Rydon Evidence - Wednesday 22nd July 2020 (1/2)

Full transcript

00:00:29 good morning everyone welcome to today's hearing today we're going to continue hearing evidence from uh mr lawrence formerly

00:00:37 formerly employed by ryden so could i ask you to ask mr lawrence to come back in please thank you

00:00:52 good morning good morning mr lawrence thank you very much for making the arrangements to be here again today

00:01:00 today and uh you're ready to carry on yes yes yes mr miller thank you mr chairman good morning mr lawrence good morning we were somewhere into a discussion uh and the story about cavity barriers

00:01:12 uh and the story about cavity barriers yesterday when we finished your evidence can i now go back to that and ask you please to turn first to ryd 309 399 64 39964

00:01:23 399 64 39964 this is an email from you to to daniel osgood on the 27th of april 2015 copy to simon o'connor in which you uh

00:01:34 copy to simon o'connor in which you uh make him uh when you invite him in the last sentence in the second paragraph

00:01:40 paragraph you say please pay particular attention to the fire break spec and insulation guide to ensure that they installed correctly before any building control inspection now when you say fire break spec there

00:01:52 now when you say fire break spec there you mean cavity barriers do you yes do you also mean fire stopping

00:01:59 stopping um

00:02:03 whatever was relevant to the the cladding package that he was looking after right you come across the expression of fire stopping i think haven't you yes and

00:02:14 stopping i think haven't you yes and i think i'll probably briefly mention the other day that they're whilst they may be

00:02:18 may be technically different their fire break fire stop

00:02:22 fire stop cavity barrier is a are sort of interchangeable terms on the construction side right and i think you told us that the word fire break covered cavity barriers and fire stops as a catch-all

00:02:34 and fire stops as a catch-all yeah they're pretty much interchangeable yeah so when you use the word firebreak spec and insulation guide were you were you intending to cover both concepts or both things cavity barriers and faster relating to the

00:02:45 barriers and faster relating to the presumably given the heading of the email that is cladding specific details relatively yes yes indeed thank you

00:02:56 did you understand the difference between

00:03:00 between cavity barriers and fire breaks uh even after the debate about whether they were fast stops or cavity barriers had been resolved by the end of march 2015.

00:03:11 end of march 2015. sorry the difference between fire breaking a cavity barrier yes well i would see them as interchangeable terms

00:03:18 terms to changeable terms well let's look at the debate about the expression and cavity barriers a little bit more closely do you remember in general terms mr lawrence that in march 2015 there was a

00:03:30 lawrence that in march 2015 there was a debate

00:03:32 debate about fire stopping on the tower

00:03:36 um if we if we're talking about the if we talk about cladding specifically then then yes i'll remember that can i ask you to go to ryd3037622

00:03:51 now this is a long email chain and i'd like to pick it up please at page three where we see that uh you

00:04:03 where we see that uh you uh are copied in on an email from mr hoban john hoban at rbc building control

00:04:11 control to neil crawford on the 20th of march you see that yes and in fact it's actually dated the 30th of

00:04:22 in fact it's actually dated the 30th of march

00:04:22 march because the email chain is being generated on that date but this is an email

00:04:27 email from 10 days before which you see and you can see i think mr crawford's response

00:04:35 response of the 30th of march if we scroll up to page 2.

00:04:42 page 2. because you're copied in on neil crawford's response of the 30 actually it's the 31st of march uh in the middle of that page there do you see that yes uh and

00:04:54 yes uh and do you remember reading that at the time or seeing that at the time i i remember the chain yeah i remember the chain

00:05:01 the chain and i've seen it since well let's go to the end of the chain uh on page one when we see neil crawford writing to you on the 31st

00:05:12 neil crawford writing to you on the 31st of march

00:05:13 of march forwarding the email chain below

00:05:18 and he says hi simon this is the response

00:05:21 response i got back from x over below seems like no one really agrees with john so let's see what he comes back with after my last email and uh he copies or forwards you

00:05:32 and uh he copies or forwards you uh terry ashton's response to him neil crawford

00:05:36 crawford of earlier that afternoon 31st of march 2015 reed grenfell tower fire stopping neil he says this isn't something that would necessarily form part of a fire

00:05:48 would necessarily form part of a fire safety strategy for a building therefore it would not have been dealt with in the fire safety strategy for this building i agree with ben kaye uh i i think he meant

00:05:58 meant um kay of ciderise there who isn't called ben um i believe that a cavity barrier is all that is required in this application even if we were to agree with rbkc it's

00:06:10 even if we were to agree with rbkc it's difficult to see how a firestop would stay in place in the event of a fire when external flaming occurred

00:06:15 occurred as this would cause the zinc cladding to fail

00:06:19 fail you see that see that and particularly those last few words that i i emphasized now i'd like to look at this email in a series of stages if i can pick it apart first of all mr ashton says this isn't

00:06:32 first of all mr ashton says this isn't something that would necessarily form part of the fire safety strategy for a building

00:06:36 building in the first sentence there did it concern you at the time do you remember that the fire safety strategy had not included reference to cavity barriers uh no and i'm not sure i would have read

00:06:47 uh no and i'm not sure i would have read this email in in great detail to be fair i would it's part of it part of a chain of emails so this is um that was ongoing between

00:06:57 between the design team members so i would have had a let's say higher level view and watching the emails go backwards and forwards but i wouldn't necessarily have read and

00:07:09 i wouldn't necessarily have read and picked apart every single word in every single

00:07:11 single part of the email chain right so whether i'd have noticed that at the time i don't recall noticing it but i may have done

00:07:17 done it i see have you well had you at the time

00:07:21 time any experience either on projects for ryden or other projects when you worked before joining ryden of actually

00:07:30 actually seeing fire safety strategies uh i

00:07:37 uh i i don't recall seeing fire safety strategies on the previous on the previous jobs with ryden so if somebody i may have done i don't don't specifically recall them

00:07:48 specifically recall them right so would did you have any knowledge or experience which you could bring to

00:07:56 bring to bear when knowing what a fire strategy should include and should not include um i think i would understand in general terms but it would be general terms but no i think

00:08:07 no i think not specifically right

00:08:14 uh

00:08:18 did you obviously you would have realized

00:08:22 realized from this that although there was a fire safety strategy because you had been told

00:08:26 told back in april of 2014 that xover had completed one did it not concern you that even though you had thought that they had completed one

00:08:37 that strategy hadn't included anything about

00:08:40 about cavity barriers

00:08:43 uh not not particularly at the time um

00:08:51 did it occur to you at this point to instruct

00:08:54 instruct mr ashton or indeed another fire safety consultant to advise you on this point no because this is a this is

00:09:02 is part of a complete chain of email that was going between the design team members

00:09:09 members so again now especially subcontractor studio e

00:09:13 studio e and building control so it was part of the design development that i was copied into and [Music]

00:09:23 [Music] would have been keeping an eye on but not

00:09:26 not necessarily pulling apart and necessarily seeing every single email as it come in i might have picked them up four or five emails down the line right would it be fair and please tell

00:09:37 right would it be fair and please tell me if it's not to describe your role at least in relation to this email chain as something of a spectator i think that would be fair yes well let's see how far

00:09:48 let's see how far your expectatorship went um the next uh question or part of the email i want to ask you about is the uh the reference at the end of it to the zinc cladding

00:09:59 zinc cladding did you notice the fact that mr ashton had thought that the material forming the external rain screen for the

00:10:10 forming the external rain screen for the cladding

00:10:11 cladding was zinc at the i've obviously read this chain numerous times since but at the time i don't recall fully reading that email and and and

00:10:22 fully reading that email and and and paying

00:10:24 much attention to it to be fair like like we've just said i was a spectator on the email chat and going between the design team so yeah so no i might not even read the full email right

00:10:37 the full email right so you didn't notice is this right i don't recall noting at the time any specific reference to a material that we weren't using

00:10:48 a material that we weren't using because of course by this time as we've been through yesterday the rain screen was not zinc it was acm wasn't it correct yes and therefore if mr ashton had been laboring under the

00:10:59 if mr ashton had been laboring under the misapprehension that the cladding was to be made of zinc that would have been can you agree with me a a pretty serious misapprehension i i would agree it would be an error and if it was something that

00:11:10 be an error and if it was something that i'd seen i would have picked up but i don't recall seeing it at the time or referencing it at the time right do you remember whether mr crawford

00:11:23 identified the error uh i i don't remember uh you never had a discussion with him about it

00:11:42 discussion with him about it did you have any concerns uh that the only fire safety specialist on this project and i think the answer to this is no

00:11:53 and i think the answer to this is no which follows but did you have any concerns

00:11:56 concerns at this time that the only fire safety specialist on this project who had completed a report so far as you were told

00:12:03 were told by april 2014 uh was still under a misapprehension about the nature of the rain screen on the outside of the building

00:12:14 the outside of the building no because i noticed the reference

00:12:23 can i then ask you to look at har406585

00:12:31 and i'd like pages one and two to go up together please now uh at the top uh

00:12:43 now uh at the top uh uh of page one we can see mr anchor jones writing to ray bailey and he starts just that it's ridiculous and this is this is this is the 27th of march 2015. so a few days earlier in the email traffic

00:12:57 a few days earlier in the email traffic if i can put it that way which culminated in the uh discussion we've just been talking about um and and uh at the bottom of page one we can see uh what he's talking about uh

00:13:10 we can see uh what he's talking about uh the bottom of page one and over to page two uh

00:13:17 you're writing sorry ray bailey is writing to anchoral jones do you have any comments and he's sending and below that we see your email to neil crawford of the 27th of march thanks for checking neil ben

00:13:28 of march thanks for checking neil ben c neil's response it doesn't look promising

00:13:31 promising and then we see what it is that doesn't look promising and it's neil crawford's uh message to you of the 27th of march middle of page two uh so earlier the same day hi simon have

00:13:42 uh so earlier the same day hi simon have spoken with john and he wasn't happy with harley's email as we are talking about fire stopping as opposed to cavity barriers i've explained again the specifics of our scenario and he will have a conversation with paul hansen

00:13:54 conversation with paul hansen to see if there is a reduced spec they can agree to and will then speak with harley's direct so that's that's the the context um i just want to come back to uh mr anchor jones's response to ray

00:14:07 uh mr anchor jones's response to ray bailey at the top of page one if we can

00:14:11 and anchor jones rankle james says and i appreciate you don't see this you're not copied in on this email he says just that it's ridiculous there is no point in fire stopping quotes on quotes

00:14:22 quotes on quotes as we all know the acm will be gone rather quickly in a fire

00:14:31 in a fire now we've just looked together earlier uh mr lawrence at the email from mr ashton mr crawford where he says that uh external flaming would cause the zinc cladding to fall off

00:14:46 did you at the time have any idea about what would happen if the external rain screen did flame

00:14:57 external rain screen did flame and fall off and and whether that meant that cavity barriers were or weren't important uh it's not something i gave any thought to at the time right did you have any particular view about

00:15:07 about whether it was right to be talking about cavity barriers all right to be talking about fire stopping um having at the time probably not but having re-read this chain

00:15:19 having re-read this chain or what i've seen of this chain since i can

00:15:22 can i can understand what they're talking about

00:15:25 about whether they're talking about inside the building or outside the building right

00:15:31 did you notice the degree of confusion about this subject from the email chain you did see i noticed there was confusion i noticed there was there was back and forth between

00:15:42 between um harley's side rise studio e building control

00:15:50 if you had been advised uh that it was the view of x over at least uh uh that the cladding panels on grenfell tower would fail in the event

00:16:01 grenfell tower would fail in the event of a fire with external flaming what would you have done

00:16:07 um

00:16:12 i mean probably at the time i would have assumed that at some point um irrespective of time as in you know

00:16:23 irrespective of time as in you know at some point i would expect all materials to fail at some point um and whether that be half an hour whether that be three days i would expect them to to fail but

00:16:39 i don't recall having that um sorry can we can you say the question again let me try it a different way because i think the three days isn't what i'm asking about if you had known that in the event of a fire

00:16:51 known that in the event of a fire the acm would be gone rather quickly if you'd known that at the time what would you have done i would have would have got that checked with building a troll to make sure that is him a

00:17:02 sure that is him a firstly within the rigs and that is that's

00:17:06 that's what he's understood that that's acceptable um and then looked into it further you say you would have checked with building control would the first port of call for

00:17:16 call for you not have been the consultants you were employing on the job namely studio e well okay as a design team as a whole thing well i'm not i don't want to suggest the answer i

00:17:28 not i don't want to suggest the answer i mean i'm putting to you why you say building control in circumstances where you had nevada to you and were retaining studio e is the architect because in this in this if we reference

00:17:39 because in this in this if we reference in this chain of emails there was there was discussion and and potential confusion or conflict between different views regarding the regulations

00:17:50 regulations so the person to provide the best advice as to what the compliance needs to be with the building regulations would be building ultimately building a truck

00:18:03 did you know that no steps had been taken to ensure that cavity barriers were in place around the windows in order to prevent fire spread into the cavity

00:18:11 cavity or cavities i didn't know they needed to be you didn't know they needed to be so it followed from that that you didn't at least take any steps to ensure that cavity barriers were in place

00:18:22 cavity barriers were in place i was relying on my designers

00:18:30 can i ask you then to look please at har40

00:18:40 3947

00:18:52 uh and i'd like you to go to please put to page four in that email run

00:19:09 thank you now uh there is some background to this um and perhaps just to remind you of it could we look please at page um go to this but go to the bottom of

00:19:21 um go to this but go to the bottom of the email we'll just scroll up very quickly

00:19:27 just just to track through the debate as it evolved up to the 30th of march so we can see um at the bottom of the email chain that this is the second page of a two

00:19:39 that this is the second page of a two page email from ricky k who's the national facade's manager at siderise uh and it starts actually on page

00:19:47 page seven if you could just please skip to that and we'll come back to page eight ricky k to ben bailey copied two others at harley

00:19:56 at harley and sue shepard at siderise and he sets out an extract from approved document b so this is the supplier

00:20:03 supplier of cap of um of the cavity barriers uh providing ben bailey had harley with with some

00:20:10 with some uh input to use a neutral word and he cop is approved document b if we can go to

00:20:15 to page eight please we'll see what he cuts and pastes from approved document b it's part of table a1 uh and you can see item 15 cavity barrier integrity 30 insulation 15.

00:20:27 insulation 15. you see that and um he says that's all that's required to form a um all that is required from a cavity fire barrier and then he says that the product

00:20:39 and then he says that the product they're offering offers 90 minutes integrity and 30 minutes insulation and therefore exceeds minimum requirements 120 minute fire rating is generally the industry standard for curtain wall to concrete slab edge fire stopping where the fire stop is located on the

00:20:50 where the fire stop is located on the inside of a building and it's considered to be a continuation of the floor slab so that's his that's his

00:20:55 his v um advice more input if you like and then

00:20:58 then scrolling back up please to page seven and six

00:21:02 and six start with seven we can see um neil crawford

00:21:05 crawford uh to uh john hope and copied to ashton at xova and paul hanson at rbkc a lot of conversation on site about cavity barrier requirements to be fitted

00:21:17 cavity barrier requirements to be fitted between the existing concrete external wall panels and new external rain screen aluminium cassettes

00:21:22 cassettes can you confirm that there had been a lot of conversation on site about that topic

00:21:27 topic um i might not be part of of that conversation i don't recall it specifically right um but then i wasn't

00:21:35 i wasn't on site permanently and i i know

00:21:39 particularly when john hoeven and um maybe not paul it would take your engine home but visited i didn't wasn't necessarily there

00:21:46 there for all those visits or saw him so do we take it from that your site manager on site at the time didn't report these conversations back to you in the late part uh well simon o'connor would have been leading the site so he's probably best to

00:21:59 the site so he's probably best to answer what conversation was said and what conversation wasn't said really very well um and then we moving up the email chain c the email from neil crawford to john hogan on the 30th of march ben bailey's who

00:22:11 on the 30th of march ben bailey's who you might ask for and then if we can go to page six we come up to john hoban's email of the 20th of march

00:22:21 copied to you where he sets out and this is obviously earlier in the month that we looked at earlier he copies he sent it to neil crawford and copies to you and others um his view

00:22:35 and others um his view uh that the fire time for the new elements of structure columns being sections of compartment floor in grenfell to entire 120 minutes and draws attention to diagram 33. did you pay any attention to this

00:22:48 did you pay any attention to this detailed advice when you were copied in on this email at that time

00:22:53 that time i possibly have read it but i wouldn't have again i wouldn't have it was an overview i wouldn't have gone into pulling apart the approved document and

00:23:01 and understanding um everything in that all right let's then scroll up to page five

00:23:08 five or i think we've seen uh the emails of the 30th of march which we've we've seen and he then gives more advice on that

00:23:19 and he then gives more advice on that date

00:23:21 date sent to uh ricky k also harley but you're also copied in on it and again did you did you pay attention to that email when it came in again i probably would have

00:23:32 it came in again i probably would have seen it in the email trail but in there you've got designers and technical people um and

00:23:45 there's nothing technical that i can add that they don't either already know or they know their subject far better than myself so i'm i've got an overview that's this is right simple as

00:23:56 overview that's this is right simple as that really and then let's look at the next email up on page four please uh which is uh your email

00:24:06 well there's an email from from ricky k at the bottom of page four to the top of page five we can just look at that because i think you're copied in on that as well

00:24:17 and he says please can someone forward over a drawing of the buildup of the cladding so my technical officer can evaluate

00:24:23 evaluate and forward an official response with a siderise product specification and then if we look at the next email up on page four this is your email to ricky k and ben bailey

00:24:33 bailey copied to uh harley and studio e ricky ben i appreciate there is a discussion and different points of view regarding the cladding fire stopping stroke cavity barrier regs

00:24:45 fire stopping stroke cavity barrier regs which we can make however we need to do this constructively and i'd rather not question the bc officer john hoban in front of everyone on email please can can you please sort this out

00:24:58 please can can you please sort this out in private and respond to myself and neil if you have a valid argument

00:25:03 was it common practice at the time in your experience to discourage direct communications between companies involved on the grenfell tower project refurbishment and building control

00:25:15 refurbishment and building control uh no and i don't read that email that's doing that if you uh as you've told us reliant on building control to give advice why did you not want to ask building

00:25:26 why did you not want to ask building control officer the building control officer mr hoban in front of everybody on an email i don't think that's the one i don't think that's quite that email says i think that email how would you i interpret that email

00:25:37 how would you i interpret that email because you've got several parties um questioning and dare i say arguing with building control sending lots of information backwards

00:25:49 sending lots of information backwards and forwards and i felt the best course of action

00:25:51 of action rather than i was going to say bully but that's probably an unfair word rather than there'd be five people questioning one building controller so i thought we should have a be professional and have a

00:26:03 should have a be professional and have a clear concise

00:26:09 point of view that he's joined up between the between the the ryden team as i'll call them so the design team the harleys the side rise

00:26:20 design team the harleys the side rise and to put that point across clearly we to john hogan not for everybody to pile in with a bit of information here and there um and get it confusing all i'm trying to do is say

00:26:31 to do is say let's calm down let's let's do this professionally and clearly and present this to the building control officer i'm not saying ignore the builder control officer i'm not saying anything like that at all

00:26:42 i'm not saying anything like that at all that's not what that email is saying so on this occasion at the very least your aim was to make sure

00:26:49 sure you as the design team if you like had to put it colloquially put got all your ducks in a row got everything sorted out correct before going to

00:27:00 going to building control had a coordinated approach yes because there seemed to be a difference in opinion right so there are a few different policies does that not tell us

00:27:11 does that not tell us that in fact at least on this issue you regarded building control as outside the team and that you would be presenting an argument to them rather than asking for their advice we

00:27:23 rather than asking for their advice we would use people to control in in both respects but i would expect us to come with a clear concise question argument however you wish to

00:27:34 question argument however you wish to phrase it to building control so he can clearly study it understand respond accordingly ask questions whatever i just didn't feel it was fair that we had um

00:27:48 feel it was fair that we had um you know i realized this is online but i didn't feel that we it was fair that we had six people standing on one side and one building control was the same the other and everyone crowding around and piling comments in i thought it would only be fair that we

00:27:59 only be fair that we stopped had a conversation or the design team had a conversation we presented it clearly and professionally to the building now you say please sort this out in private and

00:28:10 please sort this out in private and respond to myself and neil if you have a valid argument who would be the people in the team your team who would decide whether an argument was sufficiently valid to put forward to

00:28:22 sufficiently valid to put forward to building control for their comment well i expected harley's and siderise to get their ducks in a row i'd expect them to present that to um

00:28:34 i'd expect them to present that to um to neil for him for his comment as well or for studio e's comment as well and then collectively to present it to building control and ask for their advice to guidance

00:28:46 ask for their advice to guidance acceptance if that was the case

00:28:51 now

00:28:57 can i then ask you to look at a different document same date uh which is page one and two of the same email chain

00:29:16 uh and i think we're gonna need page three in fact sorry i need page three not page two i apologize

00:29:41 um could you guess can you go back to um

00:29:50 i'm so sorry if you could go back please to har i don't quite know how we've jumped to the a different document but can we go back to har four zeros three nine four seven

00:30:06 please

00:30:15 yeah and uh i'd like to look at page three of that please

00:30:23 now this is your response that's it that's the one now this is your response to chris mort and ricky k of the 30th of march 2015

00:30:34 of the 30th of march 2015 and you say thanks chris i'm happy for us to as a project team to work through this

00:30:38 this and question the bc officer if there is a valid point but the emotions behind email can easily be misread if you upset him now over a ten thousand pound issue then it could affect me

00:30:49 it could affect me later when trying to get sign off for the whole building and that's an 8.5 million pound issue for me now before you sent that email did you investigate for yourself whether the

00:31:01 investigate for yourself whether the views of harley x over and studio e set out were correct

00:31:07 regarding the technical aspects of the cavity barriers yes right can i ask you to look at sea three zeroes one 30s 14275 at page 75.

00:31:24 now this is mr crawford's ema witness statement

00:31:27 statement and i'd like you to look please with me at paragraph 245.

00:31:35 he says there in a meeting which i believe took place in april 2015 possibly the client design sign-off meeting on 30th of april 2015 i recall being told by simon lawrence

00:31:47 i recall being told by simon lawrence ryden something along the lines of that there was no need to ask any more questions as the cladding has been signed off by building control do you recall saying that to mr crawford

00:31:58 do you recall saying that to mr crawford no

00:31:59 no because i think studio where you're in control of getting the sign off so so no do you accept that the emails that we've just been looking at together this morning

00:32:10 been looking at together this morning specifically drew your attention to potential potential areas of non-compliance in the design of the facade

00:32:21 i think that email child that email trail

00:32:26 gets closed out in the end by building a troll so

00:32:30 troll so and i think as we've discussed before it would be usual for design development for the designers to be um discussing and clarifying points between themselves so

00:32:41 between themselves so no yes but you deny the conversation you say that didn't happen the one that's referred yeah i don't i don't recall that conversation and i can't see why i would be telling the

00:32:54 can't see why i would be telling the architect

00:32:55 architect who is on our behalf collating and coordinating with building troll to get things signed off that i'd be telling him that it's all signed off

00:33:15 when you're dealing with building control which was the more important um insuring compliance or not upsetting them

00:33:24 them we're ensuring compliance but you would like to have a good working relationship with all parties you wouldn't go out to

00:33:35 everybody you'd want everybody to be getting on well and the information to be flowing you wouldn't intentionally go out to upset them would you

00:33:42 you is it is it fair to say that notwithstanding the discussion that we've seen in late march between xover harley studio e

00:33:50 studio e on which you were to use my word i'm afraid

00:33:54 afraid a spectator but i think you agree with that um

00:33:58 that um don't withstanding the fact that that discussion raised a serious and a significant issue about compliance with the building regulations that your primary concern at the time for the project was to secure

00:34:10 for the project was to secure sign off of the finished building rather than

00:34:13 than absolutely thoroughly to ensure compliance now obviously there as one in the same

00:34:20 the same see them as one of the same but but to to reiterate what i've previously said the email chain to read that in a complete chain that is design development going between the

00:34:32 design development going between the designers which ultimately i believe ultimately ended up with john hoban making comment on to what was acceptable what wasn't acceptable

00:34:43 what wasn't acceptable very good can i then turn to a different topic or slightly different topic cavity barriers on other projects very short point a short topic you told us you worked with harley on over cladding

00:34:54 cladding projects at taplow house and ferrier point

00:34:57 point at chao cots and ferry point did those did those refurbishment projects have cavity barriers around the windows do you remember i don't recall there being cabbage barriers around the windows

00:35:08 around the windows but i'd have to look at the detail right who did or whom did you consider was responsible for the provision of cavity barriers on

00:35:19 the provision of cavity barriers on those

00:35:20 those projects on sorry on chao cots and ferrets

00:35:24 ferrets it would be hard i hardly had the complete package

00:35:32 can i then turn to ask one or two questions about the crown now as we know the tower grenfell tower was fitted with a an architectural crown at the top of the

00:35:43 an architectural crown at the top of the building you remember that yes

00:35:47 do you agree uh or perhaps you you can't help me but would you agree that the gap at the top of the cladding system just below the crown was the edge of a

00:35:58 just below the crown was the edge of a cavity

00:36:00 cavity the edge of a cavity for the purposes of the regulations oh i couldn't tell you you couldn't tell me right now we know for for a fact that no cavity barriers were in fact installed at the top of the

00:36:12 in fact installed at the top of the cladding system did you yourself or anybody else at ryden check the designs in that area i didn't myself i would expect the

00:36:25 i didn't myself i would expect the sorry the installation of the sorry do you mean the design part of it or the installation the design yeah my question was did you or anybody else that ride will check the designs in

00:36:36 else that ride will check the designs in that area the design would have gone through the same process as as all the other design did i follow so you would have expected studio e would you as i expected harley's to a do it right in the first

00:36:48 harley's to a do it right in the first place i would expect them to pass its studio e for comment and then it would ultimately go to building control

00:36:58 right can you explain why the absence of any cavity barriers uh around the top of the cladding system just below where it meets or met

00:37:09 just below where it meets or met the crown wasn't detected by you while you were to use your words in your statement coordinating and managing the process of design ensuring that the designs complied with

00:37:20 ensuring that the designs complied with client requirements because and again i think we forgive me for saying this but i think we've covered this previously i do not have the technical expertise and

00:37:31 do not have the technical expertise and an ability to check the designs hence why we rely on the specialist subcontractor and the lead designer and building control right can you provide any insight

00:37:42 can you provide any insight into whether anybody to your knowledge ever actually even considered that it might be important to provide vertical cavity barriers within the crown itself to prevent any lateral flame spread around the building

00:37:53 lateral flame spread around the building at the top i don't recall i don't recall

00:37:58 new topic plastering specifically s d plastering and materials and some of the works can i ask you to start please by looking

00:38:09 can i ask you to start please by looking at ryd3029360 this is an email from you to simon

00:38:21 this is an email from you to simon o'connor

00:38:22 o'connor and alan grint within ryden window trims and this is the 29th of january 2015 and you ask them gents can you do a list of materials for the window trims and

00:38:34 of materials for the window trims and pipe boxing based on the show flat 145 and send it across to me and zach zach maynard

00:38:41 maynard the surveyors will then get a chance to order and compare against budget costs and then you say i also had a thought that we might be able to use plasterboard as a packer underneath the upvc rather than timber

00:38:53 upvc rather than timber as it's cheaper what do you think will this work

00:38:57 is it fair to say looking at that email that your primary concern at least in relation to window installation at grenfell was completing it as cheaply as possible

00:39:06 possible i think the i think to be fair budget was a consideration but also when you're working inside people's homes you need to look at the

00:39:17 people's homes you need to look at the most efficient way of completing the works with minimal disruption in the quickest amount of time why would use of plasterboard as a packer rather than timber be

00:39:31 rather than timber be give rise to minimal disruption and the quickest amount of time possibly easier to cut than it is timber

00:39:38 you don't need a standing knife rather than the saw and and whatever other equipment and it's it's a um

00:39:47 what i'd seen done previously at chaucot's end of area

00:39:55 and this would be a a material change in the product wouldn't it i think what the plasterboard yes um

00:40:08 from timber then then yes it would be a did

00:40:12 did yes did you discuss this change from timber to plasterboard with anybody other than mr o'connor and mr grint um i don't recall but i do know that we

00:40:23 um i don't recall but i do know that we were looking at from a construction point of view and a how you physically construct stuff again minimal disruption efficiency of time in people's homes

00:40:35 time in people's homes so we were bringing out our knowledge from the previous projects

00:40:42 to that element that works but there will be other people involved in that whole

00:40:47 whole process did you ask anybody studio e uh harley whether or whether or not

00:40:56 not this change uh would have uh any effect architecturally or so far as compliance was concerned i'm not sure at that time we'd actually

00:41:07 i'm not sure at that time we'd actually finished and decided best way to construct

00:41:11 construct the details so probably not at that time did you consider did you consider any other properties of the materials you were considering for use

00:41:24 um at that time we were just we were taking our experience in the previous projects

00:41:30 projects and my experience from not only chao cots and ferrier and other projects that involve windows was that would be a standard um if not exclusive way of us

00:41:43 um if not exclusive way of us trimming the windows right would it be common for you unilaterally to decide to change from timber to plasterboard without getting without telling the the architects for example i think at that stage we were

00:41:54 example i think at that stage we were looking at um we were looking at how it can be constructed easily and delivered delivered easily in within someone's home so um so that's the thought process

00:42:07 so um so that's the thought process there

00:42:07 there um but the architect and you know ultimately i believe everybody knew what was being installed

00:42:19 did you have any discussion with your client the tmo about whether you should switch from timber to plasterboard as a packer

00:42:24 packer here uh i don't recall any conversations with the tmo no can i go please to ryd3029476

00:42:40 this is an email from you to mr grint could you just tell us while we're on it what mr grint's role was at this time um he was one of the site managers yes

00:42:51 um he was one of the site managers yes um but

00:42:52 um but quite what his remit of what packages he was looking after obviously internal windows but [Music]

00:42:59 [Music] possibly other stuff as well but i can't remember yes this is the 30th of january 2015 and

00:43:04 2015 and if we look at the second paragraph in that

00:43:07 that email you say i'm hearing from other sites that sd carpentry do a really good job but are slow as much as it pains me to say it their standard of work may be too good

00:43:18 standard of work may be too good for what we need in refurb hopefully dave will be okay with the time frames above

00:43:22 above but if not we may have to let them do the new flats only and get another to do the internal works

00:43:29 what do you mean when you say that sd carpentry's work may be too good for what you need in a refurb because they're they're a specialist carpentry firm that does

00:43:40 or in my experience have done some um high-end carpentry works and generally you'll find that

00:43:51 find that how best to describe this if you took a took a joiner wouldn't be suitable for somebody doing carpentry on site because the the

00:44:02 carpentry on site because the the level of finish is is completely different

00:44:06 different and to trim windows you need somebody that is

00:44:09 that is um well the quality still needs to be there

00:44:13 there but you generally find that people that fit windows trim windows are often far quicker than um sort of specialist carpentry fans

00:44:24 um sort of specialist carpentry fans you see you don't say that sd carpentry would be too expensive it's just that their standard of work may be too good why was that a problem if it wasn't a problem in terms of price i think it's more of an issue of the how

00:44:35 i think it's more of an issue of the how long it takes them to complete their works

00:44:40 that's not the sense one gets from this email the sense one gets from this email uh is that a lower standard of work was acceptable for this refurbishment well yeah i don't agree with that what

00:44:53 yeah i don't agree with that what standard of work did you regard as sufficient for this refurbishment if if if if if sd carpentry

00:44:59 carpentry were too good the correct standard that was appropriate for what we were trying to install what was it about this particular refurbishment mr lawrence which permitted a lower standard of work

00:45:11 standard of work than than sd carpentry would provide there was nothing the standard of the work i was looking for was it was what we'd previously done which i believe was a good standard of work in the other

00:45:22 work in the other in my experience in the other um blocks that we've done and not just chow cross and ferry but all the other window replacements we've done

00:45:30 done on other types of properties now uh mark dixon uh is or at least was at the time

00:45:37 the time the director of sd plastering wasn't he yes which is a completely different company to sd carpentry yeah just not to people

00:45:45 people let's just let's just explore explore that a bit we need to uh if you look at his witness statement please it's sdp five zero is one nine six and i'd like

00:45:56 five zero is one nine six and i'd like you to go please to page three in that paragraph 13 and this is under the heading instructions to refurbish the internal window surrounds in or around april 2015 i was asked by

00:46:09 in or around april 2015 i was asked by an employee of ryden whose identity i cannot recall with certainty if sdpl would provide a quotation for undertaking cosmetic works in finishing off the surrounds to newly installed windows in each residential

00:46:21 installed windows in each residential unit

00:46:22 unit at the grenfell tower i believe this request would have been made verbally during a conversation that took place on site sdpl having already secured a contract

00:46:30 contract to undertake dry lining and plastering works at grenfell tower between myself and one or more of the following individuals and then there's a list of them and you are the third down on the list simon lawrence you see that

00:46:42 simon lawrence you see that correct

00:46:44 correct [Applause] do you remember having a conversation with mr dixon about these matters

00:46:54 matters at the time i think we'd all had numerous conversations about the um the windows and the trial flats and et cetera so it could be

00:47:05 trial flats and et cetera so it could be one of

00:47:06 one of numerous i don't record anything specific that was

00:47:13 involved right now this is sd plastering was it you who approached sd plastering sdpl to quote for this work uh i don't recall

00:47:24 to quote for this work uh i don't recall whether i

00:47:24 whether i i did or one of the others did but um i may well have done i don't recall right it's right isn't it i think that mr dixon had formally worked for ryden as a contracts manager and a site

00:47:35 as a contracts manager and a site manager

00:47:36 manager uh yes mr dixon was my contracts manager when i started and and possibly simon o'connor's as well so yes yes

00:47:44 yes what steps did you or i'm so sorry do you want to finish we knew and trusted mark well yes i see you drew the distinction between sd plastering and sd carpentry uh could you just help us with that just

00:47:57 uh could you just help us with that just two different completely different companies does coincidentally using this usd yes so sd carpentry is not is not mr dixon no i see um

00:48:09 mr dixon no i see um did you or anybody else that ride into your knowledge take any steps to check that sd plastering was competent to carry out the reveal work on the windows that you were asking

00:48:20 work on the windows that you were asking them to do well they they did

00:48:25 not only dry lining and plastering but they also did um sort of general builder handyman stroke works which would be the type of trade i would expect to be

00:48:37 the type of trade i would expect to be doing

00:48:39 doing the window reveals

00:48:42 yes that wasn't quite an answer to my question i'll just ask it again did you or anybody else that ride into your knowledge take any steps to check that sd plastering was

00:48:53 to check that sd plastering was competent to carry out the window reveal work that you wanted them to do

00:48:59 um apart from being competent to be on site and competing to be able to use a a a drill and a saw i'm not sure what other specific competencies you'd have for doing window reveals

00:49:10 you'd have for doing window reveals all right i'm not aware of any um now let's look at ryd30

00:49:19 this is an email of the 6th of may 2015

00:49:33 ryd3040686

00:49:39 thank you this is an email of the 6th of may

00:49:43 may from 2015 from mark dixon to adam marriott copied to you and the subject is priced for windows surrounds

00:49:56 and you can see that he attaches to that email

00:49:59 email sdp front sheet quote 6 may 2015 say the same day now can we look at that document

00:50:11 i should before we do that just show you the text of the email he says dear all please find attached the quotation for carrying out the window surrounds at grenfell can i ask you to check the numbers as i'm

00:50:22 ask you to check the numbers as i'm unsure about the three bed units as we've never been in one and the drawings are not clear uh if we can look at the attachment then that is at ryd3088957

00:50:41 and you can see from that that it's entitled grenfell window surrounds and it's divided into columns and

00:50:52 and it's divided into columns and in the leftmost column a description of item you can see in the second line down uh you can see that it says uh place celetex insulation to reveals

00:51:05 place celetex insulation to reveals and base of window you see that yes did you read this at the time probably not

00:51:17 read this at the time probably not why not uh because it was aimed at

00:51:23 adam so it was a quantity survey and i would expect him to pick up the numbers and report back if there was any any issues

00:51:35 but you were copied in on this email can i ask why is contracts manager responsible for this project you didn't read the attachment which was the quotation it's because

00:51:46 which was the quotation it's because it's a financial it's a financial um a financial document that's relating to a quantity surveyor so i wouldn't necessarily pick up

00:51:57 i wouldn't necessarily pick up all of the attachments otherwise i'll be doing their work for them so i would expect them to be opening it understanding it clarifying any points they need to clarify

00:52:08 they need to clarify well you wouldn't be doing all their work for them would you if you just if you were interested to open the attachment and see what it was that mr dixon was was offering to do on the project but i don't recall seeing

00:52:21 on the project but i don't recall seeing this document and i didn't open it no i would i would repeat what i was just saying i would expect it was i it was i believe addressed to adam so best of our quantities about i'd

00:52:32 adam so best of our quantities about i'd expect our quantity surveyor to make sense of that

00:52:37 and then report back as required

00:52:42 yes i'm just interested in why it was you didn't even open the attachment and read it

00:52:45 read it i don't recall i don't know do you remember having any discussions uh with sd plastering mr dixon or anybody else there or within ryden about this quotation

00:52:57 or within ryden about this quotation specifically about quotation i don't recall in discussions

00:53:03 so who would have read and approved this quotation within writing if not you it would have gone to the quanti surveys for them to clarify and check against budget

00:53:16 clarify and check against budget um what's been allowed for what hasn't been allowed for

00:53:21 and then an order placed if appropriate if required would you not have been interested to know even if not the precise figures which we can see in column d

00:53:34 figures which we can see in column d what works as a subcontractor sd were promising or indicating that they would perform i think we i think we knew because i think we'd had

00:53:45 think we'd had discussions the team the site team myself has probably been at least one of them on site as to how the window surrounds were going to

00:53:57 how the window surrounds were going to be

00:53:59 be finished right did you and you told us you didn't read this document when it arrived but did you independently know that celetex insulation was going

00:54:10 know that celetex insulation was going to be

00:54:11 to be put in or around the reveals on the base of the window i wouldn't necessarily know it was celetex as a as a brand but um sort of solid boarding for my insulation was discussed yes

00:54:24 insulation was discussed yes all right let's move through that to sea four zeros three zero four zero page

00:54:36 sea four zeros three zero four zero page five

00:54:37 five please in that run of drawings uh now this uh is one of a set of drawings from uh harley which had been through the

00:54:48 uh harley which had been through the architectural intent stamp at studio e and looking at page five this is marked a status a as you can see

00:55:00 this is marked a status a as you can see from the red stamp on the right by neil crawford on the 16th of january 2015. and stamped approved for construction

00:55:13 before i ask you about the detail of this can we assume that this is a drawing that you would have you would have seen at least in copy in as part of the discussions between

00:55:25 discussions between harley and studio e at around that time

00:55:30 now if you look at the middle of the drawing in respect of the window sill condition

00:55:35 condition and it's up there on the screen it says insulation by others you see that yes do you remember seeing drawings such as this

00:55:47 this which say insulation by others in that location

00:55:50 location i remember seeing this drawing so yeah if there's others that are similar then yes

00:55:56 yes you remember seeing this drawing specifically uh yes right um do you remember when was it at the time

00:56:04 the time i i would imagine i would imagine so but in mid-january 15. yeah i couldn't give you a precise date right um what did you understand by the expression insulation by others as in harleys

00:56:17 insulation by others as in harleys weren't

00:56:19 weren't um expecting to carry out that part of the works

00:56:23 the works who were to your knowledge well at that time i don't know if we just judging by the time scale we just looked at with sd card tree and then um stp

00:56:35 um stp i don't think we decided by then originally when we originally set out in the project

00:56:41 project as we've done previously we were looking for and expected harleys to carry out the facade works so the external works and the trimming of the windows because

00:56:53 and the trimming of the windows because there is a coordination in in time products etc which is what they've done for us at jail consumption

00:57:05 does this tell us that at this point january 2015 celetex has not been selected to your knowledge

00:57:13 knowledge as the product for insulation in this location

00:57:17 location i don't recall we've seen just just insulation i don't recall what insulation was selected at this time or not we've seen that by the 6th of may 2015

00:57:29 we've seen that by the 6th of may 2015 from the sd quotation that they were quoting for placing celetex in this location among others

00:57:39 others can you help us with when celetex was specified

00:57:42 specified for application in this location um it probably would have been the when we were doing the trial for that process

00:57:51 process it wouldn't necessarily be celetex as a manufacturer specified i think we were looking at the the amount of gap available and what

00:58:04 available and what insulation to put in there with the purpose of cold bridging that was that would have been the thought process at the time

00:58:10 the time um and what would what would work underneath a um soffit and window lining board what i'm interested in mr lawrence is

00:58:21 what i'm interested in mr lawrence is the circumstances in which and the time at which celetex as a as a product or at least a brand came to be selected for use as insulation in that location i can't tell you the time scales but it

00:58:32 i can't tell you the time scales but it would have it would have come out of the when we were trialing we did it we did a trial flat so there was a an empty flat within grenfell that

00:58:43 was a an empty flat within grenfell that the

00:58:43 the client kept empty and used as a show flat for

00:58:47 flat for um for residents and others and we did that flat trimmed it for inspection and we went through several ways of how

00:58:58 and we went through several ways of how best to

00:58:59 best to carry out the construction work can you help us more accurately with the date when that was or a date range not without looking i mean i think there's

00:59:09 there's there's reports probably a clerk of works repulsed um saying that it's been finished there'll be other emails saying when it was finished but i can't tell you what i don't know the

00:59:20 i can't tell you what i don't know the time scale can you help us with who it was who chose celetex as a product or at least as a brand for insulation in that location as a

00:59:31 for insulation in that location as a brand i don't don't know i don't i wouldn't imagine that anyone specifically targeted cedartex i think it was more what was physically able to go in the

00:59:45 what was physically able to go in the um the the gap um and give support to the to the window lining board so it would be a rigid insulation not necessarily celatex

00:59:56 necessarily celatex um but a rigid insulation see somebody had chosen celetex as we've seen from the sd quotation by early may 2015. yeah what i

01:00:07 quotation by early may 2015. yeah what i want to know is who was it who chose that

01:00:09 that i don't know why can you not explain that you all i can say is that we looked at the construction details of how to um

01:00:21 how to um you know how to physically construct given the constraints of those windows what would fit in there and a a rigid board was

01:00:30 board was um agreed upon by all parties um now whether i don't believe anybody specifically when we want celetex or we want kingspan or we want a another

01:00:42 we want a another it was just the fact of what rigid insulation board will fit in that gap because the gap is small right well just following up on that whose job was it to check the approved for construction drawings

01:00:54 for construction drawings prior to planning the work to the window reveals

01:00:59 sorry whose job was it to check the approved for construction drawing such as this prior to planning the work to the window reveals

01:01:11 reveals so in well in this instance it obviously goes from harley to studio e [Music]

01:01:17 [Music] um yeah is that that we all well whose job was it to check the approved for construction drawings such as this it has a stamp

01:01:28 such as this it has a stamp approved for construction if it's if it's already been checked by studio e then it would go to the the package manager on or the site team um to look at took a truck but as part

01:01:39 um to look at took a truck but as part of that

01:01:40 of that whose job was it to specify this insulation in this location

01:01:48 well what what should have happened you would expect the either harleys if they were doing the works or studio e to specify the insulation

01:02:02 do you know who specified cellotex for using that installation not as a specific brand no no whether that whether that come about from a discussion on site

01:02:14 from a discussion on site of like i say the whole site team how do we practically complete the works and then whether so rigid insulation was discussed like i

01:02:25 so rigid insulation was discussed like i say not necessarily a particular brand

01:02:29 whether then mark when it got prices for varying different brands but it would have been seen by the the team as a um

01:02:40 the team as a um you know a like for like product whether it was in this instance whether it was a teletex kingsman

01:02:48 kingsman or a another i think the answer to my question do you know who specified it is no

01:02:54 no that's what i think i said previously but yes it is all right thank you now can i um just take you to the nbs specification which is at sea 50169

01:03:05 50169 and go to page 243 at the bottom of the page

01:03:10 page where we can see p10235 compressible insulation in gaps and it goes on manufacturer rockwool you see that yes

01:03:28 and uh below that

01:03:35 uh it says sundry insulation proofing work and also compressible insulation in gaps

01:03:40 gaps so that's that that's the whole page sundry insulation work at the top and there are uncompressible insulation gaps at the bottom and as i say you can see rockwool specified there as a product

01:03:53 specified there as a product and you can see that the product references flexible slabs rwa45 density and not less than 45 kilograms per cubic meter material mineral wool

01:04:06 cubic meter material mineral wool to bsen13162 now did you or anybody else that ride into your knowledge refer

01:04:17 into your knowledge refer back to this nbs specification to check which insulation product should be used to pack the window reveals prior to planning the work to those

01:04:28 prior to planning the work to those window reveals um i don't believe i did but i don't know if anybody else did right who ought to have checked the mbs specification for material selection prior to planning

01:04:40 for material selection prior to planning the work to the window reveals i think we all should have done can you explain why you didn't um

01:04:52 specifically details like that on site i would expect the tight team to um

01:05:00 i'm not there full time managing the package works so my view is a slightly higher level view although

01:05:08 although i would still say that we should have checked it and i do agree with that um i would expect those managing the works on site to have more of an idea a closer grip on the mbs spec

01:05:23 idea a closer grip on the mbs spec than someone like myself but i do do agree that we should have checked it

01:05:29 do you agree either

01:05:33 the rockwool mineral wool uh stipulated in the nbf spec was not a like for like slab swap sorry a light for like swap

01:05:45 slab swap sorry a light for like swap with the slabs that eventually found their way into the into the window reveal locations we've been looking at on the drawings

01:05:55 uh i agree they weren't mineral wall they weren't like whether they were like for liking performance i can't tell you that probably unlikely knowing what we know now do you agree they were compressible

01:06:06 now do you agree they were compressible either were they i mean the slabs are as i understand yep pretty rigid you can cut them to shape yes

01:06:15 yes which might have been one way of fitting them into that rather awkwardly shaped void correct here the rock wool was meant to be compressible which i assume

01:06:26 meant to be compressible which i assume is an alternative way of filling an awkwardly shaped void by cramming it in it is just correct they're not the same are they

01:06:33 are they uh no they're no they're not no you're right they're not the same um i think the insulation was used in not just the awkwardly shaped void but also in the gap

01:06:45 shaped void but also in the gap the other side of the existing window frame so in that location from ignoring a performance point of view

01:06:55 view a a solid slab you wouldn't need something that was compressible in that side of it but the awkwardly shaped but yes i'll tell your point is great all right thank you

01:07:06 point is great all right thank you and just following up on that exchange wouldn't it have been harder work taken longer to go about the business of cutting

01:07:14 cutting the non-compressible or less compressible uh celatex slabs than it would if you'd use rockwell as specified in the nba specification uh only in that awkwardly shaped void right

01:07:26 only in that awkwardly shaped void right do you agree that if the nbs specification had been referred to then it would have been clear that the selection of celetex in may 2015 by sd plastering was at odds with the specification

01:07:37 with the specification yes although that would have warranted an investigation and clarification yes and i think we could take it that no such investigational clarification was undertaken was it

01:07:49 undertaken was it uh not i believe so can i then look at ryd three zeros four two four eight six four two four eight six i'd like to have pages one and two please

01:08:00 like to have pages one and two please put up side by side at the bottom of page one is an email from you to sd plastering later in may 27th of may regarding sd plasterings making good of

01:08:13 regarding sd plasterings making good of the replacement windows in the pilot flat

01:08:16 flat flat 145 and 17th floor communal do you see that

01:08:21 see that and if you look at the top of page two um

01:08:27 two um you can see uh that it says um and this is the bottom actually i'd like to start at the bottom of page one and over to page two

01:08:38 over to page two you say i then took a look at the window trimming

01:08:42 trimming which unfortunately wasn't the finished item that i was expecting there are still some areas which need tidying up ie joint strips need installing a couple of side trims outstanding and there is a large gap behind several reveal returns which

01:08:54 gap behind several reveal returns which are too large to mastic

01:08:59 also andy has used a different upvc product rather than the original than the original it has more of a bull nose whilst i prefer the square edge i'm not

01:09:10 whilst i prefer the square edge i'm not that fussed however they now need to re-trim

01:09:12 re-trim the original so that it matches and then you say my biggest concern is how they have fitted the window boards compared

01:09:20 compared to original attempt it seems that because they have used a thicker board they have now they have decided not to install a plastic plasterboard packer below in my opinion that was a big mistake

01:09:32 that was a big mistake this means that now all of the windows have a void beneath them which is only partly stuck with grip fill as soon as you press them they noticeably deflect

01:09:41 deflect some really badly in my opinion this isn't acceptable and they all need reinstalling have a look and see what you think so cutting a long story short mr lawrence fundamentally you press on the

01:09:53 lawrence fundamentally you press on the sill of the new window frame and because there's a gap between the sill of the new frame and the old timber reveals the sill deflects is that was that what you're saying

01:10:02 saying yeah correct so if you yes yes right now at uh we see the response to this email uh

01:10:09 uh at ryd3042488 please

01:10:22 and he this is a reply the same day in the evening of that day from mark dixon to you uh evening simon starting at the top see responses below

01:10:33 responses below uh and uh he says uh about five lines up from the bottom of his email we are still struggling to find our feet do you see that yes it says we are still struggling to find our feet on the window details

01:10:45 find our feet on the window details and i'm still anxious that taking on these works is going to give me additional headaches i could have done without

01:10:50 without and add in the time scales i'm not looking forward to it we're committed now so i need to find ways of making it easier and quicker before i add another team in before we have it under control did that give you any cause for concern

01:11:03 that just said to me that he was uh looking at his labor resource because the trimming of the windows is a or

01:11:12 or well not just trimming of the windows but when you're working within occupied roof and particularly within people's homes you want to be sort of getting in and getting out

01:11:23 sort of getting in and getting out with as least disruption as and it needs to

01:11:26 to sequentially go day by day so um that just says to me he's looking at getting another team or releasing another team from somewhere else yes my question was did it give you any calls for concern mr lawrence

01:11:38 calls for concern mr lawrence no because i trusted mark to carry out the works right did mr dixon's email prompt you to lend any assistance as to how the job could be made easier and quicker

01:11:51 could be made easier and quicker uh no why is that i'm not sure what i could have added to well did you instruct anybody else at ryden to assist mr dixon in any way

01:12:04 with what finding him some later yes or finding him any kind of assistance which would make it as he says easier and quicker

01:12:13 um no i think that was i think mark would

01:12:17 would solve that himself and if he if he couldn't then he would come to us and say he couldn't carry out the works

01:12:24 so i think the answer is no did you just leave sd plastering to find a solution and get on with it yes did you yourself seek to

01:12:36 yes did you yourself seek to ensure that the problem he was foreseeing at this stage was resolved he's we talk about labour resource here well i'm talking about what he's talking about mr lawrence he's identified the

01:12:47 about mr lawrence he's identified the problem

01:12:48 problem my question is uh did you take any steps uh to seek to ensure that the problem he was foreseeing at this stage was resolved

01:12:57 resolved uh i'm i i wouldn't have found labour for him it would it would be for the subcontractor to [Music]

01:13:06 [Music] be able to resource the works or or not resource works and let us know so at this stage mark is looking into what he can do and what he can't do

01:13:16 let's look on uh the same day you i think email mr osgood and simon o'connor

01:13:23 o'connor if we can look at that that's

01:13:30 ryd-3042487 subject show flat uh and it's quite a long email um i've sent you say gents i've sent an email tonight to mark explaining my

01:13:42 email tonight to mark explaining my thoughts and asking him to call me when he's on site tomorrow i thought it best not to copy everyone in so hopefully he doesn't get defensive about the work i've also made steve blake aware so he isn't shocked when he visits tomorrow

01:13:56 isn't shocked when he visits tomorrow and then you say overall i'm extremely upset that we have got to today and that we have got to today and in my opinion are nowhere near having the flat in a show condition it shouldn't take me to visit and notice the issues straight away

01:14:07 the issues straight away apart from being unfinished in the in areas the bouncy window board is a disaster

01:14:12 disaster i still can't understand how it hasn't been noticed before i'm expecting to be called to account from steve and quite frankly i haven't got any good excuses the only saving grace is that the client's director isn't planning on

01:14:23 client's director isn't planning on visiting tomorrow as first thought whatever happens that flat has got to be top-notch ready for inspection by the client next week i expect nothing short of a quality job please ensure this happens it's our last chance um who did you consider should

01:14:37 chance um who did you consider should take responsibility for rectifying what you call

01:14:40 you call a disaster uh i would have thought that should be led by the site so simon o'connor um and danny was overseeing the at that stage

01:14:51 danny was overseeing the at that stage was he overseeing the installation of that

01:14:54 that so not you then no i'm i'm not on site full time i'm on visiting site a couple of days a week i don't oversee the day-to-day um

01:15:07 the day-to-day um installation and site works that's that's the site team's job to do that right now specifically focusing on the unfinished uh areas the bouncy window board which you described as a

01:15:18 window board which you described as a disaster

01:15:19 disaster um it's focusing on that i think mr dixon addresses this in his witness statement which i'm going to show you can i please have sdp 50196 at page four

01:15:30 sdp 50196 at page four now and this is paragraph 16. and he says there

01:15:45 paragraph 16 as the new windows were installed

01:15:48 installed beyond the original building line a gap was created between the newly installed windows and the old timber window surrounds which remain in situ following the removal of the old aluminium framed windows the width of the gap was

01:16:00 framed windows the width of the gap was approximately 60 millimeters to 100 millimeters that depth varying slightly between the units

01:16:07 units and then at paragraph 17 he says one of the

01:16:11 the this is the second sentence one of the management team explained that they were not happy

01:16:15 not happy with the standard of finish that had been achieved because amongst other things the plastic soffit and fascia boards were prone to to boeing and then at 18 he says

01:16:26 to boeing and then at 18 he says you see this in the second sentence we noted that the bowing occurred where the plastic soffit and fascia board spanned the gap

01:16:33 the gap as nothing had been used to bridge the gap in order to provide the necessary support to the plastic soffit and fascia board

01:16:40 board an edpm gasket had been installed around the new window to create a weatherproof seal which meant that it was not possible to see the interface between the new window unit and the surrounding walls

01:16:52 walls now do you agree that the gap which mr dixon

01:16:55 dixon is referring to here is the gap which he flagged up uh in or you flagged up rather in your email to him of the 27th of may which we just looked at

01:17:07 sorry can i go back to that email that that sent

01:17:11 that sent yes uh i i believe so yes i believe so okay um why did you what did you get onto studio e or harley for that matter at this point and raised this boeing issue with them

01:17:25 and raised this boeing issue with them no at that stage we were doing the show flat so the trial flat 145

01:17:31 flat 145 and like i say working out with the subcontractor and the site team how best to

01:17:39 to construct the works so it would be fair to say that you didn't see this as a job for studio or harley but purely for your site team i saw it as our as our input of how we

01:17:51 i saw it as our as our input of how we physically that's our input for construction details

01:17:55 details um or our input to um

01:18:00 to give advice on how best to construct um the details so that's what we were doing right without going back to studio or harley at that stage yes we were

01:18:11 or harley at that stage yes we were using our

01:18:12 using our subcontractor and our knowledge of you know timber and

01:18:18 window boards except rooms etc um how best it would how best it would physically work right let's look at paragraph 19 of mr dixon's statement he says

01:18:29 statement he says one of the management team instructed sdpl to produce an alternative configuration for finishing off the window surrounds the one was more aesthetically pleasing than the example windows surround two was easier to install than the

01:18:40 two was easier to install than the example windows surround and three would remedy the boeing in the example window surround she then calls the works uh i think by management team mr mr i mean mr dixon

01:18:52 by management team mr mr i mean mr dixon means to refer to ryden

01:18:56 on your knowledge was it ryden who instructed sdpl to produce an alternative configuration for finishing off the windows surrounds that satisfied those three requirements

01:19:07 that satisfied those three requirements yes i would assume so yes yes do you know which individual at ryden gave those instructions um no it could be no no it wasn't you it could be a lot so there was there's

01:19:18 it could be a lot so there was there's various points but we've all been into the flat and all seen seeing the works and comments in the works quite often with all of us standing around together giving our opinion on whether we think

01:19:29 giving our opinion on whether we think it's visually acceptable or not visually acceptable so it could be it could be a you know a number of people so we he says here and

01:19:39 and obviously we may need to explore this with him but he says that uh sdpl were instructed to produce an alternative configuration

01:19:48 it was your understanding that they were in essence just told to get on with it yeah we'd have all had an input as it let's say riding as a management team and the manager's looking after it we've

01:20:00 and the manager's looking after it we've had an input as what we think um the best visual outcome is

01:20:06 is did ryden have any input into the production of the alternative configuration that he's referring to here

01:20:12 here i think that's what i've just well what was that said by us all standing around and saying will that work will this work can we do it like this is there another way of doing it to get the uh

01:20:24 way of doing it to get the uh to get the best and most efficient job so was this discussion on site with the the boeing example

01:20:31 example in front of you i i believe that would i well

01:20:34 well i don't recall the exact discussion but i would imagine that that would be standing there in front of the example the show flat example um

01:20:46 the show flat example um to see what would what would work right you see the impression one gets from what he says and again we'll have to explore it with him is that um ryden had instructed sdpl to

01:20:57 is that um ryden had instructed sdpl to produce an alternative configuration that rather gives the sense they were sent away

01:21:01 sent away to come up with something is that wrong um not entirely but it's not it's not as black and white as that we've got a

01:21:12 black and white as that we've got a sdp have

01:21:15 carried out some works in a show flat as an example

01:21:20 we as ryden have commented on that and said

01:21:23 said we'd like you to improve that can we do this can we do that with them all together um and then they've had another go effectively so

01:21:34 had another go effectively so which is a normal sort of sample process on site

01:21:38 on site trial and error on site on something like this yes right but on this not something like this what is this this is on this yes yeah um now mr dixon goes on at paragraph 20 at the foot of that page

01:21:50 at paragraph 20 at the foot of that page to say

01:21:50 to say sdpl did not receive any instructions from ryden nor any other entity concerning compartmentation and or fire resistance in respect of the works do you agree with that

01:22:01 with that uh yes do you know why sd plastering was not given any instructions in respect of fire resistance i don't think any of us aware of the

01:22:13 us aware of the regulations relating to that i think we were

01:22:17 were um basing our knowledge on what we've done

01:22:21 done previously over the like i said before pretty much i'm not sure i can recall any window that in my experience working with ryden that we've put in that hasn't been

01:22:32 that we've put in that hasn't been trimmed in the same way mr chairman we're midway through a topic i'm afraid this is us but and therefore this is as convenient

01:22:43 but and therefore this is as convenient at the moment as only to have the morning break yes yes we probably should take it now because we've been running nearly an hour and a half uh mr lawrence we'll have a break now thank you um usual rules apply please no

01:22:54 thank you um usual rules apply please no talking to anyone about your evidence while you're out of the room and we'll come back at 20 to 12. please thank you i'd like to go to the with the usher please

01:23:14 twenty twelve fifties okay

01:42:04 right would you like to ask mr lawrence to come back please

01:42:21 good thank you ready to carry on mr lawrence yes thank you very much mr lawrence uh can i stick with mr dixon's witness statement for the moment please and ask you to look at page seven

01:42:33 uh paragraph 32.2

01:42:37 and in there you will see that he is talking about materials and under 32.2 he's talking about kingspan thermopitch insulation boards

01:42:49 kingspan thermopitch insulation boards and he says that they were purchased from ccf limited and were used to bridge the gap

01:42:54 the gap they were used interchangeably with the cellotex boards depending on their availability from sdpl suppliers this was not considered to be an issue

01:43:02 an issue in light of the fact that the insulation boards were only being used to bridge the gap in order to provide support for the plastic soffit and fascia boards and not for their thermal properties see that do you agree that the internal

01:43:13 that do you agree that the internal lining of the windows formed part of the external

01:43:16 external envelope of the building that's not how we'd have seen it now you weren't seeing it that way no does that tell us that you didn't think that all insulations used uh

01:43:27 used uh in the windows or around the windows should have been of limited combustibility we saw them as two i would have seen them as two separate or we would have all seen them as two separate and inside

01:43:38 all seen them as two separate and inside and

01:43:38 and outside right

01:43:43 now harley i think were not supervising or

01:43:47 or involved in this part of the work is that right no the intention was that they would do it initially but then they [Music]

01:43:55 [Music] for whatever reason i can't remember decided they wouldn't carry out the internal works

01:44:05 sd plastering wasn't a a design subcontractor was it no so in terms of the role of approving the use

01:44:16 use of 25 millimeter kingspan thermopitch insulation boards that would have been a choice by

01:44:21 choice by ryden would it and that should have gone to studio e to be checked but is the answer to my question yes yeah yes yes and and if you look at 32.1 the 25 millimeter celetex tb

01:44:33 millimeter celetex tb 4000 insulation boards sir same question it would have been ryden is this right that would have approved the use of that product

01:44:40 product um yes we wouldn't have known the specific

01:44:44 specific or necessarily been aware of specific tb4000 i wouldn't have known that but did you yourself personally approve the use of these two products um i think as a team we agreed that that was the way forward i don't think there

01:44:55 was the way forward i don't think there was any

01:44:56 was any formal um approval process of that apart from um showing the the the finished product to

01:45:07 showing the the the finished product to turkey works client team i believe building control ended up seeing it but there wasn't a formal approval process like you would do with the facade for example right but you yourself were you personally involved in

01:45:19 yourself were you personally involved in the decision we were all involved in how that was constructed yes all right you say all all involved at ryden right now did you know that celetex

01:45:32 right now did you know that celetex tb4000 was a fire class f product no so you wouldn't have known therefore that it was not a material of limited combustibility

01:45:43 not a material of limited combustibility correct

01:45:47 and therefore should not have been used in this application if that's what the rigs are saying then i agree

01:45:56 i agree can you account for how it comes about that ryden was selecting material that the regulations say should not have been used in that location i don't think we were cognizant

01:46:08 location i don't think we were cognizant that there are regulations relating to the window linings internally is and we would we were doing a process

01:46:19 is and we would we were doing a process that we had had always done in my previous experience with ryden

01:46:25 you see in this part of the works you regarded this as not part of the building envelope i think as you said a moment ago this was inside and not outside yes and therefore you didn't have a

01:46:38 yes and therefore you didn't have a specialist subcontractor in relation to this part of the works did you uh no i'm not sure there particularly a specialist subcontractor when it comes to

01:46:47 to window trimming and therefore as the contractor you would have no one to fall back on and you yourselves were responsible you ryden were responsible for ensuring

01:46:59 you ryden were responsible for ensuring that whatever products or materials were used in these locations they were compliant with the building regulations do you accept that i accept that and that they weren't i don't know that if you're telling me

01:47:10 i don't know that if you're telling me they weren't they weren't and that you ought to have checked we ought to put that through studio e and it should have gone the approval rate yes did you ever actually ask studio are

01:47:21 ask studio are are these two products celetex tb 4000 and kingspan thermopitch suitable and for use in this location uh i personally didn't but do you know

01:47:32 i personally didn't but do you know anybody else i don't know right now mr dixon goes on at paragraph 33 at the bottom of page seven to say these materials were selected by reason of the fact that sdpl had experience of

01:47:43 of the fact that sdpl had experience of using those products the products were readily available from sdpl suppliers and three they fulfilled the criteria for the works in providing an acceptable decorative finish to the window surrounds following the

01:47:54 to the window surrounds following the completion of the glassworks by harley [Applause] now mr dixon appears to be saying that ryden had no input into the specification of those materials and it was left to mark dixon to choose and to source it

01:48:06 mark dixon to choose and to source it sounds as if the from the answers you were giving me a moment ago about ryden's involvement that that's not right can you comment mark would have chosen where he got the materials from

01:48:17 where he got the materials from and i think as we as we said um a little while ago that we were looking at a rigid insulation and that's as far as a selection would have gone [Applause]

01:48:29 [Applause] so mark would have gone away and um looked at his supply chain or his yeah his supply chain to find what rigid insulation would fit in that thickness that he

01:48:40 would fit in that thickness that he needed to complete the work i see so so is this right that you as you understood it were relying on him simply to source the material rather than make a decision about what should be used

01:48:53 about what should be used when it comes to actual brand and um and model should we say of of material yes

01:49:06 we only had discussion about that we're looking at solid board insulation and and that's that's what the discussion was about moving on then uh and away from mr

01:49:17 moving on then uh and away from mr dixon's statement uh can we then go back to the story uh

01:49:26 ryd3042486 and i'd like just to look with you please mr lawrence at the top email in that chain this is from you to steve blake of the 27th of may 2015.

01:49:38 27th of may 2015. and this is back to the the disappointing state of uh flat 145 mr lawrence

01:49:44 lawrence and uh you say i've been to the site today and taking a look at the flat to be fair i'm really disappointed and extremely unhappy with our progress and quality while mark's lads haven't helped the matter

01:49:55 the matter our management hasn't done anything about it i don't understand why it takes me to notice these items i can only assume that those responsible our end haven't visited the flat during the installation process either way if you do visit the

01:50:09 process either way if you do visit the site tomorrow be warned danny and simon are aware again of what is needed i'll speak to them every day until it's completed

01:50:19 that when you say our management you can see the words oh management hadn't done anything about uh about the problem

01:50:29 um who were our management that you meant there uh the management on site so simon leading the project and then danny um overseeing the

01:50:40 then danny um overseeing the installation right from a ride management just to be clear danny is daniel's good yes sorry yes right i see

01:50:49 can we look then on ryd three zeros four two

01:50:52 two triple a

01:51:00 uh this is an email from mark dixon to zach maynard and james clifton we know who zach maynard is can you can

01:51:11 we know who zach maynard is can you can you tell us who james clifton is uh james clifton is a quantity surveyor who i believe took over from adam merritt so within ryden yes

01:51:22 uh and he addresses the works the window trims

01:51:27 trims and he says in the first paragraph zach as it stands today that these works are going to be difficult and this is not an element that we wanted to do and still don't so are carrying it out because no

01:51:40 don't so are carrying it out because no one else wanted to

01:51:44 did you read this email at the time it's it's copy to you i i may have done i don't recall it but i may have done do you remember whether you did anything to address mr dixon's concerns about the difficulty of the job um i don't recall

01:51:58 um i don't recall doing anything but i don't really recall this email so and he goes on to say what i can't do is lose money on it i've already changed from my original team as the prices did not work for them and i'm wrestling with keeping the team in place that i have

01:52:10 keeping the team in place that i have and i've had to increase their prices to keep them interested in wanting to stay

01:52:15 did you appreciate at the time uh mr dixon's

01:52:18 dixon's uh concerns uh about keeping people involved and interested um it's not a um

01:52:33 carrying out the window trimming works is not

01:52:36 is not a

01:52:36 a [Music]

01:52:40 a package of works that is particularly attractive to um subcontractors he's probably fair to say

01:52:51 subcontractors he's probably fair to say yes where mr dixon's sentiments has expressed here not a cause for concern to you

01:52:58 to you um i i don't recall them um but no i think that's that's probably a

01:53:06 the general negotiation and and conversations on site that that's not unusual that's no it may not be unusual but was it not a cause of concern

01:53:18 no not particularly did you think it's only a cause of concern if he says he can't do the works and then we have no subcontractors to carry it out right it's a cause of concern but we

01:53:30 right it's a cause of concern but we we trusted a new mark would do the best he can to

01:53:38 carry out the books did you have a thought about changing contractors and getting somebody who was a bit more interested in the job i think we'd already looked at looked overs previously

01:53:51 overs previously so you've looked at others previously is this right mr dixon is the only one to take it on probably at that stage was the yes was the most

01:53:59 the most um keen at that stage he goes on to say uh in the second part of that long paragraph

01:54:09 paragraph um two lines up from the bottom of it these works have started much later than you planned meaning i am being asked to increase the program to two teams at some point which again gives me a lot of pressure i don't need

01:54:20 gives me a lot of pressure i don't need at this point were you not concerned that this subcontractor group or subcontractor team were under a lot of pressure at this time partly due to the program

01:54:32 this time partly due to the program um i wasn't concerned about it overly concerned about i

01:54:38 did you just leave sd plastering to their own devices in what respect just let them get on with it despite the pressure well i think there's i think there's degrees of pressure um and

01:54:51 degrees of pressure um and i i don't really see what big pressure there is on on that it's a program pressure for us as a whole um

01:55:05 program pressure for us as a whole um now going back to mr dixon's witness statement

01:55:09 statement uh if we can please this is sdp 50196 at page six

01:55:17 uh he says at paragraph 28 there once the works in the pilot unit had been completed just pausing there is that flat

01:55:25 that flat is that the show flat five yeah one of the management team although i'm unable to recall which specific individual inspected the same and confirmed that they approved the work such that they could then be replicated

01:55:37 such that they could then be replicated throughout the units do you agree that it was ryden that inspected the work in the pilot unit and gave that confirmation um i agree that ryden would have inspected it

01:55:48 ryden would have inspected it one of the site management team would have respected it it would have also gone to the tmo and the

01:55:57 the clerk of works to inspect as well give their

01:56:01 their consent i see who at the tma are you referring to uh that probably would have been clear do you remember do you remember claire inspecting the finnish word i don't remember specifically

01:56:12 specifically i may not have been there when they were carrying out those inspections does the approval or the confirmation to which mr dixon refers um did that extend to approving the various gaps

01:56:24 various gaps that we've been through it's approving the

01:56:27 the overall appearance excuse me

01:56:31 it's the overall appearance so they're they're happy to offer um the the appearance and finish um to their residents i see

01:56:42 and finish um to their residents i see so when you agree with me that uh the ryden management team confirmed that they approved the works the confirmation extended only to appearance and not to

01:56:53 appearance and not to the substance or compliance with building regulations or anything of that nature

01:56:58 nature well at that stage i don't believe um any of the ride and team are aware that there are any um [Music]

01:57:07 [Music] we we felt that it would all i spoke to myself the others would i'm sure would say the same we feel it was an aesthetic finish product

01:57:19 what steps if any were taken to ensure that sd plasterings work was properly checked following uh that approval by ryden checked

01:57:30 that approval by ryden checked as in it would have been gone through a quality

01:57:34 quality process a snagging process you're quite right that was a better way of putting the question yes what what what process after this approval did these finishes in that flat go

01:57:45 did these finishes in that flat go through

01:57:46 through so after ryden so sdp would check it themselves to make sure it was aesthetically

01:57:55 they were able to offer it to ryden ryden would carry out the same process would snag it as we called it in the trade

01:58:01 trade it would then go to the the tmo and the clerical works would have been invited to comment on on the finished product as well now can we turn

01:58:12 we turn to ryd3042485 we're still in the 27th of may 2015 and your discussions with mr dixon

01:58:25 and your discussions with mr dixon this is now 7 13 on that day your email to him still on the subject of flat 145.

01:58:38 and we've already i think looked at this because we've looked at the middle paragraph about the noticeable deflection and i want us to pick up the second from

01:58:50 and i want us to pick up the second from last paragraph in that document you say um i appreciate we've dropped this on you at the last minute but we are under massive pressure and

01:59:02 but we are under massive pressure and criticism from the rebel residents about our quality of work i'm being called to answer questions and defend our actions by client ccs etc

01:59:14 client ccs etc so far their points are unfounded but i need to ensure our finish is good quality especially on the show areas

01:59:23 ccs who was that

01:59:28 um

01:59:35 i don't uh i don't know don't know no no i don't know sora don't right

01:59:46 no i don't know sora don't right you refer in the second line there to pressure and criticism from the rebel residents

01:59:54 residents who were the rebel residents mr lawrence

01:59:59 at the time there was a um a vocal group of

02:00:03 of residents that

02:00:08 either didn't want the work to proceed or want

02:00:11 or want it to proceed in a different way and

02:00:17 things like boilers installed in different areas and they weren't happy with

02:00:22 with the tmo and the way the work was progressing and and as is usual um within occupied refurb um not only the client but ourselves carry out

02:00:37 workshops is probably the best way of describing it showing the offering the um to consult with the

02:00:44 with the residents and showing them the products they're getting and talking them through it and et cetera et cetera and there were some some residents that a group of residents that weren't

02:00:55 a group of residents that weren't happy overall the imam was there had you been briefed by the tmo about what you describe as the res the rebel residents

02:01:07 rebel residents think we were made aware from the tmo that there was quite a strong resident voice within grenfell yes what information had been given to you that allowed you to form the impression

02:01:18 that allowed you to form the impression that some of the residents were rebels i think at that stage there was a a group that printed posters stuck them on their doors and

02:01:30 posters stuck them on their doors and and refused to allow access for the works to be carried out on what issues

02:01:37 issues to the best of your recollection were uh residents complaining at this point um i think that i think the main discussion was around the

02:01:48 discussion was around the um the hiu which is the i'm going to call it a boiler for it's not quite but a boiler um and the position of where that boiler went within their flats

02:01:59 went within their flats um i think the fact that they had surfaced pipe work as part of their new heating system there were some elements that a group

02:02:10 there were some elements that a group weren't happy with you say here so far their points are unfounded

02:02:19 unfounded what was ryden's process or was there a process at ryden for dealing with residents complaints such as

02:02:26 such as the ones that you're referring to here yeah on site we had we had recently asian officers as we called them rlo's um and they would um deal

02:02:39 um and they would um deal i'm going to put in a crude term and this is this isn't them for the for the layman

02:02:43 layman sort of customer service and they would deal

02:02:46 deal and with the complaints from the residents

02:02:51 log them and then pass them on to the site team and or client as as required

02:02:59 required at this time may 2015 who was the rlo or rlos on site in relation to this project um i think it may it would have been

02:03:11 i think it may it would have been um linda apprentice was was permanently based on site um and i think christina was her manager at the time

02:03:19 time and i'm i'm not sure if she was based on site or whether she was visiting probably visiting

02:03:26 did you personally have contact with linda prentice or christina in relation to complaints

02:03:38 in relation to complaints we would know yes we would know about the complaints did you have personal contact

02:03:41 contact with linda prentice and and with christina they were on site so yes i would i would see them on site and and if i needed to deal with something then right um they would call or email the first port of call

02:03:52 call or email the first port of call would be dealt with at a site level um so simon o'connor and the team and generally i only got um involved when um

02:04:05 when the complaints needed couldn't couldn't be resolved um and or i generally led from a ryden point of view the

02:04:17 view the sort of stakeholder engagement meetings with the client well we're going to come to that shortly um before we leave this email can you tell us what actions you had taken yourself mr lawrence to satisfy yourself that their

02:04:31 lawrence to satisfy yourself that their points as you say were quotes unfounded on quotes uh i don't know which specific points we're talking about i guess it was the hou

02:04:40 hou and we carried out extensive work um trying to install it in the best position before we leave that

02:04:52 the best position before we leave that email uh can i just see if i can remind you of something called the considerate contractor scheme which might be a clue as to what ccs yeah

02:05:01 right i acknowledge that i just don't understand why they consider a contractor scheme would necessarily be in reference to that but it may well be yes they would look at complaints if the uh

02:05:11 uh if any of the residents had called them then yes they would deal with those complaints and fall them on to us just so you can help us ccs is a body is it

02:05:22 ccs is a body is it yes and it's a body that um assists residents is this right deal with complaints or a system with their complaints against contractors it's an independent

02:05:34 against contractors it's an independent um body that

02:05:38 most contractors sign up to um and with the with the intention that raises the profile of the construction industry and part of the

02:05:49 the service they offer is a [Music]

02:05:53 [Music] help line i suppose is probably the best way of putting it where if a member of the public whether it be a resident or a member of public walking past any building site um has any concerns they

02:06:04 building site um has any concerns they can ring up log the complaint with the ccs and then the ccs will then ensure that it comes to the appropriate person on the appropriate site were you was riding a member of the ccs

02:06:15 were you was riding a member of the ccs yes yes

02:06:16 yes yes and at this point or by this point had you had uh communications with the ccs about complaints raised by residents at grenfell tower i don't record any coming

02:06:27 grenfell tower i don't record any coming in specifically from the ccs but they may have done just wondered why you refer to the ccs in this email there may have been been a complaint i don't recall anything i follow can i then turn to look at the topic of

02:06:40 can i then turn to look at the topic of residence complaints a little bit more closely away from the specifics of this email

02:06:47 email um going back in time you i think attended the tender interview for the grenfell tower project along with christina stefanu and alan sharok's correct and christina stephanie is that

02:06:58 correct and christina stephanie is that the christina you were referring to earlier in your answers yes can i ask you to look please first at art402192

02:07:10 this is artelia's tender report of the 11th of march 2014 final draft tender report on enhancements and improvements to

02:07:21 enhancements and improvements to grenfell tower as you can see can we go please to page 117

02:07:32 uh this is part of the report dealing with the interview the tenderer's interview and interview questions

02:07:42 questions and there's a scenario which is uh identified or explained there and the question sets out a hypothetical scenario and a number of questions and

02:07:53 scenario and a number of questions and let's just look at the fourth paragraph uh or or the third or fourth paragraph uh you are currently working on floors 10 to 13 but there are two flats you've been unable to gain access to

02:08:04 been unable to gain access to there have been some resident complaints these have mainly related to the lack of availability of the lifts in the morning rush hour and the continual noise of drilling through the concrete one resident is a night shift worker has

02:08:17 one resident is a night shift worker has been particularly affected the grenfell action group has made formal complaints to the directors of kctmo and encouraged negative press involvement now this is a as i understand it

02:08:31 now this is a as i understand it correct me if i'm wrong mr lawrence a hypothetical scenario it appears that way i mean i'll tell you but yes it appears do you recall being asked

02:08:39 asked this question uh at the interview um not specifically but the interview

02:08:49 what i do recall of the interview the part of the process was um unusual by the fact of you had you didn't know all the questions you were going to be

02:09:00 all the questions you were going to be asked

02:09:01 asked before you went in so you knew some of the questions so you could prepare and then there was there was i think one question where you were

02:09:08 were given a given the question at the time i had 20 minutes to prepare and then yet to provide an answer so this may have been one

02:09:16 been one i don't know if they're all the same scenarios for all the different interview ease or whether they were different ones so this may have been the one that we got

02:09:26 okay i i i described it as a hypothetical scenario um were you aware before the interview of actual complaints raised by actual

02:09:37 of actual complaints raised by actual residents in relation to the refurbishment as it stood at that stage i think the only thing that we'd seen is

02:09:45 seen is [Music]

02:09:47 [Music] any online presence in the ground for action group

02:09:52 to previous works and previous issues right but i was going to ask you have you actually heard of the grenfell action

02:09:59 action group before the tender interview only only for

02:10:03 only for when the tender originally came in and we heard the the name of the block it wouldn't be unusual to

02:10:10 google and get some background information and that was one of the things that came up right

02:10:17 right so can we leave it this way at this point that that although this was a hypothetical scenario uh you were aware at the interview that the existence of the grenfell action group was not hypothetical

02:10:28 hypothetical it was real yes did complaints of the nature anticipated by this question in fact arise during the works

02:10:36 the works um

02:10:39 that they may have done i mean i wouldn't have have seen or dealt with all the complaints so um they would have been dealt with other site team mainly but yes it's highly likely they could have done yes once you had

02:10:51 done yes once you had or even before perhaps but once you had won the tender did the tma ever explain to you how complaints of this nature set out in this interview question should be dealt with by ryden

02:11:03 should be dealt with by ryden uh we i mean we had a we had an rlo process whereby the residents would be [Music]

02:11:13 [Music] encouraged to come and talk to the rlos the rlos will be in contact with them anyway throughout the works because they would be arranging the bookings to

02:11:24 would be arranging the bookings to gain access to their properties um so we knew you know we had we had a process in place where uh if a resident complaint they'd come to an rlo it would be logged it would be passed on to the relevant

02:11:36 it would be passed on to the relevant manager or client

02:11:40 there was also the housing office where the residents would often go or could could go to and

02:11:48 with any complaints or issues and the housing office and the rlo's met frequently um to try and deal with the complaints from the results yes my question was did the tmo ever

02:12:00 yes my question was did the tmo ever explain to you how complaints of this nature should be dealt with i'm asking really about what the tmo told you rather than the system you had in place um

02:12:11 apart from making them aware i don't think may necessarily actually told us there was a descriptive process right can we then turn please to

02:12:21 ryd3012107

02:12:31 this is an email from claire williams of the 14th of july 2014 so um three or four months or so after you had won the tender

02:12:43 you had won the tender and it goes to you and to simon o'connor and it says the subject is uh councillor fm that's fielding melons as far as we can tell coming to grenfell tuesday 9 30 a.m

02:12:57 and she says i see ryden and studio ee both gonna mention in the grenfell action group blog now you have arrived exclamation mark uh

02:13:10 exclamation mark uh what had miss williams told you about the grenfell action group and the residents associated with it uh i don't i don't recall specific

02:13:21 i don't i don't recall specific um elements at that time that i don't really recall i just remember there being um being made aware that there were

02:13:34 several vocal

02:13:38 residents one of which could be extremely vocal was and was quite well known by the tmi can you give us a name i'm not he's not

02:13:51 can you give us a name i'm not he's not sure that's a appropriate really is it well i'm asking you if i'm asking you i assume that it's an appropriate question and an appropriate sorry can you just give me yes i could give you a knife who is that

02:14:00 is that um eddie dufan right what had mr what had miss williams told you about the grenfell action group just what said that they were they were they had a strong voice um

02:14:12 they had a strong voice um and they were um

02:14:18 yeah that they had a strong voice really um what did you glean from her whether from this email or discussions with her about the attitude that she had to the grenfell action group

02:14:31 um i think they caused um sorry that's probably not the right word i think they um i just think they were very vocal they

02:14:42 very vocal they we were made aware that they were very vocal um in their thoughts about the tmo and any work relating in and around grenfell can i ask you then to look at

02:14:53 then to look at a document tmo double zero eight four zero one one seven

02:15:08 zero one one seven now this is an email from uh eddie dufan

02:15:13 edward defan dated the 22nd of september 2014 to claire williams now you are not copied in on this document

02:15:23 document mr lawrence uh but i just want to ask you one or two questions about what mr tufan says in it uh it's a long document and it starts

02:15:34 document and it starts by way of a context i'm writing to you after hearing from other residents in grenfell tower that the tmo intend to smash down the door of any tenant or leaseholder that fails to cooperate with the

02:15:45 that fails to cooperate with the installation of new heating system and windows

02:15:50 windows and then can i pick it up uh about two thirds of the way down the page where he says now we're here can you see that now we hear that residents

02:16:01 hear that residents will yes sorry yes he says now we hear that residents will in fact be given no choice or opportunity to comment on the windows or cladding that we are to receive as they have

02:16:12 that we are to receive as they have already been chosen by the rbkc planning department residents in grenfell tower that i have spoken with believe that we should have been consulted with before the windows and cladding were chosen and it should be residents that

02:16:25 chosen and it should be residents that have a say in the type of window and cladding that we receive and not the sole decision of a town hall planning department now before i ask you some questions can

02:16:37 now before i ask you some questions can i just ask you to look at another document

02:16:44 ryd3018951

02:16:51 now this is an email from claire williams on the 29th of september 2014 uh to uh you mr lawrence copy to simon o'connor

02:17:02 o'connor the subject is grenfell design information and choices uh and she says i'm aware that you are having design meetings to design team meetings or design

02:17:13 to design team meetings or design meetings she calls them and there are a couple of things i need to be up to date on

02:17:16 on one window design and then she says brackets subject to mr defan's latest inquiry

02:17:22 inquiry and then two the responsibility of design design advisor what had miss williams told you about mr tufan's inquiry at this stage uh i don't recall david

02:17:34 uh i don't recall david do you remember whether she forwarded mr dufan's email of the 14th of july 2014 that we've just looked at to you i don't know that there was um

02:17:46 numerous um and regular um comments made from mr defaun so it could have been one of

02:17:57 mr defaun so it could have been one of many made to the tmo do you remember any consultation with residents on the final clouding or window designs um i don't recall the timings of of

02:18:09 um i don't recall the timings of of which um we carry it we we did a standard carry out a sort of stakeholder engagement a um resident engagement

02:18:20 um resident engagement um meetings um which is what flat 145 was about as well to show what they were and to talk them through what they were going to do we'd have open days we'd go and meet with the residents as

02:18:31 we'd go and meet with the residents as well as a as a group um the tmo i believed with studio where you had done um stakeholder meetings

02:18:42 um stakeholder meetings initially to get the get the project to where it you know to where it got to in the first place um so there was numerous but i couldn't tell you dates and

02:18:53 tell you dates and times and when and et cetera all right let's look at art403716 please and i'd like you to go to within that email run to page four

02:19:10 this is an email of the 19th of march 2015

02:19:14 2015 uh and uh it's from you to miss williams and if we look at page four and over the page

02:19:23 page what you're doing is answering some questions that she had posed to you and her questions are in blue and yours are in italic your answers are in italic red

02:19:32 red and and if we can look at the bottom of page uh

02:19:36 page uh for uh and over the page we can see that you're setting out various options for the hiu

02:19:41 the hiu installation hiu is the heat interchange unit

02:19:45 unit isn't it interface units interface unit yeah now let's look at the bottom of page four in the first paragraph um

02:19:58 uh you um say there um once right in the second line once ryden were contracted to carry out the works

02:20:07 works the design team and the kctma revisited the hiu position to ensure that it was the best solution uh from

02:20:14 uh from a a from a residence and technical point of view

02:20:17 of view there are pros and cons for each solution but as the t but as i'm so sorry but the team as a whole felt and it swiped the page that uh installing the hiu in the hallway which

02:20:29 installing the hiu in the hallway which meant the loss of some wall space was the better solution all round please see below a list of pros and cons discussed for each option and then you run through those and then at the very bottom

02:20:41 at the very bottom you say i've not mentioned the need to fix through asbestos ceiling for the pipe work boxing if the hiu is in the kitchen cupboard i assume you don't need to be questioned on this by mr defan

02:20:53 mr defan would it have been necessary to undertake asbestos removal if the hius were placed in the kitchens uh by that it appears so i don't i don't remember that but yes it appears

02:21:07 i don't remember that but yes it appears so

02:21:07 so and presumably is this right that the tmo wished to avoid the cost of those works

02:21:13 works uh no i don't i don't believe that was the driving factor in any of this i think it was it was probably what i've said out above when you say in the last sentence i assume you don't need to be questioned

02:21:25 assume you don't need to be questioned by mr defan what did you mean by the fact of the moment asbestos mentioned to to anybody in a wider audience

02:21:34 audience whether it's safe to be left in place or not would just be another subject um for mr default to be able to um complain to the teemo

02:21:46 um complain to the teemo well if his complaint was justified what was wrong with that well that's that's between the tmo mrs mr default [Music]

02:21:58 that's between the team i missed the phone well were you seeking to protect ms williams from being questioned by mr dufan in relation to this topic i was suggesting it might not be the

02:22:07 be the bullet point for her to mention but that's entirely up to the tmos to what how they deal and what they wish to mention to mr safar and the rest of the residents indeed but to the objective

02:22:18 residents indeed but to the objective reader it looks as if you are trying to assist miss williams uh in protecting her from being questioned on this topic by mr default well yes i'm sure i am

02:22:30 did you ever communicate yourself to the residents of the presence of asbestos in kitchens impacted on hru installation or their cost i i don't remember

02:22:38 remember do you know why that is if that didn't happen

02:22:43 happen because that wasn't the driving factor as to why the hius weren't in the kitchens

02:22:47 kitchens there were far more driving factors than that

02:22:50 that and removing asbestos board if that was the case

02:22:53 the case um and again without looking at all the reports i don't know um he's relatively minor compared to all the other

02:23:01 the other technical hurdles and disruption that would cause the residents by installing the hrus in their kitchens can we turn to another document on the same topic or same

02:23:12 same topic or same theme i should say tmo1309847 this is an email from a david collins

02:23:24 dated the 26th of august 2015 to peter madison of the tmo and it's copied

02:23:36 and it's copied to a people at our bkc including judith blakeman

02:23:41 blakeman and janet edwards but i don't think you are copied in on this um i just want to show you something uh on this in the second paragraph he says i did manage to get to

02:23:52 paragraph he says i did manage to get to the 18th

02:23:54 the 18th brackets 21st communal hallway floor cleaned yesterday afternoon but my door is still a mess as is my neighbors i received no response to the voicemail i left on monday at 5pm so i rang linda

02:24:06 i left on monday at 5pm so i rang linda the

02:24:06 the the ride in rlo again yesterday morning at 10 19.

02:24:09 at 10 19. i asked if she and a manager would come up and see me simon lawrence and linda arrived quickly saw the mess and left although simon suggested there would always be some mess with the works he said they would get it

02:24:20 with the works he said they would get it cleaned

02:24:22 cleaned simon returned within five minutes at that point he suggested it was one of my friend's fault that a flat was a mess and the workmen said they they didn't leave things the way i suggested well quite how the mess got there and was still there i do not know if the

02:24:34 was still there i do not know if the workman did not do it when i incredulous said something along the lines of of course it was left there simon replied to say why should i believe anything you say anyway if i didn't have the photographs i

02:24:45 if i didn't have the photographs i emailed you which were date and time stamped i actually think simon would have argued with me that his men didn't do it

02:24:51 do it during our conversation he implied that i could just be making this up for my own agenda because i have an axe to grind clearly simon does not appreciate this is not a fun pastime for me

02:25:01 for me i really do not want to be spending my time in these kinds of conversations simon left at that point as soon as i showed him the photographs timestamp from the previous evening whilst i admire his rigor in working to

02:25:12 whilst i admire his rigor in working to the quotes provable and quotes facts he is demonstrating a lack of trust and an attitude of not believing residents and being willing to fight them and what they say if his workmen deny things

02:25:25 do do you recall this conversation with mr collins i don't recall this specific conversation but there are there were various residents

02:25:36 there were various residents who we had conversations with yes did you feel that residents of grenfell tower had an agenda or an axe to grind about the refurbishment i felt there were several and and i

02:25:47 i felt there were several and and i don't think that was reflective of the whole block i think there were very several

02:25:51 several very vocal [Music]

02:25:55 [Music] dare i say aggressive residents that in my opinion regardless of what work was being carried out or not they

02:26:06 carried out or not they still would have um had reason for complain

02:26:09 complain was this an impression you got yourself or was this something you'd been told by the tmo

02:26:14 the tmo um no i'd met several of the residents that were that i would put in that category

02:26:28 did you ever discuss with the residents their

02:26:31 their view about the refurbishment generally or the presence on site and the workmanship and attitude of your men on site sorry

02:26:42 on site sorry sorry is that again in what respect yeah did you ever discuss with residents yourself their view about the refurbishment generally or the presence on site

02:26:52 of your men and the workmanship that they were carrying out i attended several meetings where um both the tmo asked me to attend and us and the tmo presented our works and

02:27:05 us and the tmo presented our works and had

02:27:06 had um debates and discussions with the residents

02:27:09 residents yes but i think you're saying you don't remember this particular conversation i don't mean that to a conversation but it's not um

02:27:20 it's not an unusual um

02:27:27 it's not unusual when you're carrying out works to a

02:27:35 multiple properties with lots of stakeholders understandably interested in in their properties

02:27:46 in in their properties for people to have multiple views and multiple expectations

02:27:53 does that tell us that you're not actually in a position to deny the details

02:27:57 details of the conversation the way that's put across i deny that i don't think that's right

02:28:02 right which parts the tone of the email i don't think that's correct because i don't think that's that's how i personally act with a resident but

02:28:14 there were like i say there were several vocal

02:28:17 vocal residents that were

02:28:21 persistent and aggressive i think he's probably the

02:28:25 well let me just ask you one more time are there any other are there any particular parts of mr collins's report of the conversation he had with you which you would take issue with well i don't recall the whole the the actual conversation but um

02:28:40 the the actual conversation but um i i don't believe i would just be um saying to someone it's not how fault somebody else is and and inferring i'm you know not interested et

02:28:51 inferring i'm you know not interested et cetera et cetera i don't i don't agree with that all right yeah i wouldn't expect any of my team to be to be doing the same either so it wouldn't just be me dealing with the

02:29:02 wouldn't just be me dealing with the any complaints um

02:29:07 if mr collins's record of the conversation in this document that he was writing the following day is correct do you accept that asking a resident in this

02:29:18 accept that asking a resident in this way as he records for provable evidence of what should have been a straightforward complaint might well contribute to a hostile atmosphere between residents and and writing yes but i don't

02:29:30 and writing yes but i don't i wouldn't expect myself or anybody else to be

02:29:35 to be dealing with a resident in in that tone then

02:29:39 then he goes on at the end of that chunk of text what is worrying you see this before the end is how the contracts manager for ryden treated me as far as i can work out either i receive this treatment because i have challenged ryden to one of their

02:29:50 challenged ryden to one of their promises of 2014 engage more with residents investigate reports of harassment keep work areas clean do the right thing etc or this is common treatment which other residents in grenfell tower

02:30:01 which other residents in grenfell tower receive

02:30:02 receive either of these two conjectures is equally disturbing do you accept that mr collins was treated badly because he challenged you no i don't accept i that i treated

02:30:14 no i don't accept i that i treated anybody badly do you consider at the time

02:30:17 time that there was a general problem with how residents uh write and interacted with residents no i think there was a there was a um a strong

02:30:26 strong vocal residence small should i say residence group it was it was the minority not the majority um that were

02:30:40 like i say vocal and vocal and aggressive towards the tmo and in turn us whether they were vocal or unaggressive or not

02:30:53 are you satisfied in your mind that you took their complaints as seriously as possible

02:30:58 possible and and actually made the effort to address them yes but by addressing them doesn't mean to say that they that we do exactly what they are

02:31:09 that we do exactly what they are requesting can i ask you to look at the document this is ryd3049916

02:31:23 this is a set of minutes of the subcontractor progress meeting on the 21st of august 2015 which is a week before

02:31:35 week before mr collins's complaint in his email we've just been looking at if we look at the attendance list at the top of page one we can see that you're not there

02:31:44 not there linda prentice is there and she's the lady i think you referred to ciel as you referred to as the rna um you sent apologies and we could see gary martin chaired it and took the minutes

02:31:57 martin chaired it and took the minutes and we can see that ryden sdp and osborne berry were there so it looks as if this was an internal meeting to the contractors uh and with no one from the client correct yep that's how it appears and

02:32:09 correct yep that's how it appears and indeed no one from artelia either as we can see no um is it fair to assume that you would have received these minutes um not necessarily no is that right you didn't ever did you as

02:32:21 is that right you didn't ever did you as a routine get sub-contractor progress meeting minutes no not necessarily enough why is that because that would be dealt with at site level were you not interested to see

02:32:32 level were you not interested to see what all the subcontractors were saying to each other about what was happening by way of progress that would be dealt with so

02:32:40 with so the intimate detail would be dealt with by the site managers and then simon o'connor and then i would be made aware of of items by exception

02:32:53 made aware of of items by exception so uh you see it says apologies simon lawrence that would rather indicate that that if you could be there you would be in the normal course is that right well i wouldn't be every subcontractor progress meeting no that

02:33:06 subcontractor progress meeting no that would be to be held by the site manager but it looks as if from this

02:33:10 this because you're sending in an apology that you would otherwise have expected to have been at this meeting uh that's that's written by gary martin and my name's on there but i wouldn't expect to be every progress meeting with

02:33:21 expect to be every progress meeting with each sub-contractor well we can actually deal with a that's dealt with a that's dealt with at a site level we have we have a site team and a site site management process site managers

02:33:33 site management process site managers that deal with their package works they have their progress meetings with their subcontractors simon o'connor um and this i don't know if this is after simon o'connor left

02:33:44 after simon o'connor left maybe or maybe not i don't know but i would then expect project manager um he wouldn't even necessarily be at the meeting but he would be aware of what was going on because he

02:33:55 aware of what was going on because he wanted progress and then anything by exception would come

02:33:59 come to myself right

02:34:04 so did these meetings routinely have you not there but marked as providing apologies routinely me not there yes correct but if you weren't expected to be there

02:34:15 if you weren't expected to be there there'd be no need to have an apology recorded by mr martin you wouldn't have to talk to gary who's done the minutes okay let's see how we get on with the pro with the substance of this if you go to page two and look at entry paragraph 502

02:34:28 and look at entry paragraph 502 um it says now we are getting towards the end of the program we will need to make more and more appointments with tenants we need to increase our levels of courtesy to allow this to happen smoothly uh

02:34:41 to allow this to happen smoothly uh whether you would whether you saw this minute or not mr lawrence do you agree that ryden needed to be more courteous in his relations with the residents at that time no i thought we were always going to be there with the residents

02:34:53 going to be there with the residents why do you think uh mr martin recorded the need to increase our levels of courtesy

02:34:58 courtesy to allow this and him the appointment i think you have to ask mr marty so is this right you weren't aware that uh courtesy needed to be improved on site

02:35:09 on site no because i thought we were always courteous without with the residents did mr martin ever not come to you and say we've got a problem our workmen are being rude we need to get we need to be nicer to the residents nice right uh any work that we

02:35:22 right uh any work that we found to be um inappropriate or rude would be asked to um would be removed from site would be asked not to

02:35:33 would be asked not to attend site all right that they're our front line they're a front line of our our reputation and our works aren't they so um they're all representing ryden can

02:35:44 um they're all representing ryden can you explain why then uh the levels of courtesy needed to be increased

02:35:49 increased no because i wasn't at the meeting i think you need to ask mr martin right uh who is mr martin answerable to who was his line manager at this time

02:36:00 at this time uh i don't know if simon o'connor was had left by then or was still there but if simon o'connor was there it would have been simon o'connor um if he'd have left and it then it would have been

02:36:12 have been it would have been myself yes

02:36:18 and i'm going to suggest to you that if there was a need to increase levels of courtesy

02:36:21 courtesy that would be something that would would have to be escalated to you and you'd know that if there was a problem then yes there clearly was a problem looking at this document wasn't there it's quite clearly minuted

02:36:32 wasn't there it's quite clearly minuted but i wasn't aware of it if there was a problem

02:36:35 problem all right let's look at ryd4049444 please

02:36:46 this is an email from claire williams to you of the 17th of august 2008. sorry 2015. uh copyrighted linda apprentice and christina stephanie and she says simon i've just had a

02:36:58 and she says simon i've just had a complaint from mr defan that the flat door of

02:37:01 door of the flat door of flat 136 i think she means front door flat 136 was left open all over the weekend

02:37:08 weekend he also said the perco was broken and the door would not pull to to shut can you please comment also please confirm the flat door can be made to shut securely now

02:37:19 to shut securely now and that it will be left shut out of working hours so as so no as so as no further complaints are received

02:37:28 do you recall that complaint uh no you don't

02:37:33 don't uh can you help us with perco what's perco perko is a self-closing um mechanism within the door yeah do you remember how this complaint would

02:37:45 do you remember how this complaint would be dealt with even in general terms um well if if it obviously did come to me

02:37:53 me um then whoever 136 resident is that may be mr defined it might may not be mystified maybe somebody else i don't know um yeah well we'd go we'd go and

02:38:07 um yeah well we'd go we'd go and we'd go and talk to them first um because any time that we leave a flat it's quite often that we are left there's a process where we're left keys

02:38:18 there's a process where we're left keys so

02:38:18 so people don't have to take time off work et cetera

02:38:21 et cetera so any time that we leave flat it should be left secure and by the look of this it wasn't for whatever reason so i would expect

02:38:33 whatever reason so i would expect myself or one of the team um possibly me at less time to go and speak to the resident and and apologize if that was the case that we left it open um and then to pass on

02:38:45 we left it open um and then to pass on to the rest of the team that it needs to be

02:38:47 be probably via toolbox talks that the doors need to be

02:38:54 secured you aware at this time of the importance of door closes to fire safety um yes but that wasn't our yes yes i understand door closes and

02:39:07 our yes yes i understand door closes and fire safety yes and whose responsibility at ryden was it to ensure that door closers were fixed

02:39:12 fixed if they were damaged during the works uh if they were noticed um then they'd be reported to the tmo because the doors the front doors weren't part of their works

02:39:26 they say if they were noticed it sounds as if that might be haphazard did anybody on site actually monitor that issue no because that's a maintenance issue for the tmo

02:39:38 for the tmo we wouldn't go around inspecting every flat for every um item and

02:39:47 building fabric that we're not dealing with

02:39:53 so no but if the perco was broken and we recognized it then we would suggest that the well i would suggest that the resident

02:40:04 well i would suggest that the resident contacted the tmo as part of their maintenance um and i suggest that we should be passing on as well yes just to clarify one thing mr defaun's flat was flat 134 136 was

02:40:17 mr defaun's flat was flat 134 136 was one of his neighbors okay um do do you do you recall or can you help

02:40:22 you help as to whether this damage was reported by ryden

02:40:25 by ryden at this time to the tmo or was mr tufan's complaint the first time it was raised

02:40:31 raised i don't know you know what steps ryden took

02:40:35 took after you received miss williams email to sort out the door closer

02:40:43 um i mean i don't recall this specifically so um so no like to say i would expect myself for one of the team to go and see the resident um but

02:40:54 see the resident um but yeah i don't recall this at all so i don't know uh can i ask you to look please at met three

02:41:03 39807

02:41:11 this is a report by the bre done for the police on the 20th of february 2019 after the fire and it's issue number two

02:41:22 after the fire and it's issue number two and i'd like you to go to page 78 please in that document

02:41:28 and here we see a list uh and i should just be clear part of a list

02:41:35 of flats in the tower after the fire uh which was reporting on the doors it's a door report if you like

02:41:46 a door report if you like and reading a reading across it's got the floor number the flat number the question as to whether the door was there or not in situ door leaf type door frame type glazing

02:41:57 door leaf type door frame type glazing indoor door closer present door closer type working door closer query

02:42:02 query door open or closed so it's a forensic report

02:42:06 report and if we look down the column

02:42:11 for the for the flats flat 136 on the 16th floor in the second column and we read across the columns we see door closer present

02:42:25 we see door closer present no door closer type not applicable working door closer not applicable

02:42:32 can you account for there being no door closer present in flat 136 at the time of the fire after the fire it wasn't part of their

02:42:43 after the fire it wasn't part of their works i left in 2015. so no did you know that at the time flat 136 was void

02:42:54 flat 136 was void it was an empty flag

02:43:01 now i may come back to that question in in due course but let me just continue a little bit if i may on the subject of resident engagement

02:43:18 if you go please first to ryd

02:43:25 3012644 and i just want to ask you about vulnerable residents this is an email from you to claire williams and sean rumble

02:43:37 williams and sean rumble and let me just wait till it comes up it's ryd three zeroes one two six four four

02:43:50 one two six four four and

02:43:57 but i don't think that's on the system strangely uh let me see if i can find you ryd3012645

02:44:20 no no we don't have those either um let me see if we can do this by recollection and we'll see if we can find the documents over the lunch break but do you remember that in july 2014 you asked claire williams and siobhan rumble

02:44:31 asked claire williams and siobhan rumble for a copy of their vulnerable uh dnva residence list uh i don't recall it but right okay okay well maybe to do that on the documents

02:44:42 documents do you remember getting a list of individuals um in the lancaster west estate where in the lancaster west estate that you'd asked for

02:44:52 asked for um i i don't recall it but it would be

02:44:58 standard information to pass on to the um

02:45:01 um our team in the rlo so we knew how to deal with vulnerable residents right can i ask you to look at a document ryd3024466

02:45:20 now this is a ryden group document grenfell tower resident survey information november 2014 you see that yes did are you familiar

02:45:32 you see that yes did are you familiar with this document uh i don't recognize the header sheet no but right

02:45:37 but right it we think it was carried out by the ryden rla's it would make sense it was yes and if we just look through it just look down to the second page please

02:45:49 just look down to the second page please first of all it uh it's a resident survey information done in november 2014 and if we can go to the third page we see a little bit more about this and

02:46:00 we see a little bit more about this and we can see that uh it's a survey sheet done by grenfell tower address date of the survey and comments across the across it and it

02:46:11 and comments across the across it and it has

02:46:12 has flat straight kitchen name and tenant information children pets health problems and start dates for internal works do you know why the rlr's the ryden rlls

02:46:25 do you know why the rlr's the ryden rlls carried out that uh survey uh yes we would always go and before any of the work started they would go and introduce well as the work started as a hole on site they would go and

02:46:37 as a hole on site they would go and introduce themselves to every resident um provide them details that of how they can

02:46:43 can you know our complaints process how they can be how we can assist during the works um and they would fill in a sheet to identify

02:46:53 identify um any issues or things we needed to be aware of can you remember if this information ryden collected about residents health

02:47:05 ryden collected about residents health problems

02:47:06 problems were shared with the tmo um i i don't know you'd have to ask the rlo's about that rob you don't know is that right i would say it probably would do but i don't know right can we go then to a different

02:47:18 right can we go then to a different document art402788 it's a document we've seen before mr lawrence it's the progress meeting number three on the 16th of september 2014 at which you were

02:47:30 16th of september 2014 at which you were present as we can see from the last but one entry

02:47:33 one entry on the attendees list and if we can go please to

02:47:37 please to again an item i've shown you before paragraph 1.4 on page two you can see that in the first item there it says sl to appoint other consultants

02:47:48 it says sl to appoint other consultants to include fire i've asked you about that and then it says dda and the action is you sl what is dda that's about the disability

02:48:03 that's about the disability so making sure things are

02:48:07 yeah are appropriate for disabled president yes does it help if i prompt you and say dda might stand for disability discrimination act

02:48:18 disability discrimination act right okay yes yeah yeah do you know whether

02:48:22 whether a dda consultant was ever appointed on this project um no and it would be i would take that as

02:48:31 as um relating to the the new works and the lower floors the new

02:48:39 not for any existing occupied resins why would you need a dda consultant only for the lower floors and not for those on the top most floors because we were only doing limited works to the residents

02:48:51 to the residents flats we weren't there to take a survey of their whole flat and determine what they required or what they didn't require that was their landlords

02:49:01 was the decision ever taken in the end not to appoint a dda consultant uh no yeah we didn't and it would like say it would have been around

02:49:12 would have been around design and the new flats that we were

02:49:17 and spaces and the lower floors that we were constructing do you know why a decision was taken not to appoint a dda consultant no i don't but it's it's not a um

02:49:29 no i don't but it's it's not a um necessary uh a usual consultant that i've used on projects provided before whose idea was it that a

02:49:36 it that a that you should appoint other consultants including a dda consultant as recorded in this minute i don't know are you aware that this proposal to appoint a dda consultant was

02:49:49 proposal to appoint a dda consultant was repeated

02:49:50 repeated in later minutes such as the 21st of october

02:49:53 october 2014 in the same language i believe that stayed on the minutes didn't it as we discussed the other day you did indeed and i'm just wondering why that was and when it fell out of the picture uh i don't recall

02:50:05 picture uh i don't recall right uh

02:50:09 right uh do you remember uh a comment or suggestion that the uh ryden newsletter

02:50:20 uh ryden newsletter came out in a language that wasn't only english

02:50:25 i personally don't but um that would be dealt with by our rlo's generally right do you recall any complaints being raised that the newsletter was only available in english and not in any other language

02:50:36 english and not in any other language not not i don't recall any note did anybody ever put on your desk the need to consider whether putting your newsletter out in a different in in more than one language was something you should be considering

02:50:47 something you should be considering we would do that if that was uh if the request would come in we would have and we had um language line and i think the language line and

02:50:57 line and other means to communicate in different languages

02:51:02 languages can i ask you then to look at ryd3011523 and this is on a slightly different topic which is complaints process and complaints prior to october 2015.

02:51:16 ryd3011523

02:51:25 all right let me try a different document it's ryd3011573

02:51:34 this is an email chain uh

02:51:46 this is an email chain uh from july 2014

02:51:52 and if we can look please first of all at

02:51:55 at uh page two of that you can see that it starts on the 8th of july 2014

02:52:06 it starts on the 8th of july 2014 with an email from claire williams to simon o'connor and it says please see the belay

02:52:14 the belay concerns over fire brigade access i know that they are due to meet you this week and i would like to be able to reassure residents with their specific information i know they postponed their visit from last week but said they would be with you before

02:52:26 but said they would be with you before this wednesday do you have a date fixed the fb chat below notes you've contacted them so he knows we are on the case

02:52:34 so this is all about access and and the ability to reassure residents uh and uh

02:52:44 uh and uh do you remember this at all this discussion i don't remember the discussion but i remember the uh i don't remember this chain of emails but i remember um five again access being

02:52:57 five again access being looked at yes right do you remember any discussions um about a complaint from mr defan about changes

02:53:08 changes to access to the tower during the refurbishment uh there's numerous correspondence with mr zafar

02:53:15 mr zafar um so unless you can highlight something specific well i i can do that when i come back i think after one o'clock with you with

02:53:26 i think after one o'clock with you with with a different document but can i ask you

02:53:28 you can look please at met three zeros four one

02:53:32 one zero four four yes

02:53:51 which may also i hope it's on the system it's not right we'll come back to that one as well can i ask you then to look at a document met triple zero four five seven six two

02:54:03 which uh is a grenfell tower issues matrix

02:54:11 dated august 2015.

02:54:16 now do you remember this document uh not particularly but it looks like one that it looks like it's the a complaint

02:54:27 it looks like it's the a complaint sort of log um done by the rlos so yes d did you know that originally grenfell compact what can i ask you have you heard or had you heard of an organization called grenfell compact

02:54:39 organization called grenfell compact no no um now this is i think the first issue of this matrix dated august 2015 when he was still there do you remember seeing this uh nice

02:54:50 do you remember seeing this uh nice not specifically don't now let's look at um

02:54:53 um issue no um or item number 16 or issue number 16 on this list on page two uh

02:55:08 it says some residents gave mr lawrence their flat numbers so that their allegations could be investigated mr lawrence has not yet replied with the results of his investigation do you remember being given flat numbers

02:55:20 do you remember being given flat numbers by residents with a view to investigating their allegations i don't know what the relegations were so no i'm asking you for your recollection i don't recall this at all you don't recall the surprise does 16

02:55:32 you don't recall the surprise does 16 follow 15

02:55:34 follow 15 are they related uh let me ask um look at item 15 update on ryden's investigation into allegations of harassment and threats by some employees of ryden and the tmo

02:55:46 employees of ryden and the tmo to investigate such matters residents have to provide specific details complaints can either be channeled through ryden or through the tmo complaints procedure the tmo will reconfirm details of these challenge of these channels and the

02:55:57 challenge of these channels and the appropriate contact details in the next edition

02:56:00 edition of the newsletter can you assist with that

02:56:03 that what what in investigation so far as you know

02:56:06 know was ryden carrying out into allegations of harassment and threats by some employees of ryden and the tmo i i don't recall i don't recall this but

02:56:18 i don't recall this but i would not be expecting our employees to be

02:56:22 to be harassing or threatening anybody so um so no i don't recall this you don't recall it you don't recall it specifically or you don't you don't recall any of it at all

02:56:33 don't you don't recall any of it at all i don't really record any of it at all can you explain how this matrix which was produced at a time when you were still on the project refers to an investigation which had to be

02:56:45 to an investigation which had to be updated

02:56:46 updated into allegations of harassment and and threats

02:56:49 threats i don't recall it so without having more information i don't are you saying as you sit there that as far as you remember there were no allegations of harassment and threats but i'm saying i don't

02:57:01 but i'm saying i don't i'm saying i don't remember i don't remember that no but just because i don't recall it doesn't mean to say that it's been logged so

02:57:13 mr chairman we're a few minutes early the earlier than one o'clock which is when we would normally rise um i just want to make sure i can pick up the references to the documents i would like to show mr

02:57:24 to the documents i would like to show mr lawrence after lunch and i'm sure i can do that over the over the lunch break um and then continue with the questions i have for him

02:57:31 him can you give me any indication of how much longer you might need to be with him

02:57:35 him yes indeed i've got on the questions i have prepared for him uh probably another um hour at the very most but then we will

02:57:46 hour at the very most but then we will have to break and i will need to make sure that

02:57:48 sure that we can canvas any follow-up questions from the appropriate yes of course sources but there may or may also be um some further questions which have come in

02:57:57 in during the course of the morning which i need to assess over lunch so i can't promise that it would be it would be three o'clock well um mr lawrence i did tell you yesterday i couldn't promise that you'd

02:58:08 yesterday i couldn't promise that you'd be finished by lunchtime and so it has transpired i'm afraid uh we're going to go on for a little bit after lunch sorry about that but anyway we'll break now come back at two o'clock

02:58:19 we'll break now come back at two o'clock please

02:58:19 please and no talking to anyone about your evidence

02:58:23 evidence thank you very much

02:58:36 right thank you two o'clock please

02:58:59 you