of that
00:18:21 we can see a signature there yes is that that's your signature correcting and if we go um to page two of this letter and i should just before i do show you page one
00:18:33 just before i do show you page one uh it is not itself dated but we i think can sort that out as we go through the through your evidence uh but it's a letter of intent grenfell
00:18:45 uh but it's a letter of intent grenfell tower the site and it says we confirm that it is our intention to appoint you under our standard subcontract order as the envelope package subcontractor in relation to the external facade works
00:18:56 in relation to the external facade works of the works at the above site and then you can see compliance the authorized works must comply with the following and you can see a and b and then c
00:19:08 you can see a and b and then c specification page numbers as per schedule of information appendix f drawing numbers as per schedule of information appendix f and there are other things in the word in there as well which have to be
00:19:19 in there as well which have to be complied with can i then take you to page two of that under the rubric contract we confirm it says there that it is kensington and chelsea tenet management organization limited the employer
00:19:30 organization limited the employer intention to appoint ryden as the contractor to undertake the works in accordance with the jct standard form and then b the articles of agreement and subcontract conditions of dom
00:19:42 subcontract conditions of dom 2 will apply save where they are modified by the terms of this contract the draft building contract is available for inspection by you at our offices you are deemed to have notice of all of
00:19:54 you are deemed to have notice of all of its provisions and its provisions are incorporated in this contract insofar as they relate to the authorized works are you familiar or were you familiar at the time with the dom ii subcontract conditions uh the the
00:20:07 ii subcontract conditions uh the the general principle yes i couldn't couldn't state to all the different conditions in it but yes right well let's just pull them up they're at inq three zeros one one two one one
00:20:24 uh that's page one uh and that's the 2011 edition which was uh current at uh at uh 2013-14
00:20:36 2013-14 uh just looking at this first page does this trigger a recollection are you familiar with this it's it's yeah i mean it's a contract that we
00:20:49 contract that we you know you know in general principle and we refer to as and when we need to right given that you're a design and build i think ryden was a design and build
00:21:01 think ryden was a design and build business relying on subcontractors was this standard form dom to a 2011 edition a
00:21:08 a a contract you commonly used as a standard form when engaging subcontractors uh it probably was at the time if obviously if we're in a jct contract as well yes
00:21:19 jct contract as well yes now let's look at page two please
00:21:28 if you look at the right hand page two of the last paragraph it says these conditions constitute a subcontract only where the domestic subcontract dom to articles of agreement and the associated appendix
00:21:40 associated appendix have been completed uh in fact can you confirm this the domestic subcontract dom two articles of
00:21:51 subcontract dom two articles of agreement
00:21:52 agreement and associated dependents were never completed when subcontracting in harley were they i don't recall you don't recall
00:22:00 recall is it that you don't recall one way or the other or i don't recall one way or the other
00:22:03 the other right the orders and um and contracts such as this are put together by the commercial department and then obviously my signature goes on
00:22:15 and then obviously my signature goes on they on the bottom of them right well when you did sign the bottom of the letter of intent referring to the sub subcontract referring to the subcontract conditions of dom 2
00:22:26 of dom 2 applying did did you on behalf of ryden intend that these terms would apply um yes i'm sure we did
00:22:41 um yes i'm sure we did let's look at page 8 and condition 2.4.1
00:22:47 top left materials goods and workmanship all materials and goods for the subcontract other than the part that are often priced in the subcontractors designated works shall so
00:22:59 subcontractors designated works shall so far as procurable be of the kinds and standards described in the subcontract documents all materials and goods for the subcontractors design works shall so far as procurable kinds and standards described in the sub in the contractors
00:23:11 described in the sub in the contractors requirements or if not they're specifically described the subcontractors proposals or documents referred to in clause point in clause 2.6 provided that the subcontractor shall not substitute anything
00:23:21 anything without the contractor's written consent but no such consent will relieve the subcontractor of his obligations under this subcontract uh i've read that at length there's quite a lot of
00:23:32 quite a lot of legal verbiage there but i just want to see how that matches up when you go back to the letter of intent please at har50 is 120
00:23:45 you can see that it says at page one uh that the authorized works must comply with the following c and i read this to you earlier specification pages as per schedule of
00:23:57 specification pages as per schedule of information appendix f and i showed you before the the provision that says that you're deemed
00:24:08 provision that says that you're deemed to have all that notice of all the building contracts provisions now the schedule of information appendix f let's look at that that's at h a r 50396
00:24:24 if we could just have that up har50396 here is appendix f
00:24:36 and this comes from from you mr lawrence can i take it that you are familiar with this schedule and its content
00:24:44 content uh yes this is a this is a ryden appendix it is and it this is this is part of the information which you were telling harley in your contract with harley that needed to be yes which
00:24:55 with harley that needed to be yes which is
00:24:55 is then this is put together by a commercial department but yes indeed but you signed it yes uh and you can see uh the third entry down under specifications you see it says
00:25:08 under specifications you see it says section b specification and design requirements so that's incorporated yes
00:25:16 yes so you're not yes sorry yes yes was it your understanding that this was a reference
00:25:21 reference to the section of the building contract between the tmo and ryden entitled entitled section b specification and design requirements yes i would expect it to be back to back
00:25:32 yes i would expect it to be back to back with our contract thank you let's turn to that then that's tmo
00:25:37 tmo one double zero four one seven nine one page two
00:25:46 under contents we can see part two if we look at that uh section b specification and design requirements
00:25:57 requirements so that's where the reference feeds through if you look at page 179 please within section 2b we can here see that it provides as you can see from the top of the page
00:26:08 can see from the top of the page architectural employer requirements are contained within and then you can see architectural nbs and appendix a architectural and room data sheets in appendix a room
00:26:20 and room data sheets in appendix a room data sheets seeing it then in both contracts and i've shown you both sides of the of your contracts contracting and contract out was it your understanding that harley
00:26:32 was it your understanding that harley was required by the letter of intent to construct the authorized works in accordance with the nbs specification yes as we've already seen the nbs
00:26:43 yes as we've already seen the nbs specification specifies at h92 power 776 that the thermal insulation must be celetex fr5000 we've seen that this morning yes so
00:26:55 we've seen that this morning yes so would it follow and do you accept that if harley were to substitute a different insulation product for fr 5000 then they would need ryden's written consent
00:27:06 written consent yes and within ryden that would be you wouldn't it who would have responsibility as contracts manager for providing that written consent um probably oh well
00:27:18 um probably oh well yeah probably ultimately but it would go to it'd probably go to the site team it would then go and be checked by the architectural team um
00:27:29 the architectural team um so we wouldn't had i known it was changed and i'm not sure when it was changed
00:27:36 i know there is some discussion and i know this from the documents that there may
00:27:41 may it may have changed post my
00:27:45 leaving the project but i wasn't aware that it changed prior to that but we're just going to come to that but thank you for sorry no no it's it's uh it's good that is
00:27:56 no no it's it's uh it's good that is where we're going now we know that celetex fr 5000 insulation was specified on grenfell tower
00:28:04 tower at h9276 776 and we've seen that and we also know that celetex rs 5000 was installed as insulation now did you know that on
00:28:16 as insulation now did you know that on the 26th of may 2015 the precisely it doesn't matter 96 sheets of k-15 kingspan cool firm k-15 were ordered by harley
00:28:26 harley from sig sig the supplier for delivery on the 4th of june 2015. no you didn't did you know that and
00:28:37 no you didn't did you know that and unless they're in somewhere else in the spec and they were for the lower floors but no i didn't i didn't know they were sorry the answer the question is no i didn't know they were ordered thank you on the 10th of september 2015 and again the precise day doesn't matter
00:28:49 and again the precise day doesn't matter but you could because you were still there
00:28:51 there for a month and a half or so before you left did you know that at that time 49 units of kingspan cool for coolfam k15
00:28:59 k15 were ordered by harley from ccf this time
00:29:03 time no no i i was aware just to fill that story out slightly more i was became aware at the end prior to me leaving
00:29:14 to me leaving that harley were in the
00:29:18 financial difficulties were in the process of of changing companies i was aware of that
00:29:25 that and i made that aware as soon as i found out i made that aware to steve and that steve had already already knew that ahead of me were you aware of any discussions uh either
00:29:35 either on site or between people on site and the architectural team as you re as you call them about the substitution of uh rs 5000 with
00:29:47 of uh rs 5000 with cool therm k-15 no i didn't know k-15 was involved at all until the evidence has come up can you explain why that is why i didn't know
00:29:59 why that is why i didn't know well first of all can you explain yes why can you explain why you didn't know um well i wouldn't necessarily see all the materials on site anyway um
00:30:10 on site anyway um unless i particularly walk around and we're looking for them which i which wouldn't necessarily be the case at that stage in come september i think i
00:30:22 i um i remember the precise date that i left
00:30:26 left um it was october sometime um but there was an overlap between me steve daviews and me leaving and then coming in so
00:30:37 and me leaving and then coming in so um yeah i i wouldn't have i didn't know that there was a kingstown on site no but you're not knowing would be a lapse wouldn't it in the in the contractual arrangements
00:30:50 the contractual arrangements somebody from somebody from ryden yes but there was an overlap when i say you're when i say your contractual i say the contractual arrangements i i mean ryden's actual arrangements both up and down yes
00:31:01 actual arrangements both up and down yes we should if they substitute the material with them yes we should know yes and to your knowledge did harley ever seek permission either in writing or otherwise to substitute um fr 5000 for kingspan cool phone k-15
00:31:13 um fr 5000 for kingspan cool phone k-15 not related to me i didn't didn't know if they had asked anybody
00:31:18 anybody who would it have been to the best of your knowledge uh well it probably would have ever been well simon o'connor probably was left as well by then it would have been it probably would have come to me
00:31:29 it probably would have come to me or at that time it would have gone to steve
00:31:33 steve dave hughes maybe um right have you any explanation as to how that product came to be on this building i think i i think i might have an insight now
00:31:44 insight now from since the disaster and since the evidence has come up and i think it's relating to their um their credit limit
00:31:56 um their credit limit and and harley's ceasing to trade one company and and starting with another but it was not something under the time right thank you uh now can i just ask you to look at mr
00:32:08 uh now can i just ask you to look at mr hughes's witness statement he's going to be coming
00:32:11 be coming to give evidence but i'll just show you a passage in his statement it is this is ryd3094213
00:32:22 and i'd like you to look at page 10 please paragraph 55.
00:32:27 now i should just preface my questions by making it clear to you that this is after your time at ryden mr lawrence but at page 10 paragraph 55 he says in december 2015
00:32:39 10 paragraph 55 he says in december 2015 or
00:32:40 or january 2016 i discussed with ben bailey and agreed the use of kingspan as harley's had difficulty obtaining celotex from their supplier as far as i was concerned kingspan and celetex are similar products with
00:32:52 celetex are similar products with similar insulation properties as far as ben and i were concerned it was a like-for-like swap of insulating material
00:32:59 material i told steve blake and the clerk of works john white of this use of kingspan insulation material now we know from the records as we've been through already that k-15
00:33:10 as we've been through already that k-15 was used during the period you were contracts manager so an earlier period of the period mr hughes is talking about here did you have any views at the time about whether
00:33:22 whether k-15 was a like for like swap with rs 5000 or fr 5000 today i didn't know it was on titan i didn't reviewed about it
00:33:33 did you know that kingspan uh is a polyurethane rigid foam whereas celotex rs5000 is a is a polyisocyanurate or p.i
00:33:45 polyisocyanurate or p.i wouldn't have known that technical difference though they look very if you were to see them side by side visually they would look similar right and i'm going to ask you now about the labc
00:33:57 i'm going to ask you now about the labc certificate related to these products did you uh well let's have a look at it kin30s 16733 please this is the labc certificate for
00:34:09 this is the labc certificate for kingspan cool thumb k15 rain screen board and this is issued or was he sort of issued on the 30th of march 2015 for this product
00:34:21 this product and we see that at the bottom of page one
00:34:24 one first issued on the 28th of august 2013. do you remember seeing this document at the time of your involvement on the grenfell tower project no i've not seen it since right
00:34:38 now we know this wasn't part this product wasn't part of the nbs specification and and we know that you as contracts manager had not seen any certificate in relation to it
00:34:49 relation to it can you explain how an insulation product is going onto this building in circumstances where it wasn't specified
00:34:58 specified and you didn't know about it or you didn't you hadn't seen a certificate for it
00:35:05 sorry can i explain how it how it was happening well i wasn't overseeing as in i wasn't on whilst i might have been on site in the office working i wasn't standing
00:35:16 in the office working i wasn't standing there managing the the package works that would be one of our site managers so i wouldn't necessarily see
00:35:27 so i wouldn't necessarily see see the product either be delivered or actually be installed is now the first time you've ever seen this certificate i believe so yeah i don't see it don't recall seen it before because you said
00:35:38 recall seen it before because you said you hadn't seen it since am i assuming from that you didn't see it at the time all since two i don't think i've seen
00:35:46 let me just try a couple of things out on you i know you on the caveat that i understand you haven't seen this document before can i can i ask you to look at page two
00:35:58 can i ask you to look at page two conditions of certificate
00:36:02 uh a third of the way down they start and two-thirds of the way down we can see
00:36:10 see in bold it says from bba 084582 tested to bs
00:36:15 to bs 8414 and then there's a a long description of the system test and its component elements
00:36:29 those were different those component elements from the components of the system going on to grenfell tower it's self-evident that that's the case but can you confirm that yes yes
00:36:40 but can you confirm that yes yes um and does it follow from your not ever having seen this and i suppose it would have to that you never investigated yourself whether the k-15 insulation product had been tested
00:36:51 product had been tested to br 135 in accordance with the criteria in bsa414 yeah correct and if we look at page four
00:36:59 page four under adb uh it it it says uh just about two thirds a third of the way down the page fire safety thermosetting insulins rigid
00:37:10 safety thermosetting insulins rigid polyurethane foam boards do not meet the limited combustibility requirements of adb2 table a7 and so should not be accepted as meeting adb2 paragraph 12.7 however if they're included as part of a
00:37:22 however if they're included as part of a cladding system tested to be r135 and bsa414 for use above 18 meters the complete assembly may ultimately prove to be acceptable uh
00:37:33 prove to be acceptable uh d do you accept that the kingspan cool them k15 doesn't meet the limited combustibility requirements of adb too i'll have to through the documents and therefore the
00:37:44 and therefore the linear route to compliance as you think i think you described it on thursday would could not have been met by using this material agreed
00:38:00 and i think it follows from all of your answers so far on this material that you yourself never conducted any investigations to satisfy yourself that this insulation was compliant with the building regulations that correct
00:38:11 regulations that correct in the context of this project yes
00:38:20 now can i take you back to paragraph 51 of your witness statement
00:38:34 uh you say that uh
00:38:39 and this is back to the obviously wrong in the
00:38:42 in the fifth line from the end you say although i have no expertise or qualifications as a designer my experience as a construction manager meant that if i saw something that was obviously wrong that i would challenge that and i would have expected the rest
00:38:53 that and i would have expected the rest of the writing team and indeed all of those involved in managing the project to do the same this is a hypothetical question but i feel i need to ask it but had you seen
00:39:05 feel i need to ask it but had you seen the labc certificate at the time would that have
00:39:08 that have jumped out at you as being a product which was obviously wrong for this project can i see the front page of that label you met please
00:39:21 label you met please yup it's already back no indeed it's back at
00:39:27 seven three kin30s16733
00:39:44 i think i think pretty much the same as the the celetex there
00:39:52 it's fairly misleading unless you read and fully understand all parts of that certificate i think that's that's slightly misleading that it gives the impression
00:40:04 misleading that it gives the impression in the first description of product that it is
00:40:08 it is for use in buildings above 18 meters but i would expect that the if the product was substituted that it would be
00:40:19 product was substituted that it would be checked by the correct design team members and building control
00:40:30 now we've already discussed ryden's obligation to obtain approval before substituting alternatives to specified products and we've discussed uh that the
00:40:41 and we've discussed uh that the specified product was fr 5000 which became rs 5000 in august 2014. um who did you understand
00:40:53 august 2014. um who did you understand you had to get approval from you personally within ryden before ordering or allowing the installation of kingspan cool firm k-15 onto this building
00:41:04 onto this building before ordering yes before allowing it onto the building um well i would go through had i known and it had it have
00:41:15 through had i known and it had it have been
00:41:16 been yeah i would have i would have seek i would have spoken to the architect i would have spoken to got that all checked that it was compliant before proposing it to the client
00:41:29 proposing it to the client or advising the client that that's what we're intending to use yes are you aware uh from your recollection of any discussions at all that you had with the architects or harley
00:41:40 with the architects or harley or anybody about the suitability of this product
00:41:43 product no because i didn't know it was uh now i want to turn to a different subject uh which is uh
00:41:52 lacking house you mentioned it briefly as we discussed it very briefly at the beginning of your evidence on thursday can i ask you to look first please at art
00:42:03 art 403042
00:42:07 this is an email from claire williams to philip booth and nick valente on the 12th of november 2014.
00:42:18 and you're not copied in on this but i'm reading it to you by way of a background mr lawrence and she she says chaps
00:42:28 windows when i delivered the building contract to site yesterday i met up with ryden and matt smith yesterday had a window discussion i'm looking to take this report to peter madison and david gibson but i'm waiting
00:42:40 madison and david gibson but i'm waiting for ryden to verify that the proposed windows will meet building regulations cladding i have just been looking at the cladding as our database is asking for costs i've put something together however i do
00:42:52 i've put something together however i do not know if there is any issue of flame retardance requirement i know at lagnal house one issue was that the replacement paneling for the asbestos cladding was not flame retardant
00:43:02 retardant i don't know if this is in the specification but want to make sure it is raised please advise now were you first of all were you at the meeting that she refers to here
00:43:14 the meeting that she refers to here uh regarding the windows well the when she delivered the building contract to site she met up with ryden were you one of these people for whether it was uh
00:43:23 it was uh i don't know if i was on site that day or whether it was simon o'connor right do you you don't recall independently sitting here whether or not you were one of those people who met claire williams at that time because obviously it was clear coming to saw it was a
00:43:34 saw it was a regular occurrence so i think okay um did you have an understanding that tmo was relying on ryden to verify that the proposed
00:43:46 ryden to verify that the proposed windows would meet building regulations uh that yes that's in that's in relation to
00:43:53 to changing the size of the windows um and i think though you know we're in the process of checking as to whether it was a a feasible change
00:44:05 as to whether it was a a feasible change right did ryden provide the verification that ms williams thought do you know i believe we did but i couldn't point you to the document right okay did you understand at the time
00:44:16 okay did you understand at the time never mind whether it's windows or anything else that the tmo was relying on ryden to verify compliance with the building regulations yes
00:44:32 she goes on to say under the cladding paragraph and i've shown you that was the issue of fire performance of the cladding ever raised with you yourself personally either by
00:44:43 with you yourself personally either by artelia or by the tma uh i believe it was raised by claire but it was very specific to the element that it was raised against yes uh well let's look at that
00:44:55 against yes uh well let's look at that ryd
00:44:57 ryd triple zero two three four six eight this is an email from claire williams to you the same day 12th of november 2014
00:45:10 i've copied to philip booth at artelia grenfell cladding
00:45:16 simon i'm just writing to get clarification on the fire retardance of the new cladding i just had a lachnal moment and then she sets out what looks like
00:45:27 and then she sets out what looks like a cutting paste or an extract from the nba specification where it refers to compliance standard at the center for windows and cladding technology standard for systemized building envelopes
00:45:39 envelopes etc there's the rest of it there when you receive that email what did you understand claire williams to mean by a lachnal moment
00:45:51 moment well i knew that um i think the references the other day i knew that i'd heard that there was a fire at latino some years before but i didn't know the specific details so i knew it was relating to fire
00:46:03 so i knew it was relating to fire right and you knew you knew it was relating to fire did you also know that it was relating to fire in the context of the fire retardance of the new cladding no
00:46:14 retardance of the new cladding no she says that though i'm writing to get clarification on the fire retardance of the new cladding i just had a lack of a moment
00:46:21 moment so putting the question so yes what what connection did you make between the fire if any between the fire retardance of the new cladding and lachnal house uh only the fact that
00:46:33 lachnal house uh only the fact that lucknow house had had a fire no more connection than that
00:46:37 that right but this email to me relating specifically to the grc cladding at the bottom section of the tower
00:46:49 tower is she not cladding not cladding overall because there'd also been a conversation there had been conversations around
00:47:00 there had been conversations around claire and the tmo's concern about the robustness of the cladding on the lower floors
00:47:06 floors of the building and the concern from external fire i um bins and ex et cetera et cetera
00:47:18 bins and ex et cetera et cetera how do you sorry sorry currently no you've finished your answer yes how do you get that from the email how do you get from the email that her concern arising from her lateral moment related only to the fire
00:47:31 lateral moment related only to the fire retardance of the cladding on the lower parts of the bill because it says grc products the bit where it's copied and pasted it says guide it says compliance and recommendations of grc 8 publications
00:47:43 of grc 8 publications and then it references the grc products well the grc products were only used on the bottom i don't know three metres six meters of the of the building around the columns at the bottom and there was also
00:47:55 the bottom and there was also another conversation and i i can't tell you the time scale but there was another conversation involving claire um and others around the robustness
00:48:06 and others around the robustness of the lower sections of um cladding external treatment around the entrance of grenfell and the concern she'd expressed concern
00:48:20 and the concern she'd expressed concern and i think this might only be verbally i'm not sure if there's any any email trail on this um about
00:48:30 um about because they stored bins and etc um around the lower floors and they were concerned about if anything happened there whether that would cause an issue
00:48:42 from the lower floor floors right i don't think there's any reference in your witness statement to the context of this email being a discussion about planning on the
00:48:53 being a discussion about planning on the lower four floors only i don't know if it mentions it in this
00:48:58 this all right well sorry it specifically says in there i read and having reviewed this since it specifically says grc products yes uh it also says compliance standard
00:49:11 yes uh it also says compliance standard the center for window and cladding clouding technology cwct standard for systemized building envelopes
00:49:18 envelopes uh what did you get out of that reference
00:49:21 reference in the context of her lateral moment i got i got out the that it was relating to the glc products and i'd like to say i believe
00:49:32 i believe that well i believe i know that there was a conversation at the time because we were looking that there was a design conversation going on in the background about whether grc products
00:49:45 about whether grc products could be substituted for renabond or a another and there was a long conversation about whether stainless steel was acceptable whether relibond was acceptable
00:49:56 relibond was acceptable whether they had stick with glc products
00:50:01 right so i read that as grc products only maybe wrongly that's how i
00:50:12 maybe wrongly that's how i it and read it now we have no record of any response by you to her question or request for clarification
00:50:23 question or request for clarification if i can put it that way uh is that right did you respond we can't find any record of it
00:50:34 on the basis that um there isn't any record of a response by you why is there no record of any response by you to her lack of moment question i don't know
00:50:46 question i don't know i i would have assumed that i would have taken that email because i wouldn't have answered it directly and i would have passed that to probably harley's so whether there is
00:50:59 probably harley's so whether there is other emails around the date or not connected i don't know well that's normally i would have expected to just take that email and i would forward that straight to
00:51:10 and i would forward that straight to harley's and i would keep claire copied in
00:51:12 in so if there was any backwards and forwards correspondence then that would it would be presumably you've had quite a long time before today to think about this email
00:51:24 yes i've seen it previously yes and you've had quite a long time to examine the documents in the inquiry to see whether there are in fact any records of you responding to her or you sending it on to harley
00:51:35 on to harley correct casting your mind back can you do you remember looking at the compliance standard cwct standardized for system systemized
00:51:46 standardized for system systemized building envelopes at least to give her an initial answer to her request for clarification no i would i would have taken that email because it's not one that i would i could answer from a technical point of
00:51:57 i could answer from a technical point of view i would take that email and i would pass it on to i think i would have passed that onto harley's you think sitting here now you would have done if yes if i if that come to me now
00:52:09 if yes if i if that come to me now then i would take that and i would pass that straight to harley's and i would keep
00:52:13 keep claire and philip copied him claire particularly copied him so they could respond accordingly to her because i couldn't provide a response to that
00:52:22 that uh i understand that uh so you say you would have sent it to harley we find a record of you passing it on to harley to saying please please help me advise my client
00:52:30 my client can you explain that right
00:52:37 you had seen the bba certificate back in april when mark harris sent it to you 23rd of april 2014 mr lawrence can you explain why you didn't at least
00:52:49 can you explain why you didn't at least tell her
00:52:51 tell her that rayna bond fr panels fire resistant panels were of also available i think i've answered this previously i didn't know they were available right
00:53:02 didn't know they were available right now if we look at mr cash's witness statement he's from artelia i just want to look at one thing in it
00:53:12 art406544 page 58 please
00:53:22 paragraph 186 uh
00:53:35 he says and it's quite a long paragraph but this is the background to it but four lines down he says on the question of cladding or on cladding
00:53:46 question of cladding or on cladding philip
00:53:47 philip that's phil booth said that he had a quick review of the specification in the tender documents for cladding and quoted various compliance standards for cladding saying he anticipated one of those standards would require flame retardance
00:53:59 standards would require flame retardance he said that as the client claire williams should seek clarification on her question from ryden this was the right approach it was for ryden as the contractor to address claire williams's questions
00:54:10 claire williams's questions first of all do you agree that it was ryden's role to address claire williams's questions uh the email was
00:54:17 was directed at us so yes yeah and your job within writing to address those questions on writing's behalf correct yes there's no reference in
00:54:29 correct yes there's no reference in mr cash's statement to the request for clarification being limited only to the lower four floors we can see that are
00:54:40 lower four floors we can see that are you quite sure that this discussion this request for clarification really was limited to the level four floors well the email directs me to grc cladding and grc cleaning was only
00:54:51 cladding and grc cleaning was only on the lower it probably wasn't even lower four floors it's probably the lower floor around the columns
00:54:58 well we may need to revisit that i'd have to look at the drawers to find how many floors it the glc cladding covered but it was it was definitely the the lower three
00:55:09 it was definitely the the lower three meters four meters five meters right and you're definite about that are you
00:55:14 you without looking at the drawings i can't tell you how many meters but i i definitely know that the specification was relating to the bottom section of the cladding yes bottom section of the envelope here
00:55:25 bottom section of the envelope here can i ask you then just to look at the nbs specification at age 92
00:55:33 which is at
00:55:46 clg
00:55:51 uh i just want to show it to you uh if someone could behind just provide me with a reference for that it's sea 50169 and i'd like you to go please to
00:56:05 page 69.
00:56:09 i just want to pick up and follow that answer through this is where we see the cwcc standard for systemized building envelopes and this is in the context of h92 rain screen cladding
00:56:29 and under 342 contractors design of rain screen generally
00:56:38 and we can see there the design standard to
00:56:43 to standard for systemized building envelopes
00:56:46 envelopes there's nothing in there about the lower floor floors only so can we pull up the part the specification that relates to grc cladding
00:56:56 cladding well we we can perhaps after a break when i put my fingers on it so perhaps we can leave that there let me let me go back into the uh the the line of the evidence i did want to show you
00:57:07 want to show you uh it's uh tmo 50887 at page 18 please which is the witness statement of david gibson of the tmo i'd like to look at paragraph 95
00:57:26 i'd like to look at paragraph 95 and he says there uh i recall however at one of our monthly design development meetings
00:57:31 meetings simon lawrence of ryden indicating that there was disparity between the delivery times
00:57:36 times for insulation and rain screen and to avoid delaying the project he indicated their intention to install the installation first and fit the rain screen later and then at paragraph 96 he goes on this was the first i was aware that the two items
00:57:47 first i was aware that the two items were separate and it raised some concerns in my mind having then recently read recommendations following the latino house fire inquest where i underst i understood that a gap between the insulation and the rain screen had
00:57:58 insulation and the rain screen had created a chimney flu effect which contributed to the fire spread you see that and then he goes on
00:58:05 goes on uh i'd understood in the next paragraph the sample cladding to have rain screen uh flush with the insulation as it came a surprise to me to learn that they were fitted separately
00:58:16 fitted separately and then if you go to paragraph 98 over the at the bottom of the page i raised this with simon lawrence as a matter of serious concern i'm sorry it's at the bottom of the previous page peron98
00:58:29 previous page peron98 uh i raised this with simon lawrence as a matter of serious concern and asked him if he could give some assurance that we would not have a lack of type problem with the separation of rain screen and insulation
00:58:40 do you recall mr gibson raising this matter with you at a meeting not at all no right rain screen by the nature of range green there is a gap between rain screen and
00:58:51 there is a gap between rain screen and the insulation so no i don't record this at all right
00:58:57 and over the top of page 99 mr gibson says
00:59:01 says the meeting was chaired by philip booth of artelia and simon lawrence assured us that this would create no problem because the materials used were completely inert and would not burn at all
00:59:11 all the meeting accepted his assurances in this regard and nothing came to my notice subsequently prior to the fire to question that these assurances were not accurate did you give such an assurance to mr
00:59:23 did you give such an assurance to mr gibson no
00:59:24 gibson no i don't agree with that statement at all do you recall seeing the minutes which match this description no because he refers to those in paragraph 100 he says the minutes of this meeting were
00:59:35 says the minutes of this meeting were produced by artelia and they definitely existed because i couldn't recall reading them i recall that lachlan had been spelting correctly in the minutes i understand these minutes cannot be located in the tmo files
00:59:46 located in the tmo files and i think you're saying you're clear in your mind you've never seen such minutes
00:59:50 minutes right
00:59:54 at paragraph 101 mr gibson says i have a clear recollection of the discussion and of the minute recording it and he explains
01:00:02 explains uh why and then he goes on to say in the middle of that paragraph until the occurrence of the fire at grenfell tower i had always believed the cladding installed was inert as had been assured by simon
01:00:15 was inert as had been assured by simon lawrence and i had no reason to consider otherwise
01:00:18 otherwise i cannot recall the date of the meeting but i have given some details in my statement as to when it was i think it may have been about march or april 2015 or possibly earlier that's that's his
01:00:31 or possibly earlier that's that's his witness statement
01:00:34 can you comment on that i don't agree with it at all right so you say mr gibson is wrong yes right now leaving aside mr gibson's recollection did you ever yourself personally assure
01:00:48 did you ever yourself personally assure him that the cladding at grenfell was to use his word inert not i wouldn't give technical assurances unless i had that information from
01:01:02 the designers or specialists no and what uh questions did you ever ask studio e
01:01:14 questions did you ever ask studio e well let me put it a slightly different way do you have a recollection of ever asking the the question of studio e about the inertness
01:01:22 inertness or urtness of these products no what about xova right mr chairman i'm going to turn to the question of cavity barriers next
01:01:34 to the question of cavity barriers next well that's which may be a convenient moment
01:01:36 moment for a break there is as you'll probably have told there's a reference i just want to check if i'm unable to do standard stranded here
01:01:43 here as it were i'll give you an understanding a couple of minutes to do that we'll have a break now mr lawrence we'll come back at um 20 past three and uh
01:01:52 uh you gave the usher no talking about your evidence all right thank you very much
01:02:05 all right 20 plus three
01:18:33 yes would you ask mr lawrence to come back please
01:18:49 all right ready to go on mrs lawrence yes thank you yes thank you mr chairman mr lawrence thank you uh can i ask you i'm going to go back to the latter moment email if i may and i want to look at that side by side with the nbs
01:19:00 at that side by side with the nbs specification which is an exercise i was vainly attempting to do before on my feet before the break and i'm glad i didn't if you go to ryd-3023468
01:19:12 this is the email and i wonder whether we can have that on the left-hand side of the screen
01:19:20 so we can see it and on the right hand side can we please have sea 50169 uh at page 55. and what i want to do mr lawrence is
01:19:31 and what i want to do mr lawrence is just to explore with you uh really uh the where we see these references in claire williams's email in the nbs specification do you see it's
01:19:43 in the nbs specification do you see it's a
01:19:44 a it's a slightly involved comparison exercise
01:19:48 exercise um page 55 is what we see on the right hand side which is part of the nbs spec h40 entitled glass fiber reinforced concrete cladding stroke components
01:20:01 concrete cladding stroke components just working our way through to the next page of that
01:20:06 h40 glass fiber reinforced concrete cladding components 130 we can see types of cladding components proprietary grc components column cladding and then you can see
01:20:18 cladding and then you can see the grc components are set out there and grc stands for glass reinforced concrete
01:20:26 concrete correct right and if you go over the page please to page 57 and look at general requirements preparatory work
01:20:38 preparatory work paragraph 205 contractors design of cladding to columns in the last bullet point there you see additional requirements comply with the recommendations of grca
01:20:49 comply with the recommendations of grca publications specification for the manufacture curing and testing of grc products and guide to fixings for glass fiber reinforced concrete cladding now just looking at that and then
01:21:02 now just looking at that and then casting your eye to the left of the screen
01:21:05 screen you can see that the words in claire williams's email comply with the recommendations of grca publications specification for the manufacture curing and testing of grc products and guide to
01:21:17 and testing of grc products and guide to fixings for glass fiber reinforced concrete cladding uh comes straight out of this part of the nbs specification correct i mean now you've put two this two side by side you can see where
01:21:29 two side by side you can see where her reference to the grca publications comes from now we have looked through age 40 and cannot find any reference in that section of the nbs specification
01:21:40 in that section of the nbs specification to
01:21:41 to the compliance standard center for window and cladding technology cwct standard for systemized building envelopes that comes from h42
01:21:54 from h42 sorry h92 i'm sorry on page 69 i'll just pick this up there page 69 please
01:22:04 this is h92 rain screen cladding we looked at this earlier in your evidence at 310 cwct standard for systemized building envelopes
01:22:15 envelopes you see that there and then
01:22:22 part six fire performance
01:22:26 so that was the compliance standard there and if you uh look uh on to the next page
01:22:42 you can uh you don't see it there but you do also see this reference elsewhere in h92 my point is it's not in the h40 section
01:22:51 section on glass fiber and therefore will you accept that given that it's in h92
01:22:59 h92 the reference in claire williams's email to the compliance standard which isn't in age 40 where you find the gw grca publications
01:23:10 gw grca publications uh is a is to be taken as a reference to the whole of the building envelope and not
01:23:14 not just the building part of the building envelope around the lower four floors well
01:23:18 well i don't accept it because i don't think it's clear but i read it as the glc
01:23:27 mr lawrence it looks as though what um miss williams has done is to take some language from the general planning uh section and some language from the
01:23:39 uh section and some language from the lower section and splice them together but
01:23:43 but without perhaps explaining why she's just put together in that way
01:23:50 yes and if um if you look at uh to be fair to you there are references to cwt standards in other parts of the nb aspect which don't deal with the upper floors for example
01:24:03 deal with the upper floors for example curtain walling and i just wanted to be fair to you to show you page 47 which is h11 if we could just have that up please
01:24:20 uh and that's curtain walling and you can see
01:24:23 can see uh there under 325 the deflection under wind load but in fact actually it's at the top of the page as well if you go to the top of the page which has disappeared now
01:24:34 page which has disappeared now uh design performance requirements 305 cwct standard for systemized building envelopes
01:24:41 envelopes and you've got them all set out again so that obviously does apply to the curtain walling which is the lower part of the building and then the bottom of the same page please
01:24:54 uh deflection under wind load you see the reference again there cwct standards but just to be clear to t for you uh the cwct
01:25:05 cwct appears not in the uh part dealing with the
01:25:09 the glass reinforced concrete does appear in h92 dealing with the whole of the envelope
01:25:14 envelope uh but also does appear in that part dealing with curtain walling so it appears in various different parts and having shown you all of that my question is really um this is is the is what
01:25:26 um this is is the is what claire williams was sending you uh what the chairman has really essentially put to you which is that these standards have been selected uh from different parts of the nbs and put together in an email
01:25:37 put together in an email so that they're not only related to the lower four floors but the whole of the building
01:25:42 building well that's not how i understood it right um i think claire is probably the best place to explain what she was meaning by the email but that's that's not how i took it i would
01:25:53 that's that's not how i took it i would focus
01:25:53 focus i did focus on the grc part of it all right
01:25:58 right i just wonder why you focused only on the grca
01:26:01 the grca part of it when the reference to compliance standard cwct is found elsewhere in the nbs bank including that h92 rain screen cladding i i don't think
01:26:12 h92 rain screen cladding i i don't think at the time i would have picked up the nbs spec
01:26:15 nbs spec and would have known that glass reinforcing glass reinforced concrete
01:26:22 concrete was also i believe known as cladding and it is it says in their guide to concrete cladding so i think i probably could have reasonably
01:26:34 gathered that the fact of the cwct and it it's referencing cladding in there that
01:26:39 that it wouldn't necessarily be specific about
01:26:42 about rain screen and or curtain walling and wouldn't also apply to the grc i would have glc is a bit that stands
01:26:53 i would have glc is a bit that stands out to me
01:26:54 out to me on that right now okay so let me just see if i can keep going on this for just a moment longer can you go back to page 60 or go to page 68.
01:27:04 68. we looked at this i think on thursday in your evidence page 68 please of the sea 169 document the nbs spec and this is 220 specification and here it says compliance standards
01:27:17 and here it says compliance standards the center for window and cladding technology cwct standard for systemized building envelopes that is an exact cut and paste into claire williams's email
01:27:27 email and this is about h92 rain screen cladding
01:27:31 cladding so i'm putting it to you that actually what she was after was fire retardance of the new cladding up and down the building lower floors and all floors upper floors
01:27:42 lower floors and all floors upper floors too
01:27:44 well i agree now showing me that there was copy and paste from the specification yes i do agree with that i don't agree that the email is clear but
01:27:53 but regardless where the email is no not regardless i picked out the grc part of it that's the bit that stands out to me as being specific and i wonder why you
01:28:04 as being specific and i wonder why you did pick that out at the time as you now say because nothing else highlights the specific otherwise we could be talking about windows as well can we is it there's a specific reference to a product there which is
01:28:15 product there which is the grc and there had been discussions around the robustness of the lower sections
01:28:22 sections of the building you say that i'm just asking you why you didn't pick out the first item on the list compliance standard cwct which appears because the grc bit stands out
01:28:34 because the grc bit stands out to me more and the fact that it also is glass room glossary glass fibre reinforced concrete cladding now without me putting those sorry without
01:28:46 without me putting those sorry without me putting those finding those exact lines in an nbs specification i don't think i don't think it's clear and quite frankly
01:28:57 and quite frankly i wouldn't have answered that myself anyway i wouldn't be able to answer that myself anyway i would have passed that to the design team for them to confirm the uh fire retardant yes
01:29:08 confirm the uh fire retardant yes you see mr lawrence our problem my problem standing here when asking you about this recollection which doesn't appear in any documents is really to go on what i've got in front of me on the screen but uh you say what you say just going
01:29:22 but uh you say what you say just going to the question then she wants clarification on the fire retardance of the new cladding she's not limiting her request to the lower four floors of the building is she
01:29:37 no but i think it
01:29:42 we we're rightly so pulling apart an email
01:29:46 email word by word and trying to understand and assume what is meant by that when i received that email i rightly or wrongly i focused on the
01:29:57 i rightly or wrongly i focused on the grc part of that email and there was also discussions going on in the background regarding the robustness of the low floors
01:30:06 floors so that's how i interpret it whether we put it apart word by word um i'm not saying you're you're wrong just a minute but i'm just
01:30:17 you're wrong just a minute but i'm just telling you how i read that email rightly or wrongly how i read that email in the context uh in the context of the question which refers to the lack of moment what was it about lachnal that was limited only to the lower four
01:30:29 that was limited only to the lower four floors i don't know enough about lacking all that can all suggest to me just fight so just her another way of emphasizing fire yes i don't know enough about that
01:30:42 fire yes i don't know enough about that house to be able to comment on on what happened and whether it was a lower floors top floors or anything i don't know nothing about it mr lawrence forgive me for this question uh i'll move on from it but i feel i do
01:30:53 uh i'll move on from it but i feel i do need to ask it but sitting here now are you sure that the answers you've been giving me based on this email are not an ex post facto after the event rationalization on your part
01:31:04 can i then turn to cavity barriers uh i'd like to go back if i may please to the bba certificate for renault bond pe55 which we looked at earlier
01:31:16 pe55 which we looked at earlier that's sca50516 you've already told us that i think you didn't read this document at least beyond the first page
01:31:29 so forgive me for the next question can you go to page five please and look at paragraph 6.6
01:31:42 uh barriers should be incorporated behind the cladding as required by the national building regulations but should not block essential ventilation pathways particular attention to be paid to
01:31:53 particular attention to be paid to preventing the spread of fire from within a building breaching the cladding system through window and door openings now you've already told us your understanding of cavity barriers when we were looking at the bca
01:32:04 were looking at the bca guidance document it seems like a very long time ago now but can we look at approved document b to clg50224 at page 82.
01:32:21 and when it comes uh here is diagram 33.
01:32:29 uh underneath paragraph 9.1 now you told us earlier on that you weren't familiar with diagram 33 just confirm that is that right correct i've read it post yeah let's just look at 9.1 and see if
01:32:42 yeah let's just look at 9.1 and see if you're familiar at least with the principles in it concealed spaces or cavities in the construction of a building provide a ready route for smoke and flame spread this is particularly so in the case of voids in above and below the
01:32:53 voids in above and below the construction of a building for example walls
01:32:56 walls floors ceilings and roofs as any spread is concealed it presents a greater danger than with a more obvious weakness in the fabric of the building
01:33:06 can i take it from earlier answers in your in your evidence that you you're you weren't familiar at the time with the precise words of this text correct were you familiar with the principles
01:33:17 principles at least as expressed in it uh the principles of um
01:33:24 compartmentation yes yes
01:33:29 were you aware at the time of your involvement in this project that cavity barriers play an important role in
01:33:36 role in preventing the spread of fire and smoke throughout or across a building yes
01:33:43 can i ask you to look at paragraph 9.3 over the page junctions and cavity closures cavity barriers should be provided to close the
01:33:55 barriers should be provided to close the edges of cavities including around openings then it goes on cavity barriers should also be provided a at the junction
01:34:04 junction between an external cavity wall except where the cavity wall complies with diagram 34 and every compartment floor and compartment wall at the time of your involvement in this project if not familiar with the precise
01:34:16 project if not familiar with the precise text were you familiar with this principle
01:34:19 principle i was i was familiar with when it comes to rain screen cladding that previously that we would put cavity barriers
01:34:26 barriers um in line with the compartment walls and floors of each individual property were you aware at the time of your involvement that an example of an opening would be a window
01:34:39 example of an opening would be a window uh i wasn't aware it's on there right
01:34:52 now given that you accept i think ryden was responsible for ensuring that the as built designed for grenfell tower had to meet statutory requirements so you accept that yes um and i think as
01:35:05 so you accept that yes um and i think as you also accept your personal role was to coordinate and manage the process of design though not the design itself yes and also to make sure the designs comply with client requirements
01:35:16 comply with client requirements yes given those things my question is what system or strategy did you yourself use
01:35:22 use on this project to make sure that cavity barriers were included as required on this building uh i used a specialist subcontractor he's a lead designer and we use the consultation
01:35:33 designer and we use the consultation with the building control now let's look then in the light of that at a document har 3017738
01:35:54 this is an email from kevin lamb of the third of march 2015 to you a copy to neil crawford at studio e and bruce sowns and others at harley
01:36:07 please find simon please find attached drawings now showing the fire breaks both horizontal and vertical we assume a requirement of 90 minutes integrity and 30 minutes insulation is sufficient if not please advise
01:36:21 if not please advise were you surprised to be asked this question by your specialist cladding subcontractor um i think they were just seeking clarification so i wasn't particularly
01:36:33 clarification so i wasn't particularly surprised but as with the other requests for information it would obviously be directed to me or has been directed to me but would be
01:36:44 or has been directed to me but would be i would be expecting studio e to be commenting on that right did
01:36:52 right did in the light of our discussions yesterday
01:36:55 yesterday where you were copied in on discussions between harley and studio e but didn't expect to have any input into them is that the reason why you didn't ask mr lam why he was asking you and not studio
01:37:07 lam why he was asking you and not studio e
01:37:08 e correct yes did it occur to you at this point when you saw that mr lam himself uh who was providing harley with services needed direction here that you
01:37:20 direction here that you needed to employ some specialist external specialist fire advice no i think he's i think he's stating what he believes is correct and he's asking for
01:37:31 asking for um further verification of that right so did it not occur to you to wonder why he needed advice
01:37:42 to wonder why he needed advice no i think i think it's i don't think it's unusual for a specialist or any other designer to want
01:37:55 to want other parties whether that be building control with a big studio either whoever to
01:38:01 double check their their design that their assumptions are correct and i think in particular with building control or the building regulations from my
01:38:12 the building regulations from my understanding is that they can be interpreted sometimes in different ways well you see here is your specialist subcontractor on whom you say ryden was completely reliant
01:38:24 you say ryden was completely reliant yes batting back to you or at least studio e
01:38:28 studio e and you uh a request for advice about whether their assumption about a 90-minute integrity and 30-minute insulation was sufficient did that not cause you some alarm no i saw that as a normal
01:38:40 no i saw that as a normal design process and and discussions did you look at the drawings at which mr lam attached to his email i don't know if i did at the time if you
01:38:52 i don't know if i did at the time if you hadn't done it how would you be able to do your job as you say in your statement to checking that the designs complied with client requirements i would expect studio or expect to rely on studio e to be checking the design
01:39:04 on studio e to be checking the design for a technical perspective and be advising me
01:39:10 let's see if we can we can trigger a recollection can i ask you to look at one of the drawings you were sent har403952 please
01:39:23 and if you look at the top of this drawing
01:39:29 in the middle
01:39:34 uh we can see with just within the shaded area it says firebreak and there's a long set of horizontal uh dashed lines across the page see do you
01:39:45 dashed lines across the page see do you see that
01:39:46 see that that that's it says firebreak what did you understand that to represent a cavity barrier a cavity barrier okay look at the top right hand of the drawing uh again there's a reference to
01:39:58 there's a reference to fire break what did you what did you understand that to be the same right i think they're
01:40:05 correct or or incorrect i think they're you know
01:40:09 you know words that often get exchanged right in construction i mean looking at these these drawings do these drawings trigger a recollection in your mind that you saw them at the time do you think i've seen these drawings so right okay
01:40:22 i've seen these drawings so right okay bottom left-hand corner of the drawing is another reference to firebreak again is that a cavity barrier yes i would yes i would assume so yeah
01:40:32 so when we see the word on this drawing fire break was it your understanding either specifically or on this drawing or generally that it fire break meant cavity barrier
01:40:43 fire break meant cavity barrier yes those are the terms that have been used i'd seen used previously in in previous projects so yes i see so you think there's a the word firebrick is a is an industry term is it i think it's an entertain
01:40:55 is it i think it's an entertain interchangeable term with cavity barrier you see the word firebreak is not a word that's used in approved document b
01:41:04 b did you know that uh no right in fact it's not a technical expression for a cavity barrier at all did you did you know that uh
01:41:15 did you did you know that uh not recognized expression no no i didn't know that that's that's i think that's a word that's commonly used in construction right
01:41:26 and for clarity would you accept that the word cavity barrier should have been used as opposed to fire break uh yes it says yeah right
01:41:40 now do you agree that there are on this drawing no cavity barriers at all shown around the window jam or the window sill openings they don't appear to be correct
01:41:51 and we can see the floor line marked with ffl
01:41:55 with ffl you can see that uh and we can see that the horizontal cavity barriers appear above this line uh given what i've just shown you in
01:42:06 uh given what i've just shown you in approved document b paragraph 9.3 do you agree that the horizontal cavity barrier should have appeared in line with the floor
01:42:19 sorry why are they not in line with the floor well they don't appear to be in line with the floor but the floor will be well i don't know what the floor is 150 mil 200 mil 300 mil thick
01:42:31 mil 200 mil 300 mil thick right and the the lines
01:42:35 only aligned so i don't think you can determine from that it's definitely not in line with the floor
01:42:43 floor right now
01:42:48 yeah okay all right now do you accept
01:42:54 that word fire break there could be confusing specifically could be confused with something called a fire stop
01:43:06 something called a fire stop uh i'm sure it could be right have you come across the word firebreak in the industry as interchangeable as between cavity barrier and firestop uh i have done and well and previously
01:43:17 uh i have done and well and previously at this
01:43:18 at this my experience previously was with harleys and and their terminology so
01:43:25 up to that date that might have been a learned experience from chao cots and ferrier which both involved harleys so now looking at ex0401315
01:43:39 now looking at ex0401315 we can see the discussion about fire breaks developing through march 2015 and you're involved in this and really what i want to do is just explore with you over the next few
01:43:51 explore with you over the next few questions how deeply involved you were and this is an email from neil crawford passing the issue about 90 minutes integrity and 30 minutes insulation on to terry ashton at x over
01:44:05 insulation on to terry ashton at x over now you're not copied in on this email but he sends him a selection of attachments hi terry just a quick question related to grenfell tower and then he passes on the query do you see that yes uh and he uh
01:44:18 do you see that yes uh and he uh specifically he asks in the second line can you comment on the level of protection 90 plus 30 as to whether this is suitable had you asked mr crawford to
01:44:29 suitable had you asked mr crawford to seek mr ashton's advice do you remember uh i don't believe so so as far as you're concerned sitting here you you think that he did it off his own bad yes moving forward
01:44:42 yes moving forward uh we could see uh mr crawford's response to kevin lam
01:44:48 ex0401461
01:45:00 and this time neil crawford copies you in to the email he sends him and also bruce soames and others at harley hi
01:45:11 bruce soames and others at harley hi kevin
01:45:12 kevin as per our telephone conversation i've asked the question of x over on the fire break
01:45:17 break but not had anything back to me the fire breaks would have to follow the ratings of the party walls which are shown on the fire plan attached you can see some of the lay level apartments are separated by 120 minutes and others by 60 minutes
01:45:30 and others by 60 minutes now you can see that from this email that you had discovered that mr crawford had asked xavier for advice did you did it surprise you that he had gone out to x over for advice on
01:45:41 gone out to x over for advice on something like this i think at the time yes it did did you i i without knowing the other conversation with x over brought in i don't know the timeline on that so right given that
01:45:53 the timeline on that so right given that you say that it did surprise you at the time that mr crawford had gone out to x over
01:45:58 over on something like this did you seek to have a conversation with uh neil crawford or indeed bruce sainz about why they felt they needed this external advice um i don't believe specific conversation
01:46:10 i don't believe specific conversation about that no no is there a reason why you didn't pick it up with him and say well hang on why do you need to go to x-over for something like this um no i don't know i mean
01:46:22 um no i don't know i mean ultimately it would building control will be who would be relying on
01:46:29 do you know whether mr ashland ever actually replied to this query i don't know right
01:46:45 uh he says as i've read this to you
01:46:51 to me the fire breaks would have to follow the ratings of the party walls were you happy to rely on the opinion of mr crawford in circumstances where he had felt it necessary to go out to
01:47:02 he had felt it necessary to go out to terry ashton to ask him the answer well i knew that ultimately he would building control would be consulted about it so i knew there would be a check from building control about the compliance
01:47:16 right but
01:47:20 this is at this stage my question at this stage is given that you were surprised as you've told us that mr crawford had felt it necessary to seek external
01:47:32 to seek external specialist fire safety advice from mr ashton
01:47:37 ashton were you happy to rely on his opinion in in circumstances where he had felt it necessary to seek external advice and hadn't got it yet
01:47:49 the design wasn't finished and signed off so this again is part of a a chain of a process of of design development as it goes through um
01:48:00 design development as it goes through um yeah and i may not have even seen this email at the time it was sent there may have been
01:48:05 have been i'm sure there are others attached to this email that i may have picked up later on i wouldn't not necessarily seen it minute by minute as it came in so yeah my question is a narrow one he says to me the fire breaks would have to follow
01:48:16 me the fire breaks would have to follow the ratings of the party walls if matters had stopped there would you have been confident in relying on mr crawford's advice or his view as expressed there in the circumstances i've put to you
01:48:27 circumstances i've put to you yes because i know that it's going to go to building control to have a final overview and sign off that he's correct so it sounds from that answer that it doesn't really matter
01:48:38 answer that it doesn't really matter what either studio we or xover are saying because studio because building controller there to pick up the pieces at the end if it's all wrong i'm not sure they're there to pick up the pieces but they are definitely there
01:48:50 the pieces but they are definitely there to
01:48:51 to uh advise and uh look at the compliance of the scheme against building rigs right yes they are they are a check aren't they but there's a risk isn't there that
01:49:02 but there's a risk isn't there that you're over engineering this because um 120 minutes is obviously more than 120 minutes 60 minutes
01:49:12 minutes is more than the 90 30. if building control is satisfied with 90 30 and you've spent money putting in 120 60 waste of money agreed if i've got a
01:49:23 waste of money agreed if i've got a fixed contract with a subcontractor and they're over speccing something and they're ultimately paying for it then you don't mind i don't mind
01:49:36 uh tracing this through further we have sca3013076
01:49:47 which is an email from you mr lawrence ii ben bailey and ray bailey at harley copy to neil crawford and simon o'connor uh you're forwarding an email uh in
01:50:01 uh you're forwarding an email uh in which
01:50:01 which uh which you had i think received in copy from john hoban on the first of april
01:50:06 april earlier that day which he had sent to neil crawford at studio e setting out the building regulations contents in relation to the uh the uh issue
01:50:17 uh the uh issue of elements of structure uh
01:50:22 uh you confirmed to harley and copied to studio e gents the building control officer is now in agreement with the fire protection in the clouding being a
01:50:33 fire protection in the clouding being a cavity barrier rather than a fire stop as first thought
01:50:40 let's say that's where i think it ends from from you
01:50:50 did you have any thoughts at the time about whether the building control officer
01:50:56 officer uh having given this advice
01:51:00 and being now in agreement with the fire protection was initially in error sorry are you sorry are you saying that whether i thought the building officer was wrong
01:51:11 was wrong it to start with and there had been a debate through march and it ended up with the building control officers you say being now in agreement with the fire protection in the cladding bingo cavity barrier
01:51:22 the cladding bingo cavity barrier um no i wouldn't expect travis to be wrong right
01:51:29 now if we move to ryd 30399 64.
01:51:36 this is an email to
01:51:41 you from daniel osgood on the 27th of march 2015
01:51:50 morning danny i understand you've landed at grenfell okay this morning and getting your head round harley facade's pack the holly's facade package and the cladding i've found all of the information that we have drawings and
01:52:02 we have drawings and material info in the following location and you give it i'm sure it'll take a few days or so to get to grips with it so happy reading please pay particular attention to the fire break spec and insulation guide to ensure they install it correctly before
01:52:13 ensure they install it correctly before any building control inspection now is it fair to say just looking at that your concern here was to make sure that the firebreak spec and the insulation guide
01:52:25 and the insulation guide had been complied with and installed correctly before building control inspected it yes as we should do yes so in this instance at the very least you were not reliant on building to control
01:52:37 reliant on building to control to get the fire break spec right and to advise you on that and the insulation guide
01:52:42 guide or in installation you wanted to make sure that all of those things were correct
01:52:47 correct before building control inspected is that a fair reading of this email yes we we should go through our as should the subcontractors go through their quality
01:52:58 their quality checks to make sure that what their what we are offering to building a troll for inspection is he's correct to the drawing and correct exactly so he is able to
01:53:11 and correct exactly so he is able to inspect and snag accordingly yes so does this tell us that so far as your subcontractors were concerned at least at least in relation to this topic on this email
01:53:22 this email you weren't relying on building control advice
01:53:25 advice to get it right in the first place you were relying on your subcontractors to get it right before building control inspected it so that building control would pass it
01:53:36 that building control would pass it correct yes and that that is an example if you like a paradigm example in fact of how building you saw building control throughout really as a as a
01:53:49 throughout really as a as a regulator telling you whether you passed or failed
01:53:53 or failed rather than advising you on whether you would or not i think part i think both actually i would i would expect our our designers specialists or otherwise
01:54:04 our designers specialists or otherwise to get the design correct and compliant in the first place but i would also expect that there are or there is highly likely to be areas of the building regulations that they need to clarify from building control
01:54:16 to clarify from building control so i would expect building control to give us advice and work with us on that which i i believe is there is their remit um and then i would expect them
01:54:27 expect them to check the drawings and specification to say yes it is compliant with the building rigs yes well in that last answer i note that you say you were
01:54:38 you say you were you would expect building control to give us advice and work with us which i believe is in their remit and we explored this a little bit yesterday but since it's come back again i i i need just to
01:54:50 back again i i i need just to ask you a question about that was it your opinion and understanding at the time of your involvement that building control were if not formally
01:54:58 formally uh informally part of your subcontractor team
01:55:04 team no i wouldn't say they're part of our subcontractor team but i think as i think their their role is to be able to
01:55:12 to interpret the building that they're in best place they're they're government officials in best place to understand the building regulations most of which some of which are extremely complicated
01:55:23 extremely complicated i expect design teams as they do in my experience throughout the construction industry to talk to the
01:55:34 talk to the people that know the building rigs the best i.e building control if they have any queries and to interpret that and building control into i don't expect building control to do a design to give a blank bit of paper for
01:55:45 design to give a blank bit of paper for them to do a design but i do expect them to collaborate with the design team to ensure that the design
01:55:56 to ensure that the design and in the end the installation is compliant and correct we're building strong
01:56:02 strong and was that your experience on other projects
01:56:05 projects as well as the grenfell tower project yes although i actually found the grenfell tower john hoban and paul henson to be
01:56:19 very willing and and
01:56:26 very willing to to collaborate and advise when required
01:56:34 yes uh now mr chairman we're a few minutes away from four o'clock uh we're really in the middle of a fairly lengthy part of the story about cavity barriers
01:56:45 part of the story about cavity barriers is
01:56:45 is is this a sort of convenient place to stop this is a con this is as convenient a place as any to stop well i can take stock and see how much of the rest is i actually need to go through yes but before i ask you to rise i i
01:56:56 yes but before i ask you to rise i i there is one question i'm afraid i feel i have to just revisit this afternoon on on a document we looked at earlier if i can just just do that in a minute or two that remains and it's the lachnal house
01:57:06 house or the lachnal moment email i just feel there's some uh there's a question i just need to ask you about it if you go back to it it's ryd triple zero two three four six eight
01:57:18 and i i put a lot of questions to you this afternoon about about this document i i just want you just to help me with this
01:57:29 this document i know is a well-known document
01:57:32 document in the disclosure
01:57:36 did you have any assistance in preparing to give evidence to the inquiry today and in the last few days about what sort of answers you should give in relation to this document
01:57:47 give in relation to this document no sure about that yes mr german i have no further questions for this afternoon yes but you have some more questions from eddie lawrence now yes uh
01:57:58 from eddie lawrence now yes uh to set mr lawrence's mind at rest we will certainly finish tomorrow unless anything
01:58:03 anything which is uh not reasonably foreseeable it happens overnight yes from sources outside my team um so we should finish comfortably within tomorrow he would probably like
01:58:15 within tomorrow he would probably like me to ask you whether he could hope to finish before lunchtime that would be a reasonable question and i think it would be i think the reasonable answer is hope but not expect
01:58:26 but not expect oh well sorry mr lawrence that's the best i think you can get um i'm sorry we've got to ask you to come back again tomorrow but at least we warned you as a possibility and i hope you've been able to make
01:58:37 to make suitable arrangements so um we'll break now resume at 10 o'clock tomorrow and
01:58:44 and we'll hope without any undertaking that you might get out by lunchtime but we'll do our best all right thank you very much thank you very much if you'd like to
01:58:51 to don't talk to anyone about your evidence or anything related to it over the break and uh we'll see you tomorrow
01:58:58 tomorrow like to give the usher now that'll be fine thank you
01:59:10 nothing else today mr miller mr chairman thank you thank you very much 10 o'clock tomorrow please
02:02:04 you