Rydon Evidence - Wednesday 29th July 2020 (2/2)

29 July 2020 · Simon Lawrence (Rydon), Simon O'Connor (Rydon), Counsel to the Inquiry · 2:44:15
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Grenfell Tower Inquiry - Rydon Evidence - Wednesday 29th July 2020 (2/2). Evidence from Simon Lawrence and Simon O'Connor regarding Rydon's role as main contractor, material substitutions, and project management failures.

Key moments

Full transcript

00:00:28 right would you ask mr blake to come back

00:00:42 please

00:00:56 um

00:01:01 right mr rigg thank you yes mr chairman mr blake

00:01:04 mr blake um i just wanted to go back to a topic we looked at before the lunch break which was carl stokes and there's a document that i should have shown you this morning but i want to show you now can you look

00:01:15 i want to show you now can you look please at cst401284

00:01:24 this is an email at the bottom of the page that i think you won't have seen before

00:01:29 before between carl stokes and the tmo uh from april 2017. it's from carl stokes to janice ray uh and

00:01:42 uh carl stokes says to janice ray grenfell was clad but the cladding complied with the requirements of the building regulations lots of questions asked of ryden's and

00:01:54 lots of questions asked of ryden's and answers received back from them did you receive questions from mr stokes do you remember about the cladding

00:02:05 do you remember about the cladding um no i don't i don't remember that well uh mr stokes is saying uh that lots of questions were asked of ryden's

00:02:14 ryden's in the context of the cladding complying with the building regulations do you remember receiving any questions from mr stokes about whether the cladding complied with the building regulations no i don't do you remember providing any

00:02:27 no i don't do you remember providing any advice or answers to mr stokes about whether the cladding complied with the building regulations no i don't to your knowledge did anyone from ryden give mr stokes any assurances

00:02:39 from ryden give mr stokes any assurances regarding the compliance of the clouding system

00:02:42 system with the building regulations i don't know whether they did i'd like now to turn to the topic of um fr 5000

00:02:51 fr 5000 which was one of the insulation products to be used on grenfell tower and in the end was uh was changed to uh our um rs5000 but

00:03:04 changed to uh our um rs5000 but there was no product change can i uh ask you to look please at sea 50169 page 73 this is the nbs specification and

00:03:17 this is the nbs specification and specifically that part of it which specifies or specified uh fr 5000 as insulation for use of grenfell tower if we look at paragraph 776

00:03:30 if we look at paragraph 776 in this section dealing with h92 range green cladding we can see there that the thermal insulation was stipulated uh as rigid pir insulation board

00:03:43 uh as rigid pir insulation board manufacturer did you see that okay yes

00:03:50 okay yes uh did you read the specification or and specifically this part of it at any point during your involvement with the grenfell

00:03:59 grenfell tower project um i i can't uh recall that right you can't recall that you could see just a little bit lower down that the product

00:04:10 a little bit lower down that the product reference there is fr5000 aluminium foil faced both sides when did you first become aware that fr 5000 was the insulation product

00:04:22 fr 5000 was the insulation product originally stipulated for use out on the tower um after the after the fire i see

00:04:35 were you familiar during your involvement with the project with fr 5000 as a product no does it follow from that that you had no

00:04:46 does it follow from that that you had no views one way or the other about its combustibility that's correct did you ever discuss this product

00:04:55 product with anybody or have anybody mention it to you or ask to discuss it with you during the project during the project yes no i didn't no can i ask you about kingspan cool firm

00:05:06 can i ask you about kingspan cool firm k15 insulation are you aware that although as we can see here from this page the nbs specification provided for the use of celetex fr 5000 a quantity of kingspan

00:05:20 fr 5000 a quantity of kingspan cool firm k15 was also installed on the building as insulation did you know that at the time i didn't know that well i um

00:05:33 from the previous evidence is i'm aware of that and

00:05:42 i was made aware that there was a an amount at the end of the project that was

00:05:50 used on the building

00:05:54 well um you say previous evidence are you referring to the evidence given to this inquiry yes oh i see well let's let's let's just explore that a little bit can i ask you to be shown ryd 30 is

00:06:07 can i ask you to be shown ryd 30 is 94213

00:06:10 94213 at page 10 please now this is david hughes's witness statement and i'd like to look at paragraph 55. he says uh in december

00:06:23 he says uh in december 2015 or january 2016 i discussed with ben bailey and agreed the use of kingspan as harley's had difficulty obtaining celetex

00:06:32 celetex from their supplier as far as i was concerned kingspan and celetex are similar products with similar insulation properties as far as ben and i were concerned it was a ca it was a like for like swap of insulating

00:06:44 like for like swap of insulating material

00:06:45 material i told steve blake and the clerk of works john white of this use of kingspan insulation material

00:06:52 material do you remember having a conversation with mr hughes about swapping rs 5000 for kingspan coolphone k15 um but prior to this being raised i i

00:07:06 um but prior to this being raised i i um it wasn't part of my recall but this um is um something that happened so um i i agree with that you agree with it

00:07:19 i i agree with that you agree with it right yes

00:07:25 did david hughes do you remember ask you whether it was acceptable to use the kingspan product um i don't recall the exact

00:07:42 exchange do you recall whether he was simply i see you don't recall the exchange i mean from your recollection you you accept i think what mr

00:07:54 accept i think what mr hughes is saying here are you accepting what he's saying here namely that he told you of the use because he remembers it or or are you telling us that you have your own independent recollection of that

00:08:06 independent recollection of that discussion his his statement has prompted my recall and i i don't disagree with um what he he's put down here right so do

00:08:18 what he he's put down here right so do you have

00:08:19 you have a recollection of your own of discussing this matter with mr hughes yeah but i don't know exactly what we discuss right

00:08:30 discuss right okay can you remember this much was he asking you for permission to use it or is he asking you or just telling you that it was being used

00:08:40 used um he would be informing me of uh this

00:08:47 uh this this event and i would i would hope that he's telling me that um it is an equivalent material um so

00:09:00 um so that's um that seems perfectly um correct um note of of what we of what we spoke

00:09:12 note of of what we of what we spoke about

00:09:15 so your recollection is that he told you it was an equivalent material i just want to be clear about you yes i i would yeah i would um say that's um what i was told

00:09:28 um say that's um what i was told equivalent in what respect do you remember in in all respects do you know the basis on which mr hughes could have known how

00:09:40 could have known how cool them k15 could have been equivalent to the celetex in all respects um i i don't know that no [Applause]

00:09:53 when this discussion occurred in december 2015 or or january 2016 had the product already been ordered do you remember

00:10:03 um i don't recall do you know whether it was on site it may have been now mr hughes says that as far as he was concerned and i've just shown you this on the uh in his statement kingspan and celetex

00:10:14 in his statement kingspan and celetex are similar products with similar insulation materials and that it was a like for like swap did you have your own view about whether that product was indeed a like-for-like swap with celetex or did

00:10:25 a like-for-like swap with celetex or did you just take it on trust from him i took that as as read right did you know that this product kingspan k15

00:10:33 k15 or well let me ask you a prior question did you understand when he referred to kingspan that he was referring to kingspan cool firm cool firm k15 no it was

00:10:45 the same material from a different manufacturer did you know that kingspan is a pur polyurethane rigid foam whereas celitex

00:10:53 celitex rs 5000 as it had become is a polyisocyanurate pir no i did not right

00:11:06 did you take any steps to satisfy yourself

00:11:09 yourself that celetex and kingspan were like for like materials no i didn't and i and i should have done

00:11:22 yeah you say you should have done what in hindsight yes did you or anyone else at ryden talk directly to kingspan about the suitability of kingspan cool firm k15 on this building

00:11:35 this building uh no

00:11:40 so it would follow from that you never sought any informational documentation as to the fire performance of this product

00:11:46 product on this building no i

00:11:51 assumed without personally checking that it was a light for light product um it was the end of the install

00:12:02 when the mast climbers were coming down

00:12:07 so miracle it was for an extremely uh limited amount that doesn't excuse not checking it out

00:12:18 that doesn't excuse not checking it out but in the context of the whole it was for in filling um the the gaps left on the building with

00:12:30 the the gaps left on the building with the removal of the mask climber fixings did you see where this kingspan was being put on the building at the time um

00:12:41 time um exactly what i've just described is where i understood it to be used do you remember seeing any gaps in any particular places for example the east elevation uh only

00:12:53 for example the east elevation uh only where the

00:12:53 where the the mass climber fixings were removed um so and that that's where i understood it was going to be used right i see okay

00:13:05 right i see okay as they were being taken off the building

00:13:09 building i i i'm assuming that you never asked to see the bba certificate for kingspan i i have this product

00:13:16 product i don't think i did and i can't recall well let me just see if i can show you a document to see if it prompts a recollection

00:13:25 k-i-n-3014639 please

00:13:37 now this is the bba certificate for kingspan insulation uh first issued on the 8th of october 2015.

00:13:47 2015. see that yes and it says in the middle of the page behavior in relation to fire the product is classified as cs1 d naught in accordance with bn

00:14:00 naught in accordance with bn bsen13501

00:14:02 bsen13501 does this prompt a recollection that you saw this at the time december 15 january 16. no

00:14:10 were you familiar with this document at all at the time do you think not the time now

00:14:20 were you aware or did you consider that the substitution uh of rs 5004 cool them k-15 might have had an impact

00:14:31 cool them k-15 might have had an impact on whether the facade design as a whole complied with the building regulations

00:14:38 um

00:14:41 i would have worked on the basis that it was being

00:14:45 was being um suggested as as a as an alternative on the basis that it was um

00:14:54 was um equivalent in every respect

00:15:01 so you that was an assumption that you would have made which you didn't explore that's right did you consider checking back with the contract that you

00:15:12 checking back with the contract that you had with the tma to satisfy yourself that when this substitution was made there was nothing that you should be doing to make sure it was safe

00:15:21 was safe um i would know that from previous experience if there's a um a change that's suggested um

00:15:34 a change that's suggested um it needs to be verified what steps did which were taken to your knowledge to verify i've said that there weren't

00:15:46 can you account for that failure

00:15:52 no

00:15:56 given that this product k15 was not on the nbs spec and it was a substitute it appears that no advice was taken from a

00:16:07 no advice was taken from a fire safety expert such as x over or indeed any fire safety engineer to verify whether it was safe can you explain why that was same reason as i've already said do you

00:16:19 same reason as i've already said do you accept that before accepting the product as an equivalent substitute you should have made those inquiries

00:16:27 um what um what should have done is uh present the the choice to the um architect um i've it's been given

00:16:40 um i've it's been given to us by the um specialist contractor as an equivalent um and then i should have run a uh a process

00:16:51 process by the architect um just to double check but i've accepted on the basis that it's given to me by our

00:17:01 our specialist who is employed with that

00:17:06 obligation um that i would have passed it to the architect for them to check

00:17:14 check now we've already discussed some parts of the contract and i think we've seen that

00:17:17 that the contract with the tma provided that ryden wouldn't substitute any materials specified in the employer's requirements without the prior written consent of the tmo

00:17:27 tmo we saw that yesterday did you notify the tmo will seek the tmo's approval for the use of kingspan coolthon k15 on the building no i didn't why is that

00:17:40 on the building no i didn't why is that for the same reason but what you should have done but what is the reason why you didn't oh you've said i i said i haven't done

00:17:51 oh you've said i i said i haven't done it so

00:17:52 it so i'm just trying to get to the bottom of why there is no reason as to why i wouldn't do that it's um

00:18:04 it's at the there's i can't give a reason why not because that's what i should have done all right did building control ever receive any drawing or specification that provided written confirmation that

00:18:15 that provided written confirmation that kingspan k15 was being proposed as insulation material in this bill is there any reason why that was the case

00:18:26 for the same reason

00:18:32 can i just look at your statement ryd3094225 page 14 please and look at the second line at the top of the page this is paragraph 9.1

00:18:49 and in the first full sentence there you say building control were provided with all that they requested as part of their process for satisfying themselves that the work was compliant

00:19:00 themselves that the work was compliant building control certified that the building was compliant with building regulations now in the light of of your evidence there

00:19:08 there given that building control weren't aware of the substitution of kingspan cool them k-15 do you know how they would have known to request information in respect of it

00:19:21 they wouldn't have done so therefore how could you rely on building control certification that the building was compliant with building regulations if you hadn't told them about the substitution of the insulation

00:19:33 substitution of the insulation and they hadn't considered it by going back to the first part is that um

00:19:44 um i understood from the specialist contractor that it was an equal or approved product for

00:19:57 the the quantum of it is

00:20:02 no excuse for not for not doing that but for a very limited um area at the completion of the

00:20:13 area at the completion of the of the project just following up on that answer you say i understood from the specialist contractor that it was an equal or approved product by specialist contractor do you mean harley

00:20:24 contractor do you mean harley yes i do yeah that's did anyone from harley tell you that kingspan k15 was an equivalent or was it equal or approved product that's going back to

00:20:36 that's going back to today's statement i see

00:20:41 coming back to my question again though how could

00:20:45 how could you rely on building control certification that the building was compliant with the building regulations in circumstances where you knew that building control had not been provided

00:20:56 provided with information about the substitution of

00:20:59 of rs 5000 with kingspan k-15 cool firm i relied on on the basis that um i believe that that product was

00:21:11 i believe that that product was compliant

00:21:12 compliant no that doesn't quite answer my question you're looking at your statement you say building control were provided with all that they requested as part of their process for satisfying themselves that the work was compliant

00:21:26 my question is how could you rely on building control uh certifying and satisfying themselves that the work was compliant when you knew they hadn't had all the information and particularly as

00:21:39 all the information and particularly as i say

00:21:39 i say the information that kingsman cool 15 cool firm k-15 was going on the building

00:21:46 i i'd still rely on it in the same way i believe that product um to be compliant so therefore

00:21:57 um to be compliant so therefore it would be compliant well you might think it was compliant let's assume that but you would know that building control wouldn't have had all the information and therefore you couldn't rely on

00:22:08 and therefore you couldn't rely on building control because you had no building control didn't have the information it must be right

00:22:18 sorry i don't see

00:22:22 why i wouldn't think that right uh different topic cavity barriers at chalcott's and ferry point do you remember there was a fire

00:22:33 point do you remember there was a fire at taplow house on the chalcott's estate in january 2012. id and you were the contract manager for that project i think when she told us yes uh what was your involvement

00:22:45 told us yes uh what was your involvement in dealing with that incident just in headline terms um i was informed by the

00:22:52 by the um client that there'd been a a fire in in the in the property and they asked me to visit site

00:23:05 which i did um that we have an ongoing um maintenance obligation after the refurbishment works

00:23:16 after the refurbishment works um and part of that remit was to um assist with the immediate clear-up um and then thereafter the

00:23:28 um and then thereafter the um reinstatement of the of the of the area damaged by the fire right now can we look at har3010169

00:23:39 right now can we look at har3010169 please

00:23:41 please this is harley's uh incident report from that fire

00:23:46 that fire and we can see that it's dated the 17th of january 2012 and those present included you

00:23:55 uh and from the introduction we can see that

00:23:58 that it has started with a telephone call from steve blake writing construction to tim lovell contracts manager and ray bailey director

00:24:06 director on the 17th of january 2012. it was confirmed that a fire did indeed take place to the inside of a flat 123 on the 17th floor to taplow house

00:24:17 123 on the 17th floor to taplow house and you can see in the second sentence that the new facade also consisted of additional fire breaks and rockwool insulation

00:24:28 do you remember alerting harley to the fire

00:24:31 fire yes look at page four please of that document and i just want to look with you at the words in the middle of the page

00:24:39 page uh now first of all you can see as a photograph with a gentleman pointing is that you it is

00:24:46 is right and then underneath it it says it was evident that despite the fire and the amount of flammable items in the flat such as paper etc the fire breaks were still intact and prevented the fire spreading between

00:24:58 prevented the fire spreading between flats the highly designed fire break system is visible now the surrounding fabric is melted under the extensive heat and we can see you pointing what are you pointing to

00:25:09 pointing to um that's to the head of the window where the

00:25:13 where the um fire break was located when you say fire breaks do you mean cavity barriers um yes

00:25:25 um yes yep you don't sound sure um i know there was a debate about the um definition of the description um so that is um

00:25:39 so that is um yeah it's i would put it as a as a fire break and it is a barrier it is a barrier across a cavity

00:25:49 cavity right so but he either can be applied to this

00:25:57 uh what's been referred to

00:26:01 would be neither what does fire break mean

00:26:04 mean in addition to cavity barriers um the arrangement of camden is is um not

00:26:15 is um not is dissimilar to um grenfell well that just in terms of terminology fire break what does it mean it's a a means of stopping

00:26:26 it's a a means of stopping um fire from one compartment to another can we look at cep 5-0 sorry for

00:26:37 four zeros three two two three please cep four zero three two two three

00:26:45 this is uh um an ab sale survey

00:26:50 for the same incident uh are you familiar with this document i am yes um and let's just look at the distribution list on the next page

00:27:01 distribution list on the next page please page two you can see that um your head of the distribution list there as are ray bailey and daniel anchored jones from harley and others from harley as well like mark

00:27:13 and others from harley as well like mark stapley this is dated the 23rd of january 2012. and if you look please uh at the distribution list in total you

00:27:24 uh at the distribution list in total you can see you're the only ride and representative on that list did you distribute it more widely within ryden when you got it do you think um i i would have thought so yes i can't

00:27:38 um i i would have thought so yes i can't recall

00:27:40 recall precisely but i would think so yes to whom within ryden do you think doing the best you can you distributed it

00:27:50 it um it would have gone to the legal team um that would have been uh

00:27:58 to put insurers on notice um and i would i would have reported it to jeff as a matter of course anyway so um and

00:28:12 to the people on the main who administering the maintenance contract did you have a system did ryden have a system in place to ensure that documents such as this were circulated amongst

00:28:23 such as this were circulated amongst people who needed to see them

00:28:29 yeah it would um

00:28:34 go to whoever was needed to see it did you have a system of ensuring that important lessons arising from events like taplow house

00:28:45 events like taplow house became the subject of an established practice within ryden um lessons learned yeah there was always opportunity for

00:28:56 yeah there was always opportunity for lessons learned

00:28:59 not necessarily a you know a prescriptive formal system um

00:29:06 system um but yeah the okay let's look at the document if you go to the bottom of page one in the introduction you can see in the second paragraph in the page uh there

00:29:15 there it says the damage is recorded as having been extensive you see that sort of the end of the first paragraph and then the look at the third line of the second paragraph the severity of the fire completely destroyed the living room window

00:29:27 destroyed the living room window however the fire was contained from spreading to over floors by the extensive fire breaks located at the head and sill of each window

00:29:36 smoke smoke damage caused further damage to the

00:29:40 to the external cladding and cavity does that accord with your recollection

00:29:48 um well that's this is harley's report that they've produced yes does it accord with your recollection

00:29:58 um i didn't do the report so um no i don't know what you're asking me well

00:30:05 well we saw from the ryden document that that you had been on site yeah and had seen

00:30:11 seen the damage and specifically around the windows because you confirmed that it was you

00:30:16 was you pointing uh my question is does the harley report in the passages i've just read to you correspond with your recollection

00:30:26 it does but they're making a statement about containment the fire went out because the fire brigade put it out

00:30:34 um let's go to page

00:30:40 two at the top there

00:30:48 sorry two at the bottom i should say we go to two at the bottom this is the

00:30:54 yeah where it says the fire was contained from spreading over floors by the extensive fire breaks located at the head and sill of each window

00:31:05 window do you disagree with that conclusion well that was part of the process but that's a statement they're making

00:31:15 they've been asked to provide a report um but i'm reading that and you know the file was put out by the

00:31:26 and you know the file was put out by the fire brigade let's go to page 14 please let's look at the text at the top

00:31:35 you can see in the second line there the conclusion that hardly reaches the fire barrier prevented the spread of fire into the internal space now this is in context in a particular location

00:31:46 location um that's the conclusion and if we can turn over to page 15

00:31:54 we see the conclusion to the document and let's just look at the third paragraph

00:31:58 paragraph it is however apparent that the design of the facade and fire stops has unquestionably worked well as despite the severe heat the extremes of the damage have been compartmentalized within the flat and a progressive tower block fire has

00:32:10 and a progressive tower block fire has not occurred the actions have all involved from designers building users fixing teams and fire brigade may have saved lives and has led to the facade remaining physically intact in many ways this has been a success for

00:32:22 in many ways this has been a success for all concerned now i know you didn't write the report but to your way of understanding it when you read it did fire breaks fire barriers and fire stops all mean

00:32:33 fire barriers and fire stops all mean the same thing or do they mean different things

00:32:37 things um in the context of this report the same thing is that cavity barriers yeah thank you now just pausing there would you agree that anyone reading this

00:32:48 would you agree that anyone reading this document

00:32:50 document would consider that the use of cavity barriers around the windows had been a critical factor in stopping the fire spreading from the flat in which it started to

00:33:02 from the flat in which it started to the rest of the building

00:33:05 um as as part of it yes definitely do you agree with the conclusion set out in that

00:33:13 in that third paragraph there that i've read to you

00:33:22 um yeah um there's no reason not not to agree with that

00:33:31 with that would you also agree therefore that as a recipient of this report and and indeed as the sole representative who actually attended taplo house after the fire you had first-hand knowledge of the

00:33:43 you had first-hand knowledge of the importance of cavity barriers to the prevention of fire spread in high-rise overcloud buildings such as taplo house by the time you began work on the grenfell tower project

00:33:55 grenfell tower project indeed yes and in and in particular you had first-hand knowledge of the importance of cavity barriers around windows

00:34:08 yes i did yes [Applause]

00:34:16 did the tapper house fire caused you to consider whether insulation which was of limited combustibility should be used above 18 meters

00:34:28 no it didn't did the tableau house fire cause you to consider whether acm panels where the riveted or faced fix with a pe core was suitable for residential buildings above 18 meters no

00:34:40 residential buildings above 18 meters no it didn't

00:34:41 it didn't did you having read this report and have reason to think that

00:34:51 a great deal depended upon the proper and effective installation of cavity barriers around the windows as a means of saving lives in

00:35:02 as a means of saving lives in circumstances where acn polyethylene panels were used

00:35:09 um i knew that that was yeah a part of the strategy compartmentalizing um

00:35:22 for the arrangement yes and would you accept that

00:35:29 given the importance of cavity barriers around the windows in order to prevent external fire spread ryden was contractually obliged this is your understanding at the time

00:35:40 your understanding at the time contractually obliged to provide cavity barriers around the windows at grenfell tower that was the design development that um

00:35:51 had taken place on that contract i don't understand that that that was the design that um was um

00:36:03 um was um finalized and installed on that contract so

00:36:07 so um which contract the camden one i see that's not an answer to my question i'm afraid i'm going to ask it once more

00:36:17 once more given the importance of cavity barriers around the windows in order to prevent external fire spread was it your understanding at the time that when ryden entered into its contract with the tmo it was obliged uh to provide cavity

00:36:30 it was obliged uh to provide cavity barriers around the windows at grenfell um i didn't necessarily know that i knew that there was the requirement to provide protection at compartments

00:36:45 provide protection at compartments [Music]

00:36:46 [Music] so that that was my understanding

00:36:53 how many exp prior to the um start of the grandfather project and your involvement in it how many uh incidents like the one at tatplayer house had you experienced

00:37:06 house had you experienced what a full-blown fire a full-blown fire affecting a rain screen cladding uh that's

00:37:13 that's that's my um only experience of that yeah

00:37:17 yeah in the light of that sole experience at tableau house did you ever think to check

00:37:22 check the designs of the windows and ensure that

00:37:25 that the proper cavity barriers were provided for in those designs to ensure that if a fire did break out the same degree of protection would be afforded

00:37:34 afforded at grenfell as experience had shown you had been afforded at taplow house i'm not the designer of um

00:37:46 of um of of of anything so at grenfell that was the commission of harley's studio e

00:37:58 commission of harley's studio e and and to building control well let me qualify the question in the light of your sole experience at taplow house did you ever think to

00:38:09 at taplow house did you ever think to check

00:38:09 check with studio e or harley that property proper cavity barriers were provided for in their designs so as to be sure that if a fire did break out

00:38:20 break out the same degree of protection would be afforded at grenfell as experience had shown you it had been afforded at taplow house um i didn't do that with them no why not

00:38:32 um i didn't do that with them no why not given the experience that you'd had at tapla

00:38:37 tapla because i relied on

00:38:41 harley's in particular if the the notation from their report here would

00:38:48 would show me that they see it as particularly important so why would they um not apply

00:39:00 um not apply um the same uh level um to the to the work they're doing at grenfell i had no reason to think that the

00:39:11 i had no reason to think that the design that they that was

00:39:17 evolved and developed through the exchanges through the design team would not be appropriate i understand that mr blake but i'm just

00:39:30 i understand that mr blake but i'm just asking you from your own experience why you thought it sufficient simply to rely on harleys and let them get on with it

00:39:38 it in circumstances of your own personal experience and involvement at tapley house

00:39:44 house well at the point in time when this design development was occurring

00:39:51 i wasn't

00:39:54 the fulfilling the contract manager's role

00:39:59 role on the project

00:40:07 in very general terms did you know that acm would be gone rather quickly in a fire if there was a fire on the exterior

00:40:16 exterior i did not know that can i ask you

00:40:29 can i ask you a slightly different topic now can i ask you to go please to art six six 40664 one

00:40:43 and this is a set of emails in march 2015

00:40:49 and i'd like you to go to page two and look at the bottom of that page

00:40:53 this is an email from matt smith of max fordham to clare williams of the tmo on the 17th of march you need to go to the to page two please

00:41:05 you need to go to the to page two please and look at the bottom of page two yes uh and afternoon claire he says we've been round the houses with this a bit already now you're not copied in on this i should just say um there appears to be

00:41:17 should just say um there appears to be some confusion with js wright ryden so would you be able to explicit explicitly state which flats the tmo requires to be lifetime homes compliant whether these flats are to be fully compliant i.e middle level trvs

00:41:30 compliant i.e middle level trvs consumer unit etc and then which flats or flats is disabled access and what requirements the tmo has for it lst radiators etc now

00:41:42 etc now if we move up then to the top of that

00:41:46 page claire williams tells mr smith on that day matt if ryden do not know what is in the contract then they should raise an rfi so there can be a formal response within a time frame

00:41:58 within a time frame the question is were you aware that the tmo at this time thought that ryden might not understand its contractual obligations

00:42:08 um i would imagine that we are asking a question because it's not clear

00:42:17 do you accept it was your job to be aware of concerns such as this if they existed

00:42:24 um i see this as

00:42:28 a simple request for information um that would be dealt with by the project team right let's move to page one

00:42:39 right let's move to page one we can see neil reads of artelia's response to matt smith on the 19th of march

00:42:46 and he also sends it to claire williams now you're not copied in again i should just

00:42:51 just draw that to your attention but in the second paragraph mr reed says matt i appreciate we haven't spoken yet but looking forward to working with you and introducing some improved discipline by ryden to the resolution of queries

00:43:03 by ryden to the resolution of queries decisions etc you'll be very welcome to attend the meeting so by copy to nick i will ask him to invite you so we can meet and discuss project status quo

00:43:13 i just want to ask you about the improved discipline brackets by ryden brackets that he refers to did neil reed or anybody else at artelia or indeed claire williams at the tmo for

00:43:24 or indeed claire williams at the tmo for that matter tell you that needed ryden needed to just to improve his discipline in any respect um when i took over the um

00:43:38 when i took over the um cm duties um

00:43:42 part of that would have been um some resolution of outstanding uh queries

00:43:49 queries um

00:43:52 and my recall being that it's not clear from the information provided what was required

00:43:59 required which is why the question has been raised again very um very straightforward um not unusual um dialogue um in a

00:44:12 um dialogue um in a in a contract situation

00:44:16 you say when i took over the cm duties that's october 2015 is it well i've introduced myself to the uh project

00:44:24 project uh simon um gave you notice which i think was 12 weeks so i knew that simon was going um

00:44:36 so i knew that simon was going um that would be end of august september time

00:44:39 time yeah but this is march you see to that i'm asking so at this start you hadn't yet taken over asia so at this stage at this stage when simon lawrence is

00:44:50 at this stage when simon lawrence is still

00:44:51 still the contract manager yeah do you know why

00:44:56 why artelia had the impression that the discipline by ryden needed to be improved

00:45:03 improved um at least in the respect i don't know you don't know whose responsibility at that stage march 15 was it to deal with the resolution of queries decisions etc

00:45:17 that would be uh simon's role to raise that with the with the client team

00:45:23 team i see did anybody from artelia or the tmo come to you and complain that simon lawrence wasn't very disciplined in respect of his resolution of queries decisions

00:45:35 resolution of queries decisions etc um

00:45:38 etc um i i can't recall right

00:45:43 can we look at art four art406629 please

00:45:49 this moves forward in the story by a month or so this is an email from neil reed of artelia to claire williams of the 9th of april 2015.

00:45:59 and you're not copied in on it but i just want to ask you about there's one or two things in it uh he says with my limited involvement to date i held a perception that one the

00:46:10 date i held a perception that one the scope of the work that ryden is doing is not as well understood as it could be there is significant email traffic of what is considered to be in the contract the roles and responsibilities of all parties do not appear as clear to me as

00:46:22 parties do not appear as clear to me as they could be processes for resident liaison crw scope architectural compliance monitoring for example

00:46:28 example new risks and issues are arising that need managing mitigating and for which financial provision is required in terms of bill cost and consultancy implications and then he proposes a meeting and the meeting objective to review the contract

00:46:39 meeting objective to review the contract documents and scope of works desired outcome clarity on what is and is not included in the contract and the implications arising

00:46:49 this would include christian limb and simon from ryden i think that's not i'm sorry and perhaps i simon from ryden both are available should you agree did anybody raise with you at this time

00:47:01 did anybody raise with you at this time early april 2015 the problem that mr reed identifies in paragraph

00:47:08 one um no i don't think so what about issue two that he identifies does anyone raise with you the problem that mr reed identifies there no

00:47:20 that mr reed identifies there no i don't i don't recall that

00:47:27 now i think in your statement you say you received reports from managers on all matters of progress including safety and whether and whether the project was on time and to budget looking at item three

00:47:41 in mr neil mr reed's email is it fair to say that

00:47:44 say that that kind of issue fell squarely within the scope of what should have been brought to your attention through the process you've described

00:47:54 um yeah if there's um items

00:48:01 um items outside the scope of the contract i mean can you explain how come you weren't aware at this time of the matters of complaint or

00:48:12 of the matters of complaint or uh yeah complaint that the subject of paragraphs one and two of mr reed's email

00:48:20 email um i don't see them as complaint i see them as

00:48:25 them as um a

00:48:28 um a an employer's agent um who himself is um new to the job i don't see any uh issue about the scope

00:48:40 i don't see any uh issue about the scope of the work if i think it's good that there's a traffic of email um clarifying exactly what is required i don't see a problem with that at all

00:48:52 don't see a problem with that at all the roles and responsibilities of all parties

00:48:55 parties do not appear to appear as clear to me as they could be that that is a reference to the job as a whole that artelier are the project manager on behalf of the client for

00:49:06 behalf of the client for so that seems to be they're criticizing themselves new risks and issues you can only deal with them

00:49:14 with them as and when they arise um and whatever so that's i don't see that's um an issue either

00:49:28 um an issue either all right that's your that's your answer on the substance uh my question was was whether anybody raised

00:49:35 raised these matters with you at the time never mind

00:49:39 mind whether they're complaints or not complaints did anybody raise with you the matters identified in paragraphs one two and three at the time um i don't think they they they did and i i don't see

00:49:52 they they did and i i don't see a reason for well uh

00:50:01 can we look at art406657 this is an email sent after a meeting which appears to have taken place on the 17th of april 2015.

00:50:12 17th of april 2015. from nick valente of artelia to simon lawrence claire williams and neil reed and it contains the the same text as we saw before at the top meeting objective to review

00:50:24 at the top meeting objective to review the contract documents and scope of works

00:50:26 works desired outcome clarity on what is and is not included in the contract and the implications are rising and that was the meeting that was held and it looks as if this email is the one that is one that

00:50:39 email is the one that is one that follows the meeting were you aware at the time that matters had got to the stage where it was necessary to hold a meeting with simon lawrence with the express aim that there be clarity on what is and is not included

00:50:51 clarity on what is and is not included in the contract um simon may have raised this with me and that that's exactly what i'd expect from the contracts manager to be doing had anyone expressed to you that

00:51:06 had anyone expressed to you that there was no clarity on what is and is not included in the contract

00:51:14 if simon had raised that to me that that that's what was occupying a great deal of his time doing

00:51:22 again i'd see that as a perfectly reasonable

00:51:28 situation and and him being part of the process

00:51:33 process to to clarify exactly that well forgive me mr blake but wasn't it ryden's job as design and build contractor who had responsibility for managing the

00:51:45 who had responsibility for managing the process

00:51:46 process among other things of the performance of its subcontractors wasn't it ryden's job to make sure that everyone who was involved in the project had clarity about their respective roles

00:51:58 we have our role as principal contractor to be

00:52:01 to be part of the team and the uh the employer's agent role is uh that's artelia's uh responsibility

00:52:12 that's artelia's uh responsibility so that there's a an ebb and a flow of information in that respect so you saying that this was a concern for artelia

00:52:23 was a concern for artelia but not a concern for ryden this is demonstrating to me that the contract team is is doing their job asking the questions

00:52:35 is doing their job asking the questions clarifying

00:52:38 and understanding the contract because on on these items here um there is a there's an element of uh

00:52:49 there is a there's an element of uh change that's been accommodated um that is part of the um tmo's choices

00:52:59 did he not come as a surprise to you to discover from mr lawrence that you should that anyone from writing should need to be invited to a meeting such as this with your client concerning

00:53:11 such as this with your client concerning what

00:53:11 what is and is not included in the contract over a year after ryden had been appointed

00:53:20 uh no i think that's a perfectly reasonable circumstance really

00:53:29 really do you know what led mr reed to take the step that he did and to organize this meeting

00:53:41 for the reasons that he's identified in his

00:53:44 his previous uh email can we go to art406681 please

00:53:58 this is an email that mr reed sent mr lawrence on the 10th of july 2015

00:54:06 2015 copy to the tmo

00:54:13 and i'm sorry you're being shown page one i'd like page three please of that string

00:54:19 string thank you yes that's that's the page now um

00:54:24 um it's it says simon i understand that we have moved no further forward on the below since your your team's meeting with treachen i'd like to request a meeting with you

00:54:35 i'd like to request a meeting with you your team and your director next friday morning 17th july to discuss how ryden is planning to deal with the commercial service required including the response awaited re-my email of 22nd of may we remain disappointed

00:54:46 disappointed not to have received a response from ryden and have little option other than to escalate the issue please confirm that this is possible and who will attend meeting objective to discuss the commercial status quo

00:54:57 to discuss the commercial status quo lack of responsive stroke proactive commercial service from writing and how we can remedy the issues desired outcome strategy agreed for resolving the issue with oversight from a writing director

00:55:15 now the director first of all um must have been you mr blake i imagine yes yes were you ever told of mr reed's

00:55:26 yes were you ever told of mr reed's request

00:55:27 request for this meeting um

00:55:32 i can't recall but i'm i would have hoped

00:55:37 hoped i would have done all right uh in the light of mr reed's desired outcome

00:55:45 outcome including the perceived need for oversight from from you do you accept that by this stage mr reed had come to the view that the staff or the team

00:55:55 the team presently working on the grenfell project were not performing adequately um i would say what specifically they're not um

00:56:06 what specifically they're not um performing against if it's requests for um financial information in respect of changes

00:56:16 then if if the team is occupied doing other things

00:56:25 things then that commercial [Music]

00:56:29 [Music] or that that advice um may take longer than um than than neil would um expect um that's

00:56:43 expect um that's we have a finite resource um and that's that's how it would be um allocated

00:56:57 um allocated i mean it's clear from this email that mr reed was not satisfied with ryden's performance specifically he thought there was a lack of responsiveness and proactive commercial service

00:57:08 and proactive commercial service is the is the fact that he had or was the fact that he had those opinions of ryden's performance at this stage brought to your attention um i can't recall if that was sent to me

00:57:20 um i can't recall if that was sent to me or not

00:57:22 or not well we can't see you copied in it's sent to simon lawrence and we asked the question one more time did simon lawrence raise with you the fact that mr reed had formed a view of ryden's performance

00:57:35 had formed a view of ryden's performance in that it was it was not sufficiently responsive or proactive in the way that mr rita set out there

00:57:42 out there i can't recall but i expect that i would have been

00:57:45 have been did you what did you do about it

00:57:52 well it seems that i'm being invited to a meeting but um i don't know whether that happened or not

00:57:59 not do you remember going to a meeting with mr reed and discussing the matters which were on his mind i don't recall

00:58:07 looking at this email at least do you accept that artelia at least by this time

00:58:11 time considered that there was a serious issue regarding wrighton's responsiveness on the project that required to be dealt with by someone at your seniority that uh certainly says that yes um so

00:58:24 uh certainly says that yes um so now if we move up the email chain we can see zach maynard's response he's copied in on this email but he is the one who is sent in to respond so to speak and he

00:58:36 sent in to respond so to speak and he responds

00:58:37 responds on the 13th of july

00:58:41 back to neil reed and simon lawrence

00:58:45 and this one is copied to you as you can see you're the last copy e on it so you can see it

00:58:52 when you got this email from zach maynard did you look at what it was he was responding to um i may have done i i haven't got a recall of this

00:59:03 recall of this so by the 13th of july and the time when zach maynard came to respond you must have realized that neil reed wasn't happy with ryden's service

00:59:11 service and then he wanted a meeting with you when i received this

00:59:16 um yeah yeah and you could see that zach maynard's response includes the statement at the end of the second line there that it doesn't appear that a meeting is necessary and there's very as there's

00:59:28 necessary and there's very as there's very little information outstanding was that your view um i can't recall this so i i can't confirm that did you discuss mr

00:59:39 i can't confirm that did you discuss mr maynard's response to mr reed before he sent it do you remember

00:59:43 remember i don't know would it be usual for you to do so given that you essentially had been identified as the as the person to go to a meeting

00:59:59 i um relying here on

01:00:03 zack's response um uh he's he's a seat he's a hold a senior position

01:00:14 hold a senior position and it seems that he's responded in detail to the items raised i would be always willing and available to meet me

01:00:29 any of the project team so

01:00:33 that that's a given in my role

01:00:53 can i ask you to go to art four zero six two six six two zero six please

01:01:04 this is an email i think we looked at before from simon cashton it will read on the first of october 2015. this is the one about your relationship going

01:01:14 going the relationship with peter madison going back a long way remember we looked at that yesterday afternoon mr mr blake can i ask you this time to look at the end of the fourth line down

01:01:32 where it says peter fully appreciates what we're doing and is very supportive of our approach what we did agree was that he and i would meet with steve next week to have an offline chat to review the

01:01:43 to have an offline chat to review the overall situation and try and explain that no one is threatening ryden's or trying to be aggressive but rather we're trying to guide them as to what they need to do to sort themselves out

01:01:54 need to do to sort themselves out hopefully this might make steve open up a little more than when he is in meetings where he feels under threat and is therefore less forthcoming peter reiterated that the key for him is still budget then quality and finally time there is a

01:02:07 then quality and finally time there is a huge political agenda sitting over him and what he needs us to do is to ensure that he does not get strung up as a result of reporting things that turn out not to be true

01:02:18 turn out not to be true i just want to focus on the end of the first paragraph there uh do you remember do you remember whether that meeting took place

01:02:32 um i do know that we we had a meeting um

01:02:40 so that that date is december 15 uh sorry october 15th yes i'm sorry it is it's october 15 yes it's american dating but it is october 15.

01:02:51 15. um i remember at the end of the contract um we um

01:02:59 um we um part of the conclusion of any contract is to

01:03:03 is to um uh to

01:03:06 um uh to put a final account uh proposal to the client

01:03:10 client um we also have to put in the notices to

01:03:18 regularize the contract with respect to the the time finish and we need to get paid against our um

01:03:30 we need to get paid against our um application so at that point in time which was october 15 which is

01:03:42 which was october 15 which is running up to the conclusion of the contract

01:03:46 contract um we had we hadn't had um i think there's one extension of time granted

01:03:54 granted um but there was a huge uh quite significant disparity in terms of

01:04:01 of of that award and and the the projected end of the contract so that gave us a liability we had a final account that wasn't um agreed

01:04:12 agreed um and that was putting pressure on the the cash flow of the project

01:04:22 so and the response from martellier was that you're not entitled to any of this um so that was putting us into a um

01:04:35 for one of you know it was a you know a stressed position

01:04:44 can we look at pages two and three of this

01:04:47 this uh email string and i'd like to have pages two and three put up next to each other this is the email to which the one i've just been showing you is a response

01:04:58 you is a response and it's dated the 27th of september 2015 from neil reed to simon cash so it's internal at artelia

01:05:07 artelia and it's it's subject is sit rep following visit thursday 24th september 2015 and i just want to focus on two paragraphs in it first of all paragraph two please

01:05:18 paragraph two please um where it says since the meeting the cw cows report that further and ongoing delays brackets cladding brackets mean that there is little confidence in completion being achieved

01:05:30 confidence in completion being achieved in january 2016 i believe february is looking more tenable based on the delays in september but this may worsen should significant progress not be achieved in the coming two weeks

01:05:40 two weeks the cow continued to flag quality control related problems which i'm concerned

01:05:45 concerned ryden is not closing expediently that sb and sl simply need to do better to work with the cow and resolve the quality issues being raised

01:05:57 and then just looking at page three and paragraph five please it it refers to a handover me completion a kickoff meeting on the 24th of

01:06:08 a kickoff meeting on the 24th of september

01:06:11 and it goes on in the second line and this was a little frustrating as much of what had been discussed agreed and minuted at the progress meeting was revisited and clarified a completion strategy was discussed

01:06:22 a completion strategy was discussed briefly and a further meeting will be organized with stakeholders on or around 8th october this is to allow 2-3 meetings to take place prior to completion anticipated to be achieved no earlier than january it will serve as a forum in which to

01:06:34 it will serve as a forum in which to define success agree the deliverables track and manage actions proactively and ensure the ride and provide the things it is obliged to provide under the contract ryden will be adopting what they describe as a trade approach

01:06:46 describe as a trade approach to the producing the information and will issue a tracker document ahead of the meeting to identify all the things it plans to provide artelia will issue an agenda and share the meeting and just looking at those two paragraphs out of a

01:06:59 looking at those two paragraphs out of a number in that letter were you aware at this time

01:07:01 this time late september 2015 that artelia uh thought that ryden had to sort itself out in respect of quality program costs and other matters i've just shown

01:07:12 costs and other matters i've just shown you

01:07:15 you um yeah i'm aware of all those issues yeah were you did you agree that management of ryden on this project needed to sort itself out

01:07:26 out using those words in the end at that time i i don't agree with the statement sort itself out um the uh the employer's agent need to um understand the reasons why

01:07:39 um understand the reasons why things are um that they're describing as they are

01:07:44 they are um

01:07:48 yes i'm just good i'm just i'm so sorry to continue your answer how did you finish well the question was was i aware of

01:07:59 well the question was was i aware of this

01:08:00 this the answer is yes um my uh response to it is that um that there's a lot of explanation as to

01:08:11 that there's a lot of explanation as to why things were as they are as as they were um so um and i made mention of that in my

01:08:22 um and i made mention of that in my previous office of the the positions that we needed to um achieve which would be okay the time money

01:08:36 okay the time money and also the everything that's needed to achieve pc at handover um so there's nothing in there that i i disagree with all right thank you

01:08:50 i disagree with all right thank you now i want to move the story on a bit if i may uh are we going to another topic

01:08:56 topic not well not really no no all right um i'm just thinking that we getting to that time when we might well yes

01:09:08 yes we could take a break now i'm perfectly happy too might be a good time if it's not too but it's as good as any mr chairman probably um we'll have a short break now i think

01:09:19 i think 10 minutes or so should be enough so usual rules they're talking about your evidence please okay and then we'll come back at 20 past

01:09:46 please

01:20:54 good yes can we have mr blake back please

01:21:21 right ready to carry on mr blake i am i thank you

01:21:25 thank you yes mr millet mr blake can i ask you to go to ryd3044349 please i'd like you to look at page two in that

01:21:36 i'd like you to look at page two in that and look at the middle of the page this is an email from simon lawrence dated the 22nd

01:21:41 the 22nd of june 2015 to james clifton zach maynard attaching invoices for andy hannibus

01:21:50 hannibus and his supervisory works at the tower now if we look at the top of page 2 with me

01:21:54 me mr blake you can see that mr maynard passes this to you directly to say that mr hannibas rate had been reduced but he was still on site you see that

01:22:05 but he was still on site you see that yes yeah that's the context i'd like to turn to page one and look at the middle you emailed mr lawrence there

01:22:13 to say the gift of timing this is burning a hole in our pockets can we reduce this to once a month catch up

01:22:21 up what do you mean by this is burning a hole in our pockets um this is um

01:22:31 a guy that we employed uh to to help with the uh m e store um there was a presumably an allowance made

01:22:42 there was a presumably an allowance made in the budget um that we were overspending against in what regard did mr

01:22:50 mr lawrence need to catch up

01:22:54 um well i've asked him a question can we reduce this to once a month and catch up what do you mean by catch up

01:23:03 up talk about it right oh i see you're not telling him to catch up with the project you're telling him that you want to meet him and discuss it yes i think now let's look at the top of the page

01:23:15 now let's look at the top of the page for mr lawrence's response and i want to focus on the first paragraph he says not that i disagree with the fact stewart is costing us money so probably over budget however it disappoints me that zach has sent

01:23:27 it disappoints me that zach has sent this to you without talking to me if i had actually seen any budget for grenfell in the last eight months at least

01:23:33 least then we may have been able to manage this differently did it surprise you to learn that mr lawrence had not seen any budget for grenfell in the previous eight months at least

01:23:43 least um yeah the budget is available anytime for for a contract manager if if um if they wish to look at it it's it's it's on the system and um

01:23:56 it's on the system and um he's it's available for him to see and and use

01:24:00 and use did it surprise you to learn that mr lawrence had not seen any budget for grenfell in the previous eight months

01:24:12 months um yeah um but again as i'd say it's available if he wanted to see it you just gotta ask for it did you go

01:24:23 you just gotta ask for it did you go back to

01:24:24 back to mr lawrence and say why have you not seen a budget for this project for eight months at least it's on the system explain yourself uh no i didn't why is that

01:24:36 that um because i didn't see a need to you didn't see a need to take him up on the fact

01:24:44 the fact that your contracts manager had not seen a budget

01:24:47 a budget for this project for eight months why is that

01:24:55 i didn't take that up with him no i know i'm just seeking to really understand understand why why you let that go um

01:25:07 because it's

01:25:10 it's available for him so he he doesn't need to be shown it he can find out for himself

01:25:23 we go on in the email he says at the moment we have a poorly performing site which is mainly but not totally caused by poor surveying and cheap incompetent subcontractors

01:25:35 subcontractors did you agree with mr lawrence's evaluation of ryden's subcontractors as cheap and incompetent mr blake no i mean you know i see this is a

01:25:49 no i mean you know i see this is a point in time against a frustrated man um

01:25:54 um doing his job in um

01:25:58 in the with a lot of um activities going on at the same time and yeah he's obviously uh uh

01:26:09 yeah he's obviously uh uh frustrated so he's he's venting that um with me

01:26:22 um with me does that tell us that you didn't agree with him that the subcontractors were cheap and incompetent you thought they were expensive and competent did you

01:26:34 um that that that is that's his view at a point in time i i didn't have a i didn't have a view about that you

01:26:45 i didn't have a view about that you didn't have a view about whether the subcontractors in the opinion of your contract manager were all weren't cheap and incompetent

01:26:56 and incompetent i i didn't at that that time no i wasn't on site um

01:27:09 due process is um

01:27:14 is run through in order to appoint those subcontractors which the contracts managers is part of that process if there is issues of performance

01:27:27 if there is issues of performance then part of the contract's manager's role

01:27:30 role is to

01:27:33 is to you know bring them to account and to

01:27:39 and to so that they fulfill their obligations as as

01:27:43 as as they're employed if they can't manage to do that

01:27:47 do that then they will be removed from the contract

01:27:51 contract when you received this email did you take any steps to ensure that quality was being maintained on this project um i can't recall what i would have done

01:28:04 um i can't recall what i would have done specifically did you supervise on an ongoing basis thereafter whether quality was being delivered on this project

01:28:15 this project did i do what sorry did you supervise on an ongoing basis whether the process of overseeing the quality delivered by subcontractors uh was being properly delivered

01:28:27 uh was being properly delivered i didn't um supervise on a regular basis here is your contract manager alerting you to the fact that he thought that the subcontractors were cheap and

01:28:39 subcontractors were cheap and incompetent as a result of being told that did you do anything to look for yourself to see whether there was anything in what mr lawrence was saying to you um i can't recall exactly what i did

01:28:55 so i can't um i can't make a statement in the second paragraph penultimate line he says we still have no competent manager to deal with m e issues did you

01:29:06 manager to deal with m e issues did you agree that ryden had no competent manager dealing with m e issues at this time

01:29:11 time um no because that's what the employee of um

01:29:15 of um uh stuart hannah bus was there for so not your problem is that what you're telling us it's all my problem yes so given that

01:29:26 it's all my problem yes so given that you're told by your contracts manager that you've gotten a competent manager to deal with the m e issues the first question was do you agree

01:29:36 i don't know i didn't i don't know did it not concern you of course it concerns me um that's um it's a very negative uh email of a

01:29:48 um it's a very negative uh email of a state of affairs from a contracts manager

01:29:51 manager given his concern what steps did you take to ensure that m e issues were properly managed by wright yeah and i i can't recall what i did about it

01:30:07 what i did about it all right can i ask you to look at a document tmo one zero zero eight five no sorry tmo

01:30:18 one zero zero eight five no sorry tmo zero tm00859230

01:30:24 this is first of october 2015. and it's an email from neil reed to leclaire williams responding to harry met of the 1st of october 2015 that's the context

01:30:37 october 2015 that's the context and he refers to a meeting last week's meeting

01:30:44 and in the

01:30:49 uh you can see there's a list of five points and in the point four um he says uh agree but little else we can do other than monitor situation at present and he

01:31:00 than monitor situation at present and he says this last week's meeting with hard work with steve blake progress and the follow-up on tuesday as his general approach seems to be to kick things back without taking ownership of things that clearly sit with ryden

01:31:11 clearly sit with ryden but do you agree that's a that was a fair observation or description of your attitude at this time mr blake i don't know what point four is referring to

01:31:23 point four is referring to well if we want we can look at the email to which is the response let's do that page two item four please email claire williams to neil reid first of october ryden resources i'm still not convinced that ryden have enough resource to manage the scheme to the end

01:31:35 resource to manage the scheme to the end steve blake's day or two a week does not give the existing site management team a lead

01:31:39 lead miranda's dropping i believe so i'd like to push this point with ryden too at the site meeting as well as generally so that's 0.4 that's the context i'll ask the question again

01:31:51 okay i'll ask the question again

01:31:56 and the question was

01:32:00 would you agree that the observation made of paragraph four by mr reed about your attitude was a fair one um no i don't no

01:32:13 um no i don't no are you surprised to read that artelia perceived you at the time as not taking ownership

01:32:17 ownership of things that clearly sit with ryden um i'd i'd be disappointed that's not mine

01:32:29 that's not mine [Music]

01:32:30 [Music] that's not my style do you say that mr reed's view of you was unjustified

01:32:38 to make that comment yes i would yes all right

01:32:42 right i just want to ask you a question or two about handover from mr lawrence to you as contract manager art406706 please

01:32:53 manager art406706 please this is an email from john white a clerk of works

01:32:57 of works working for john rowan and partners it's alt406706

01:33:03 alt406706 thank you and it says uh i'd give you the date it's the 5th of october 2015 mr blake to say you're clear about the dating um and the second

01:33:15 and the second line mr white tells ms williams just sent my report not good reading i'm afraid simon from ryden's needs to start handing over all the duties to his replacement asap and ryden's needs to get the cladding

01:33:26 and ryden's needs to get the cladding contractor up to their labour immediately now i know you weren't copied in on this obviously at the time my question is when mr lawrence left ryden in october 2015 was there a

01:33:38 ryden in october 2015 was there a handover

01:33:39 handover of his responsibilities to you as the incoming contract manager uh yes there was yeah was there a handover pack of documents for you to read

01:33:51 read no what did the handover entail you can tell us briefly um

01:34:00 i would

01:34:03 obviously spend an amount of time with simon

01:34:07 simon discussing the job we discussed it to during the process of our normal exchange um

01:34:19 normal exchange um as director contracts manager and then i would make myself familiar with the information

01:34:33 to administer the contract and by way of example i would start with the

01:34:41 the site meeting minutes which identifies actions for ryden today does that tell us that you didn't start by looking at all the individual contracts

01:34:54 no i wouldn't do that so contracts manager coming into the job wouldn't look at the contracts is that is that normal um the the job is

01:35:06 um the the job is in in progress so i would i'd only refer to them if there was a need for me to do that right

01:35:16 going to another document this is art406662

01:35:20 art406662 at page 2 please this is an email from tony batty he's of silcock dawson and this is an email from him to claire williams and others on the 6th of

01:35:32 williams and others on the 6th of november 2015. can i just show you that mr batty says that the properties for these are voids for inspection and he identifies them one four five one

01:35:44 he identifies them one four five one three six and one two four there and um he says in in summary that the properties have not been made ready for inspection

01:35:55 have not been made ready for inspection uh and

01:36:00 underneath where it says chris holt the site manager and i think what's happened here is that this is a a a a response to an earlier email

01:36:10 under that it says clearly we cannot continue like this when we inspect the occupied flats and something needs to be done rydens should be inspecting and signing off the flats

01:36:19 flats and then capital letters before the cows now let's turn over to page one for mr reed's response

01:36:28 uh he comes back to tony batty on the 6th of november 2015 on this subject thanks for this

01:36:40 on this subject thanks for this uh and then in the third paragraph he says claire either way this is shoddy management by ryden of our team's time and effort and i would urge you to elevate this to peter for his discussions with steve

01:36:51 to peter for his discussions with steve this demonstrates again that ryden must do better i hold a perception from their inaction here that they are apathetic to our efforts to help

01:36:59 help and need to be far more proactive in getting work complete and right first time do you do we need a high-level meeting to discuss the new elephant in the room i don't think i need to ask you about

01:37:10 i don't think i need to ask you about that my question is were the concerns that mr reed is reflecting in this email here about shoddy management of ryden

01:37:22 and apathy ever raised with you at this time the

01:37:25 time the early november 2015. this is the time when you just come in as contracts manager

01:37:31 manager um well it doesn't appear that i've seen this email um my uh

01:37:39 um my uh introduction to the contract um would be uh to focus on um the critical path um parts of the contract um

01:37:53 parts of the contract um and that didn't include um this

01:37:59 um this element of work so my focus was um to apply all my energy um into uh the first part of that of

01:38:12 into uh the first part of that of of getting items of work in place

01:38:20 and finalized in order to

01:38:25 produce the best

01:38:28 finishing um

01:38:33 point for the for the program um and this this work is not part of that um critical path um so i've

01:38:46 critical path um so i've arranged the management thus um and i could have explained that to the client

01:38:56 client but i didn't um and we certainly weren't apathetic to um any efforts for help um and that

01:39:07 um and that is that was my recall of my introduction into the into the program and

01:39:18 into the program and if my attitude towards that criticism um they may have seen that i i

01:39:30 was focusing on other on other things mr big i'm sorry to cut you off you may have misunderstood my question my question was a very short one did anybody raise the concerns i've shown you in this email

01:39:41 shown you in this email with you at the time no but there was there was um you know they were when i came into the contract um there was an awful lot of change

01:39:54 awful lot of change there was a many

01:39:58 obstacles to progress that was going on simultaneously we had client change we had access to flats um we had

01:40:10 access to flats um we had uh two contractual insolvencies so there was an

01:40:13 was an awful lot of simultaneous event so in terms of my prioritizing

01:40:24 so in terms of my prioritizing the void's work if it suffered as a consequence would be the reason why it did

01:40:38 can i ask you to look

01:40:42 i'm just going to do one more document on this i think can i ask you to look at art406672 please this is an email from mr reed to simon

01:40:53 this is an email from mr reed to simon cash among others of the 9th of may 2016 so we've jumped forward in time and i appreciate mr blake that there was an awful lot that happened between the autumn of 15 and the may of

01:41:06 between the autumn of 15 and the may of 16.

01:41:09 i just want to show you this email this is

01:41:13 an email you didn't see at the time it's internal to artelia and he says this simon the o m's are unacceptable to the cows this is to flag that this is becoming a farce despite all our efforts to ensure ensure

01:41:25 despite all our efforts to ensure ensure a smooth landing i have to say i do not think i have ever worked with a contractor operating with this level of nonchalance we're all getting sucked into doing far more than we ought at this stage of the project

01:41:36 project i'm wondering if if you need to write to the tma to express our concern and what we are endeavoring to do about it additional site visits additional meetings endless emails on design related issues that don't concern us as claire as the design lead etc

01:41:48 as claire as the design lead etc challenging the contractor etcetera i just want to focus very narrowly on the words

01:41:55 the words i don't think i've ever worked with a contractor operating with this level of nonchalance my question to you is is that a fair criticism of writing at this time um

01:42:07 at this time um i've been called many things but nonsense

01:42:11 nonsense is not a word that's been used i absolutely don't accept that did either artelia or the tmo accuse you directly of nonchalance as we see here

01:42:23 see here no they didn't i'm going to turn to a different topic altogether which is cdm regulations did you take any steps yourself to satisfy yourself that the health and

01:42:35 satisfy yourself that the health and safety file had been properly produced and handed to the tmo at the end of the project

01:42:40 project um the the way that that was arranged is that the agreement was that the information contained within the rn manuals

01:42:49 manuals would be used by the tmo um to populate the the health and safety manual

01:42:56 manual we've heard evidence from mr hughes that ryden never received the final copy of the o

01:43:00 the o m manual following handover did you know that at the time um i didn't know that at the time no can i ask you to go to met406610 please

01:43:15 this is a an email chain between steve butler of all group holdings you claire williams neil reed and others dated the 6th of june 2016 and i just want to focus on the second email on that page

01:43:26 email on that page which is to you um steve butler says i'm also producing

01:43:34 you see that i can't quite see that which bit do you want mr millett

01:43:52 which bit do you want mr millett uh let's move on to that again um i'm not sure is the answer um

01:44:00 my question i think is d did you understand whose responsibility it was to produce the health and safety file um yes whose

01:44:14 um yes whose that was the well previously lay with the

01:44:18 the um cdmc

01:44:21 um cdmc um with our obligation to provide the information

01:44:27 to be part of its compile so that that's always the case in in in any job um and then

01:44:38 in any job um and then we were approached um to say would we take over that role which we didn't um and then uh artelia and or

01:44:52 artelia and or the tmo um

01:44:56 was it was reported that they would take the responsibility uh for um for that obligation with us uh providing the information

01:45:08 with us uh providing the information to the health and safety file through the content of the rnm can i ask you to look at the document again please it's it's gone off i think from the screen but it's met

01:45:19 from the screen but it's met 3066178 and just go please to what i was looking for which i couldn't see

01:45:26 see which is the very top of page two it's it's he says i'm also producing a health and safety an hms file from the information i already have as the client

01:45:38 information i already have as the client doesn't seem to think it's their responsibility under the cdm regs it is my question is had the need for a health and safety file been discussed before this time

01:45:49 this time and this is june 2016. um yeah i think it was part of the um handover um

01:46:01 of the um handover um discussions we had a separate um set of minutes um and meetings with respect to um identifying everything uh required to

01:46:15 identifying everything uh required to uh meet handover when you say handover you mean handling sorry uh achieving practical complaints right yes my question i'm sorry i don't think you answered it

01:46:26 you answered it my question is uh had the need for a health and safety file been discussed before early june 2016. or was or was this the first time that it was no my response was i think that it was and

01:46:38 my response was i think that it was and like the medium for that discussion was at those meetings right when do you think the discussion of the completion of the health and safety files started um i can't recall exactly

01:46:51 um i can't recall exactly did you raise any concerns with artelia or the tmo about the timing of the preparation of this health and safety file as at this time early june 2016 uh no i didn't know

01:47:12 can i ask you a number of uh

01:47:20 brief questions about building control

01:47:25 uh in brief terms mr mr blake what involvement did you have in build with building control prior to your taking over the role of contracts manager in october 2015.

01:47:38 manager in october 2015. um i i don't think i had any contact with them

01:47:42 with them what about after afterwards yes now we've heard that there was no formal method for recording other than emails perhaps what drawings were sent to building control

01:47:55 in the absence of a formal tracker how did you yourself after october 2015 take steps to satisfy yourself the building control had everything they

01:48:07 the building control had everything they needed

01:48:08 needed yes i did yeah how did you go about that by uh contacting studio e right who did you contact at studio i can't recall who it was most probably neil crawford

01:48:21 who it was most probably neil crawford was there an occasion you recall when you contacted studio e and asked them that question um i remember contacting them to um

01:48:32 um i remember contacting them to um to make sure that they had submitted all the available information to building control

01:48:44 what was the occasion on which you sought that assurance that that was

01:48:52 that was me making sure that everything necessary to gain building control approval had been sent to building control via the

01:49:04 sent to building control via the architect

01:49:06 architect yes what was the occasion that that's what triggered it that's part of my job to um make sure that that's um happening do you remember when it was i

01:49:19 happening do you remember when it was i i

01:49:20 i can't recall did you do it more than once

01:49:23 once um possibly but i know that i did it um to say to them that their responsibility

01:49:34 to say to them that their responsibility is to

01:49:35 is to um submit that information to to building control did when you say they mean studio e yes did studio e ever come back to you after that and say

01:49:46 that and say we've done it and explained to you what they had done no i do remember from that meeting that um they they confirmed to me that they hadn't um

01:49:56 hadn't um sent the structural engineers drawings to them

01:49:59 to them so i got that

01:50:04 reminded of them that was their obligation to do that which i understand that they did

01:50:12 when you say you contacted studio e to tell them that their responsibility was to submit information to building control can you how did you make that contact

01:50:24 how did you make that contact uh that would have been a phone call a phone call no email no

01:50:34 was it not an important thing to record in writing that you had you had done

01:50:41 if it's important i start with a phone call

01:50:45 call why didn't you follow it up with an email because they must have satisfied me that they indeed done it right and agreed to do it okay

01:50:58 right and agreed to do it okay and

01:51:02 you that was enough for you was it i can't recall whether there was a confirmation back from studio e saying that they um submitted the details so your answer a

01:51:14 submitted the details so your answer a few lines ago was that they must have satisfied me that and they had indeed done it and agreed to do it what did they tell you that they had a good time or that they had done it i can't recall exactly what

01:51:25 had done it i can't recall exactly what was said

01:51:26 was said right

01:51:30 are you aware that there were certain inaccuracies in the information provided to building control certain gaps

01:51:44 [Applause] now

01:51:51 were you ever concerned that building control

01:51:54 control didn't have the structural drawings prior to you finding out about it

01:52:01 um yeah because uh they could come back and say

01:52:06 and say this is um uh this is not compliant and then we may have to

01:52:13 have to um make alterations so um yes i was did that not alert you uh to the fact that perhaps studio e uh were not fully okay with what

01:52:27 uh were not fully okay with what they had to provide to building control um it didn't make me think that they didn't know that they had to do it it just

01:52:38 highlighted that they hadn't done it and then

01:52:42 then from that point um i say that's my role to make sure that the

01:52:51 the building control had sufficient information to issue a compliance certificate was that not something that you thought you ought to monitor

01:53:02 you ought to monitor on a continuing basis

01:53:07 um

01:53:11 yeah yeah the monitoring is is is part of

01:53:14 of our role yeah did you ever have occasion given that the lapse you had found about the structural drawings to go back and make sure studio e had continued to provide building control with up-to-date

01:53:25 provide building control with up-to-date and accurate and complete information about drawings and materials that might that was my understanding was that was um the only item that hadn't been

01:53:36 um the only item that hadn't been provided right thereafter um i was uh i met building control um so i had a

01:53:47 um so i had a a face-to-face meeting with them did you know that the drawings that studio e provided to building control showed that the rain screen was zinc

01:53:59 showed that the rain screen was zinc i didn't know that no can you explain how

01:54:02 how that lapse occurred um the the drawings that um were um constructed would were the harley

01:54:14 um constructed would were the harley drawings

01:54:14 drawings as a specialist subcontractor so for me that's the precedent drawing um so it

01:54:24 um so it it wouldn't have concerned me um had that

01:54:28 that note on the architect's drawing being different

01:54:32 different it's obviously not ideal um but the like i say the um the drawing is is hardest

01:54:46 i just want to go back to ask one or two further questions about the health and safety file did you do any checks yourself to determine if all group holdings were competent and able to produce a compliant

01:54:57 compliant health and safety file um we'd employed them before to fulfill that function um and that's what their business is

01:55:09 um and that's what their business is um so i would think it perfectly reasonable to uh employ them to do that did you understand yourself what needed to go into a health and a health and safety file

01:55:20 file um i've got previous experience of uh o m's and and health and safety files so i i know pretty much yeah was it not

01:55:31 so i i know pretty much yeah was it not your job ryden's job to maintain or compile the health and safety file throughout the project and not just at the very end um yeah you collect information on the

01:55:43 um yeah you collect information on the way

01:55:45 way and then it's presented at the end of the contract so um to the best of your recollection was

01:55:52 was information for the health and safety file compiled as a health and safety file along the way well the drawings would be exactly that yes

01:56:01 yes what about other things in the health and safety file well most things conclude at the end so in terms of

01:56:08 terms of uh

01:56:12 electrical certs and commissioning certs uh completions all generally come at the end of the project um so i don't think that that's

01:56:23 um so i don't think that that's um an unreasonable um point in time to assemble it

01:56:33 did you check the health and safety file once it had been produced um the health and safety file was the for the client the the o m's uh were

01:56:45 for the client the the o m's uh were produced

01:56:46 produced um and i didn't um check them myself no why is that you know uh i didn't see any team who at ryden

01:56:57 see any team who at ryden was responsible for checking the health and safety file handover again we've employed someone who does that for a living so i wouldn't check

01:57:08 wouldn't check the finite detail of of what they've assembled

01:57:12 assembled um and that's presented to the client for their acceptance so um

01:57:20 that's that would be i i wouldn't see a need to do that you wouldn't see a need to do that does that mean that you would not see a need on the part of anybody at ryden to check

01:57:31 on the part of anybody at ryden to check uh that all group holdings had done a proper job before handing the health and safety file to the client um

01:57:40 i wouldn't again i wouldn't check it in finite detail so um that i would they're employed to do that on our behalf now it seems that ryden only received a draft of the o and m manual

01:57:53 received a draft of the o and m manual and never received a final version did you know that um i didn't i didn't know that no

01:58:07 um i didn't i didn't know that no can you explain why you didn't know that

01:58:15 i didn't know that because all group holdings um didn't tell me that what i do know is that

01:58:26 i made arrangements for all group holdings to

01:58:31 meet with the tmo to agree the content to agree uh the referencing um that would be um

01:58:42 um that would be um applied to the pages so that it um fitted into the the tmo system of records

01:58:49 records that that was the purpose of putting the two people together and so that everything that is required under the

01:59:01 everything that is required under the health and safety obligation was provided via uh the owner manuals that we submitted mr chairman i've got one more

01:59:13 submitted mr chairman i've got one more self-contained topic but i'm looking at the time and the topic won't take very long

01:59:17 long i i can't guarantee how long i'm afraid but uh

01:59:21 but uh i will you say not very long are we talking five or ten minutes yes well then i think we'll carry on i'm grateful thank you i want to ask you about about residents and complaints can i ask you first of all please to see

01:59:36 ryd3062813

01:59:41 this is part of an email exchange between you and claire williams on the 22nd of december 2015. and this is in the context of the

01:59:54 departure of one of your staff members or team members uh

02:00:04 and in claire williams email

02:00:11 to you

02:00:14 uh i should perhaps show you john white's email actually first of all to dave david hughes and to you below it uh and he and and john white says he's disappointed that chris is leaving he's

02:00:26 disappointed that chris is leaving he's been the one that has brought all the internal handovers together and a fundamental part of his success i do think there with nearly a hundred flats to hand over his loss will have affect the smooth running of the future handovers

02:00:37 future handovers uh and in the end oh at the end he says i feel his departure would jeopardize ryden's ability to finish the contract successfully and and then claire williams comes on to

02:00:48 and and then claire williams comes on to you on the same day and says steve i was on site this morning and picked up the news about your proposal to move chris i would like to ask you to reconsider this decision as chris has as clark of our works phrased below the trust of our

02:01:00 our works phrased below the trust of our residents

02:01:01 residents he's conscientious and personable and a good person for the resident interface

02:01:07 and then it goes on our clerk of work has reported that people welcome linda and chris by name into their flats and we need this good will to keep the project moving to a satisfactory conclusion i'm aware only through negotiation has

02:01:18 i'm aware only through negotiation has chris been able to get work undertaken where residents have been ambivalent or difficult i would not underplay this skill the grandfather project team has already been through a lot of changes and the continuity of staff plus

02:01:29 changes and the continuity of staff plus the positive attitude of both chris and dave is to me imperative to the project please ring me did you do you respond to claire williams regarding your decision to take chris off the project

02:01:41 to take chris off the project um if she'd asked me to ring i i i would have rung yeah but i i can't remember

02:01:49 remember what i would have said how important was it to structure your to structure your team in a way which gave residents trust and confidence in writing

02:02:00 it's yeah of course it's it's good to see a positive email um so that that's

02:02:11 so that that's that's part of the job in occupied environments did you consider or take steps to bring another resident liaison officer

02:02:21 officer or member of onto site to familiarize themselves with the residents and their various concerns and vulnerabilities

02:02:29 bring another one in yes um linda was there for the duration yes you decided to take chris

02:02:40 duration yes you decided to take chris off the project did you consider taking any steps to replace it with someone with equivalent skills um they all have that

02:02:52 skill set to

02:02:55 to work in in that environment can i ask you to look at another document ryd3090775 please this is an email you sent to john

02:03:06 please this is an email you sent to john heggs at js wright on the 22 24th of february 2016. and uh it

02:03:17 and uh it says a number of things in it and then it said had a residence meeting last night

02:03:21 night so pain is to be shared can you just explain what do you mean by the pain caused by the residents meeting

02:03:32 um

02:03:35 the uh the note that the basically the hi is a there's a trap on the on this let's call it a boiler um and on a windy day

02:03:49 um and on a windy day it basically vibrates um so um that has to be um that had to be remedied so that was

02:04:00 um that had to be remedied so that was uh feedback from the residents meeting so

02:04:04 so you uh the plumbers um need to uh come up with a solution did they

02:04:12 they yes they did yeah with the residents happy yes

02:04:16 happy yes how many of these residence meetings did you personally attend i didn't go to many residents meetings and

02:04:23 and i i would always be available if if requested

02:04:27 requested the the invite came from the tmo

02:04:32 that's that's part of my role to attend residence meetings and i would expect to do that can i ask you to look at rbk three zeros

02:04:44 two seven three zero nine

02:04:48 and this is a set of artelia minutes from the meeting on the 1st of april 2014

02:04:54 2014 we could just see there it's the same minute we looked at before it's the it's the first of april uh contract induction meeting or introduction meeting we know you were

02:05:05 introduction meeting we know you were there from that because we looked at it earlier

02:05:08 earlier can i ask you please to go to paragraph 6.1

02:05:17 which you'll find on page four and under the heading resident liaison it says it was agreed that cs can begin resident profiling

02:05:29 cs can begin resident profiling uh and cs i think is christina stefanu is that right yep and cs is in the column um what was christina

02:05:40 christina stefanu's role on this project um she was helping uh uh linda i see

02:05:51 uh linda i see and you can see that she was given this task of profiling the residence of grenfell what did profiling the residence entail do you remember um i i

02:06:04 um i i i'm not actually familiar with that word profiling but i would imagine that means um basically getting a contact uh uh a number for them

02:06:18 uh uh a number for them what was the purpose of that process do you remember um that's so that um access can be arranged

02:06:25 arranged as and when um work and and survey etc um to arrange access into a

02:06:34 into a uh into their home do you remember whether it involved looking at individual mobility difficulties whether people

02:06:46 mobility difficulties whether people partial were partially sighted any health issues or anything of that nature

02:06:51 nature on an individual by individual basis um not uh not not specifically um as as part of the um

02:07:02 as as part of the um that there'd be an introduction meeting to

02:07:06 to um should the resident want it um to describe the works that are planned to be carried out um if

02:07:17 planned to be carried out um if the resident had any um concerns or if there was any reasons why work couldn't be carried out then uh the you know the

02:07:30 then uh the you know the the resident liaison officer would bring that back to the tmo and there would be a accommodation made of uh

02:07:42 accommodation made of uh the the individual's um uh needs and um that that's how i would um describe that

02:07:54 how i would um describe that right thank you mr blake uh for the time being i've come to the end of my questions um i'm going to ask the chairman for a break now but it may be necessary to come back and

02:08:05 but it may be necessary to come back and for you to come back and ask answer some further questions i just need to check my notes

02:08:09 my notes thank you well mr blake we normally have a short break at this stage even though council think they've asked all the questions a bit of a review sometimes displays that they haven't so we'll break now until 20 past four will

02:08:22 we'll break now until 20 past four will that give you long enough yes that should be enough but if not you can let me know yes thank you um so if you could be ready to come back at 20 past four um we'll resume then and you can go to the usher now if you would please thank

02:08:34 the usher now if you would please thank you

02:08:51 again say 20 past if you need more time just let me know i'm grateful mr chairman thank you

02:31:22 yes would you ask us to blake to come back please

02:31:40 um

02:31:54 mr blake i'm sorry we kept you waiting longer than i suggested i think maybe there's there were more things to sort out than i'd originally thought um but we're ready to go on if you are um

02:32:04 um yes mr chairman you have some more questions i do have some more questions i

02:32:08 i i have prepared to ask i'm also still i am

02:32:11 am told uh by one set of core participants waiting for further questions i'm not sure whether they're follow-up questions or not and i should wait to see them but let me see how i get on i don't have very many

02:32:22 how i get on i don't have very many questions to ask i want to ask you about an email at

02:32:30 h-a-r-3-17538 please

02:32:36 and this is an email from emma kelly at ryden

02:32:42 sent to david hughes sorry sent to the baileys actually but copy to david hughes urgent update grenfell tower windows and emma kelly who's a maintenance

02:32:53 and emma kelly who's a maintenance coordinator as you'll probably know this is uh january 2017 so this is after practical completion by quite a few months says it has been noted that there is a

02:33:05 says it has been noted that there is a large number of defects relating to windows open on our system some of which have been open as long as august this is not acceptable and we are not receiving any response from our chaser email stroke calls

02:33:16 chaser email stroke calls we must ensure that defects are closed out within the target rectification time provided

02:33:21 provided please ensure we're provided with a thorough update by close of play today failure to do this uh will result in the issue being escalated and then there's a list of different flats in grenfell tower

02:33:34 flats in grenfell tower uh do you see that and and some other uh and some descriptions of the outstanding defects my question is were you aware at this

02:33:45 my question is were you aware at this time january 2017 of the poor quality of the windows as expressed by miss kelly in this email

02:33:53 um if she'd sent that to me then um i would be aware um well you're not copied in on the email as i think i pointed out to you yeah in general terms

02:34:06 pointed out to you yeah in general terms were you aware of the poor quality of the windows the subject of this message i'm not um it doesn't appear that i'm i was aware of that

02:34:17 was aware of that um list of defects uh well it doesn't appear from this email i i quite accept that mr blake my question was

02:34:26 was other than this email did you have an awareness from another source that so many of uh of these flats had defects relating to windows which were still open and unresolved

02:34:38 still open and unresolved and had been unresolved since august um well many cases i don't recall right

02:34:46 at the time were you generally concerned about the quality of the installation of the windows

02:34:54 um no

02:34:57 had you had similar experiences on other refurbishments such as that which is identified here in this message when i say you i mean right and generally

02:35:07 generally um it's not unusual for uh window defects

02:35:14 defects to come through on the on the reports

02:35:20 it would be helpful to see what the descriptions are on the report itself but if you if you do have tilt and turn windows

02:35:32 if you do have tilt and turn windows sometimes you can get issues with them not being operated correctly all the mechanisms themselves

02:35:43 sticking or

02:35:46 such so over a period of time you would it wouldn't be unusual for an amount of

02:35:59 defects like those to be reported through the through the defects liability period

02:36:10 i want to ask you about the uh o m manual

02:36:13 manual and the and the h s health and safety file

02:36:17 file uh

02:36:21 can you please be shown a rt406185

02:36:27 now these are the notes of progress meeting number 17 mr blake which which took place on the 17th of november 2015 and we can see that mr madison mr gibson

02:36:39 and we can see that mr madison mr gibson and ms williams were there as were you from ryden and a long list of other people from ryden

02:36:46 ryden do you remember that meeting um not specifically no no can i ask you to turn please to the bottom of page two of this minute and look at item 2.8 and

02:36:57 of this minute and look at item 2.8 and it goes over to the top of page three and it says item 3.2 cdm regulations 2015

02:37:05 2015 am noted the pmn on previous minutes that's a pmn is a post-meeting note i think isn't it um i would i would agree with that yes

02:37:18 um i would i would agree with that yes copied here for completeness pmn under the 2015 regulations if the pd appointment finishes before the end of the works

02:37:25 the works then the principal contractor takes on the pd role this means the principal contractor puts together the h and s file for the client for discussion at the next

02:37:36 the next progress meeting now pd stands for principal designer

02:37:45 did you understand that that was what was meant yes i do yes um do you accept that this was the arrangement identified here that was agreed with the tmo to prepare the health and safety file and then present it completed to the tmo

02:37:58 and then present it completed to the tmo and not simply to provide the o m manuals

02:38:04 no the the agreement um is that the o m manuals would contain the information necessary to be put into the health and safety file for the tmo

02:38:18 for the tmo having inherited the the role of principal designer well let's just look on it was agreed says the note that ryden are not the pd

02:38:29 are not the pd principal designer under the cdm regulations 2015 the tmo as the client had to undertake this role it was further agreed that ryden would be responsible for collating

02:38:40 ryden would be responsible for collating and presenting the h and s file in accordance with the employer's requirements and the pci and present to the p to the tmo

02:38:49 tmo as pd do you accept that that was the arrangement that was agreed with the tmo and i've shown it all to you which is that ryden was to prepare the health and safety file in his east side and present it to the

02:39:01 in his east side and present it to the tmo to

02:39:02 tmo to present the information required for it well it doesn't say that it says presenting the health and safety file

02:39:09 file information in accordance with the employer's requirements if you go back to the bottom of page two we can see it all in its context

02:39:21 um well my understanding is by doing exactly what i described fulfills that responsibility i see so just to be clear when we see

02:39:33 i see so just to be clear when we see the words ryden would be responsible for collating and presenting the ancient s file information exactly in accordance with the employer's requirements it was your understanding that you wouldn't be compiling and

02:39:45 that you wouldn't be compiling and presenting the complete file but only the information to go into it exactly that i see

02:39:58 who was then responsible for completion of the health and safety file if not ryden that's the client has taken that responsibility from the

02:40:10 taken that responsibility from the change of the cdn regulations prior to that it was um artelier's wrong were all group holdings instructed by ryden

02:40:19 ryden to complete the health and safety file itself and complete and provide a complete version to you for passing on to the tmo or only to compile the information to go

02:40:31 or only to compile the information to go into it

02:40:32 into it which is the distinction i think you're drawing based on this document um the um the the brief is to collect the information um

02:40:46 collect the information um for the o m and um

02:40:52 part of the reason for the um putting the two people together the tmo and the compiler um was to agree the exact brief

02:41:02 brief and format of how that information would be

02:41:14 presented mr blake i've got one final question for you and it's a question i i ask some witnesses who come to the inquiry

02:41:23 inquiry we've been through an awful lot of evidence over the last two days and i'm grateful to you for helping me with it looking back on all that evidence and looking back on your involvement in the

02:41:34 looking back on your involvement in the project as a whole is there anything that you would have done differently

02:41:42 um hindsight is a gift that um none of us have

02:41:48 have um i uh

02:41:53 um i uh in the examination it's it's very clear that at a point in time when i believed

02:42:05 at a point in time when i believed the presentation and acceptance of um the the windows and the the cladding designs um

02:42:16 the cladding designs um had been accepted um to the satisfaction of the through the design process and and the submission and the exchange of building

02:42:27 submission and the exchange of building control

02:42:30 i believe this to be um correct and it's it haunts me

02:42:41 it's it haunts me um that it was never um that it wasn't challenged because it was

02:42:48 was um believed to be correct thank you mr blake miss blake i've got no further questions mr chairman no further questions thank you very much mr william well mr

02:43:00 thank you very much mr william well mr blake thank you very much for coming to give your evidence it's been immensely helpful to us to hear what you have to say i'm sorry it's gone on probably longer than you would have wished and longer this afternoon than we

02:43:11 this afternoon than we probably gave you to understand but we are very grateful and uh you're now free to go thank you very much

02:43:31 thank you mr minute uh that's it for the afternoon mr chairman it is and miss grange will take uh two further ride and witnesses tomorrow yes well thank you very much we'll rise down and sit at ten o'clock

02:43:42 we'll rise down and sit at ten o'clock tomorrow thank you thank you

02:44:14 you

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