Testimony from Siderise (cavity barrier manufacturer) on testing standards TGD 19, limitations of BS 8414 tests, and performance of open state cavity barriers in rain screen systems.
00:00:10 welcome back everyone we are now ready to continue taking evidence from mr mort so i'm going to just check that mr morty is there and he's able to see me and really hear me
00:00:22 able to see me and really hear me clearly you're there mr maude yes i am good oh hello welcome back thank you very much you're ready to carry on yes i am right in that case i'll invite ms grange
00:00:33 right in that case i'll invite ms grange to put some more questions to you and when you're ready miss grange yes thank you mr chairman yes good afternoon mr mort um just carrying on now with the the subject
00:00:44 carrying on now with the the subject of testing and and whether or not there was other testing being done by siderise at this time can we just look at this point at mr barnaby carrick's witness statement this is sil 50295 on page two
00:00:59 sil 50295 on page two and i want to look at paragraph 5c in his witness statement now um mr barnaby carrick he was a technical applications engineer for siderise
00:01:11 applications engineer for siderise at the time of the grenfell refurbishment is that right yes and we can see uh in paragraph five here of his witness statement he's explaining what his
00:01:23 statement he's explaining what his duties and responsibilities were and at subparagraph c he says to attend test houses for product testing from august 2012 to january 2016 i attended approximately four product
00:01:35 i attended approximately four product tests alongside mr mort um now in terms of the siderise cavity barriers that were used on grenfell tower we can only identify
00:01:47 tower we can only identify um the tests that we've looked at already today in that period i two tests one in july 2013 and one in april 2014. um
00:01:58 in april 2014. um can you help us as to what the four tests
00:02:02 tests were that well he says approximately four tests that he attended alongside you in that period can you help us as to what he might be referring to they would have been other uh furnace
00:02:13 they would have been other uh furnace tests
00:02:13 tests for other product lines i couldn't specifically say what tests but they would have been tests to en 1366 part four right
00:02:24 en 1366 part four right that's the linear joint sealed test yes i see so there would have been other siderise products likely to be horizontal or vertical vertical cavity barriers or could they
00:02:36 vertical cavity barriers or could they have been fire stops there could be fire stops there could have been cavity barriers um we continually test products yeah i see um i now want to turn to the
00:02:47 yeah i see um i now want to turn to the tgd 19 standard itself this is at sil401540
00:02:57 and we can see from this first page that this is the july 2014 version so that's the first version that was developed is that correct yes and it's its title is fire resistance
00:03:10 and it's its title is fire resistance test for open state cavity barriers used in the external envelope or fabric of buildings
00:03:16 buildings and if we can go to page three of this document
00:03:22 i want to look at the first two paragraphs in the forward at the top
00:03:29 so if we could zoom in on that thank you so it says here this test method has been drafted by a subgroup of asfp task group 3 firestopping which in turn
00:03:40 task group 3 firestopping which in turn reports to the asfp technical committee it has been drafted in response to a need identified by the membership of tg3 for a test method to evaluate the fire
00:03:51 for a test method to evaluate the fire resistance of open state cavity barriers such as those used in rain screen cladding systems the method is also intended to assist certification bodies to develop technical schedules allowing
00:04:04 to develop technical schedules allowing for the third party product certification of open state cavity barriers so that's what it says there and then in this second paragraph it goes on this test method is only intended to
00:04:15 this test method is only intended to evaluate the fire resistance performance of the open state cavity barrier against fire exposure from below in terms of the time from ignition necessary to effectively seal the cavity
00:04:28 necessary to effectively seal the cavity and to maintain that seal to evaluate the performance of open state cavity barriers within a complete cladding system a large-scale test such as bs 8414
00:04:39 a large-scale test such as bs 8414 fire performance of external cladding systems should be considered and then it also says that a european standard for cavity barriers is also being developed including open state
00:04:51 being developed including open state barriers we see that there yes and we've discussed this before haven't we but and although we've got reference there to the bs 8414 test it's right that in that test the
00:05:04 test it's right that in that test the performance of the cavity barriers is not specifically measured is it that's correct yeah that's a large-scale reaction to fire test and what it measures is in terms of the
00:05:15 and what it measures is in terms of the extent of flame spread across the facade and that's not the same as what's measured in the smaller scale fire resistance test is it that's correct
00:05:27 can you just explain to us you were involved in the committee who drafted this tgg 19 standard yes yes can you just explain that the the
00:05:38 yes can you just explain that the the reason
00:05:39 reason why it's stated there that to evaluate the performance of open state cavity barriers within a complete cladding system a large-scale test such as 8414 should be considered well
00:05:52 such as 8414 should be considered well um as discussed uh earlier you can prove the performance of a character barrier on a furnace test but that furnace test does not uh prove the overall
00:06:04 does not uh prove the overall performance of the complete uh building envelope system
00:06:10 system and the only way to prove the complete built-in envelope system is to carry out an 8414 test of many different components from many different manufacturers
00:06:21 different manufacturers yes but but can we agree that even if you pass a successful 8414 test that doesn't necessarily tell you everything you need to know about the performance of the cavity barriers for
00:06:32 performance of the cavity barriers for example in terms of how they contain uh smoke spread or radiant heat behind the scenes the performance criteria you're looking at their
00:06:42 at their integrity and insulation criteria are set from the fire resistance test the cavity barrier in an eight four one four test
00:06:50 four test is needed in order for the test to function
00:06:54 function if you don't have cavity barriers then the test would fail within the first two to three minutes through hidden flame spread within the cavity
00:07:03 cavity yes i followed that but i think what i'm putting to you is that even if you've had a successful 8414 test that doesn't necessarily tell you everything you need to know about the performance of the cavity
00:07:13 cavity barrier does it no that's correct yeah now if we look back at tgd 19 itself um and as we've already explored the usual way of testing in accordance with
00:07:25 usual way of testing in accordance with that standard is to undertake the test between two concrete elements and we can see that if we look at pages this is set out in pages six to eleven but i want to look for example at
00:07:37 eleven but i want to look for example at page six of this test standard we can see at the top here is a cross-section of a block and there we can see that that's a test
00:07:50 and there we can see that that's a test for the barrier simply between non-combustible cladding isn't it or well it's actually between concrete blocks yes yes and
00:08:01 blocks yes yes and you mentioned earlier that one of the things tgd 19 does is also allow you to test with insulation either side of the cavity barrier let's look at page 10 at the bottom of the page
00:08:15 there we've got for example uninterrupted insulation yes yes and i believe that there's also diagrams i think somewhere else of interrupted
00:08:26 think somewhere else of interrupted insulation yes in the text yes yes now um we've been through the tests that cider eyes carried out they were all carried out between two
00:08:38 they were all carried out between two concrete blocks weren't they they didn't incorporate other materials such as timber as you referred to earlier
00:08:49 and just to be absolutely clear that build up
00:08:52 build up is not representative of the products being used in a rain screen application is it it's purely to test the performance of the product yeah and tgd 19 made expressly clear
00:09:04 yeah and tgd 19 made expressly clear that
00:09:04 that it couldn't be used to assess the performance of a whole cladding system could it that's correct and can we agree that if horizontal open state cavity barriers are used with
00:09:16 state cavity barriers are used with acm rain screen cladding panels the acm panels may distort due to heat and thus compromise the effectiveness of the cavity barriers there is potential for that yes just to
00:09:29 there is potential for that yes just to illustrate that point i just want to look at some um extracts from dr lane's phase one report again if we can go to blas 5010 at page 20
00:09:41 5010 at page 20 and i look i want to look at figure 10.19 at the bottom of page 20.
00:09:56 so um you can see that at the top this is paragraph 10.3.39 horizontal and vertical
00:10:03 vertical barriers and dr lane is explaining that rain screen cladding panels can distort when heated either through the heating of the panel itself or by failure of the supporting fixtures and this can allow further gaps between
00:10:15 and this can allow further gaps between the cavity barriers in the rain screen cladding panels to form and she's illustrated that in figure 10.19 below do you see that yes
00:10:26 below do you see that yes and you can see in the in the labels she's then got next to that diagram in the photograph she's giving an example of this mechanism of failure the rain screen cladding panel
00:10:37 cladding panel distorts due to exposure to heat or failure of the fixings there's then a route around the intermediate layer becomes available even if the intumescent has expanded
00:10:48 even if the intumescent has expanded and then distortion of the panels with the pe core outwards due to exposure to heat and flames yes yes now in general terms
00:10:59 yes yes now in general terms was that risk of the way in which um these cavity barriers might behave in combination with rain screen cladding panels did cider eyes appreciate that risk
00:11:10 risk prior to the grenfell project yes totally and we have openly in open forum requested that cloudy manufacturers assist us with cloud intestine
00:11:22 cloud intestine i see and when you say assistance with cladding testing what kind of cladding testing do you mean there eight four one four right and prior to the grenfell tower project to what extent had siderez done
00:11:34 to what extent had siderez done any testing which assessed the extent to which the open state cavity barriers could perform with metal composite rain screen panels sideways would not have undertaken
00:11:47 sideways would not have undertaken 841 for testing in its own entity however there have been a number of 8414 tests carried out
00:11:54 out with our materials um in there where we just supplied the materials we had no uh financial involvement in the test but were any of those eight
00:12:05 in the test but were any of those eight four one four tests where the siderise materials were used or any of those with metal composite rain screen panels i believe there's one with
00:12:17 i believe there's one with fr a2 acm in 2016 that was carried out in dubai
00:12:22 in dubai right but prior to say prior to the supply on grenfell tower so that's 2015 yes yes there had been no
00:12:33 yes there had been no testing done by sideriser or anyone else using a ciderised product that you were aware of showing the extent to which the cavity barriers could perform with metal
00:12:45 barriers could perform with metal composite rain screen panels that's correct
00:12:49 correct yeah now going back to tgd 19 if we can look at page 14 of that standard sil 401540 page 14.
00:13:05 at the bottom of the page we get the performance criteria in section 11. and we can see it says 11.1 effective closure of the open state cavity barrier
00:13:17 closure of the open state cavity barrier the time taken for the cavity barrier to close
00:13:19 close as defined in clause 10 4 shall be measured and recorded cavity barriers must close within five minutes from the start of the test as determined above or they will have been deemed
00:13:29 deemed to have failed the test and then if we can go over the page
00:13:40 we can see under installation it says um transmission of heat through the test construction shall not raise any more of the thermocouple temperatures of the unexposed surface of the test specimen more than 180
00:13:53 specimen more than 180 k above its initial temperature however any failure before five minutes shall be disregarded
00:14:01 and then if we go down to integrity 11.3 integrity shall be determined in accordance with en 13631 except that any failure before five minutes shall be disregarded
00:14:13 minutes shall be disregarded unless any area of any surfaces exhibits sustained flaming above the seal within that period so um is it right that effectively this test
00:14:26 is it right that effectively this test standard
00:14:27 standard permits there to be a disregarding of the first five minutes of the results of the test
00:14:35 yes and you will see that the integrity it's not
00:14:38 it's not uncommon um it's also within another standard can you explain how and why that was
00:14:49 can you explain how and why that was determined to be appropriate
00:14:53 it's as i just discussed earlier on today
00:14:56 today there are other elements of construction that are tested in a similar way and there has to be given time for them to either mechanically or
00:15:08 them to either mechanically or intumescent wise react to the temperature being exposed as in the
00:15:13 as in the uh damper standard there within the first five minutes and actually says there but exhibit stained flaming above the seal
00:15:24 exhibit stained flaming above the seal this is why you if you test with combustible insulation above
00:15:28 above um if there was any shortcomings that insulation would ignite yes and fail the test immediately right i see
00:15:36 i see um but where did the five minutes come from what was the scientific basis for choosing that five minute period as i said it's in there from the um
00:15:47 as i said it's in there from the um standard for dampers there's a clause in there
00:15:52 there for the first five minutes i see so what in a different british standard dealing with dampers there's a similar clause in there relating to the first five minutes being
00:16:03 relating to the first five minutes being disregarded yes yes can you help us with which particular british standard that is it would on that page
00:16:11 if we go back to it sorry
00:16:15 just go back to that page and all these five minutes are for the laboratory to be able to establish a controller you're talking about the damper standard in en 1366 part two yes yes i see
00:16:32 we've seen from some of the tests that some of the barriers not all closed within around one minute why disallow five minutes in those circumstances
00:16:46 they reacted faster than the five-minute period they the time the temperature rise on the actual cavity barrier the thermocouples are affixed to the actual
00:16:57 thermocouples are affixed to the actual cavity barrier itself are recorded from time zero the thermocouples attached to the insulation above the cavity barrier or recorded to a time zero
00:17:09 yes i appreciate that but it's very clear here that any failure before five minutes shall be disregarded yes you would not get any failure on fixed thermocouples within the first
00:17:21 on fixed thermocouples within the first five minutes if you had failure of fixed thermocouples within the first five minutes then you seriously have something wrong with the product that's installed right this is purely related
00:17:32 is purely related to the suspended thermocouples directly above
00:17:35 above the open cavity that exposed to direct heating from the furnace during the closing phase right i see so it does not um discount the thermocouples
00:17:48 um discount the thermocouples that are on the cavity barriers themselves because they are recorded from time zero as in all tests but you said earlier that that five minute approach is included in the
00:17:59 approach is included in the fire resisting damper standard did somebody do an analysis as to whether or not that was a comparable situation to these and therefore could be read across it
00:18:11 and therefore could be read across it was done by consensus of committee i see and then can we go to page 16 of this we can see there's a heading direct
00:18:23 we can see there's a heading direct field of application of the test results and then and it says underneath general 13.1 the results of the fire test are directly applicable to similar
00:18:34 test are directly applicable to similar constructions where one or more of the changes listed below are made and then we can see what the changes are that make the test results directly
00:18:46 are that make the test results directly applicable increasing the length of the cavity barrier decreasing the distance of fixing centers boys sides can be interpolated between minimum and maximum voids tested if a single void size is tested the
00:18:58 if a single void size is tested the result is only applicable to that void size again we see that yes and then a decrease in the gap between the seal and any external cladding subject to any minimum requirements for ventilation purposes
00:19:10 requirements for ventilation purposes um so that's explaining in what way the tests are directly applicable to similar constructions and then if we could go to page 17
00:19:21 and then if we could go to page 17 we get an annex a on page 17
00:19:26 there's some what's called informative commentary at the back of this part of tgd19 and it says below is some information taken from various third party publications provided for information
00:19:39 publications provided for information only and we can see if you look in the third paragraph down an extract has been provided from br135 second edition which reads in practice it's been found that small-scale tests
00:19:51 it's been found that small-scale tests do not reflect the fire hazard associated with full-scale cladding systems
00:19:56 systems and the only effective method of assessing the fire performance of the fire barriers is to test a complete system
00:20:02 system at large scale now um did cider eyes appreciate the importance of that guidance prior to the grenfell tower project
00:20:11 project yes and openly in public forum and requested
00:20:16 requested that the cladding industry engage with ourselves to test nobody came forward
00:20:26 right so you're saying openly and in public forum we requested that the cladding industry engage with ourselves to test but nobody came forward so in what public forums did you request
00:20:37 in what public forums did you request that people came forward and test with you
00:20:39 you we held some conferences on facades and our systems and our sleeves wales openly
00:20:51 and our sleeves wales openly to audience including cwct arab facade contractors openly requested that people engage for testing
00:21:06 when you say that openly request that people engage for testing are you saying he was openly asking for partners in large-scale testing so that the performance of these cavity
00:21:18 so that the performance of these cavity barriers could be better understood
00:21:23 the performance of the complete systems be better understood as we established earlier 8414 does not ratify the performance of
00:21:34 8414 does not ratify the performance of county barriers however it does ratify the performance of the whole system yes i see so he you say mr swales was making an open
00:21:46 you say mr swales was making an open request for assistance with testing that would help these systems to be better understood yes yes
00:21:53 yes yes in those circumstances where there was the clear
00:21:57 the clear identification of a need for further testing um
00:22:05 why did side arise and will come to your marketing material later feel it was appropriate to be marketing these open state cavity barriers in rain screen systems
00:22:16 screen systems if i go back to the failure criteria of an 8414 test at a maximum temperature 600 degrees at level two
00:22:23 level two and the cavity barriers are exposed to temperatures in excess of that for the duration of the test then the cavity barriers would never be the weak link in an 8414
00:22:35 would never be the weak link in an 8414 test
00:22:37 test because the temperatures that they're exposed to are not all the same magnitude as they're exposed to in a furnace test that may well be right the cavity barriers might not be the weak link but if the system may well be weak and
00:22:50 but if the system may well be weak and the cavity barriers can't perform properly
00:22:54 properly again i'd ask my question again in circumstances where the need for further testing of those systems was identified why did cider eyes feel it was appropriate to be marketing these open state cavity barriers in rain screen
00:23:05 state cavity barriers in rain screen systems
00:23:07 systems they had been tested on a few occasions in braintree systems and again i would say we openly requested
00:23:14 requested from industry to partner with us and tested nobody came forward we we are not experts in building brain screens
00:23:22 screens you need the expert partners in other parts of the industry to come forward to the table to assist right okay well this is a theme we will
00:23:33 right okay well this is a theme we will keep coming back to let's move on for now let's look at technical note 73 produced by the cwct the center for window and cladding technology that's at
00:23:44 technology that's at cwct 5019. just before that standard comes up were you aware of the cwct
00:23:55 you aware of the cwct in 2014 2015 or thereabouts yes was siderise a member of the cwct at that time
00:24:03 that time yes and were you aware that the cwct produced
00:24:07 produced notes such as technical note 73 to assist the industry yes and were you aware of this note technical note 73 we can see it's dated march 2011
00:24:18 73 we can see it's dated march 2011 in the bottom right hand corner where you're aware of this technical note when it was first published yes and if we can go on it so we know we can see it's
00:24:29 see it's fire performance of curtain walls and rain screens if we can look at page five and i want to look at the last paragraph of
00:24:39 of that left hand column and over to the top of the right hand column so picking up right at the bottom of that screen it says cavity berries may be tested following the principles of bs 47620 or bsen
00:24:52 of bs 47620 or bsen 13666 part 4. tests are generally conducted with the barrier in a cavity between walls of fire resisting construction and performance with
00:25:04 construction and performance with rain screen panels may be different now were you aware of that that particular piece of guidance by the cwct from 2011 onwards
00:25:28 from 2011 onwards mr moore are you there can you hear me sorry
00:25:32 sorry were you aware of that particular part of this cwct guidance yes it makes clear that they're tested between walls of fire resisting construction but performance with rain screen panels may be different
00:25:44 screen panels may be different yes it was
00:25:47 and that's making a similar point to the one we saw in the tg in the technical guidance tg19 ttd 19 isn't it
00:25:57 isn't it yes it is and then if we carry on with what it says in that top right hand paragraph in the next sentence just picking it up there it says intumescent materials react at
00:26:09 says intumescent materials react at approximately 150 degrees centigrade thus
00:26:12 thus allowing passage of cool smoke when the temperature does rise they may take a significant time to form a seal
00:26:20 a seal this time delay may not be significant in a test where the cavity is empty but may be significant in practice if there is combustible insulation in the cavity
00:26:29 cavity which could be ignited in the time taken to seal the cavity and again were you aware of that guidance
00:26:37 guidance at the time you were developing the testing of the slider eyes open state cavity barriers yes as we established this morning we we test with combustible insulation above
00:26:48 test with combustible insulation above and below
00:26:49 and below the character value for that actual reason
00:26:53 reason and can we agree therefore that these considerations are used in a rain screen and with combustible insulation could dramatically impact the performance of open state cavity
00:27:04 performance of open state cavity barriers
00:27:06 barriers the all cavity barriers need two resilient surfaces in order to perform
00:27:13 perform the cavity barrier is not the weak link in any green screen system the weak link is the rain screen itself yes can i just ask that question again
00:27:25 yes can i just ask that question again can we agree therefore that these considerations are the use in a range screen and with combustible insulation those two factors could dramatically impact on the performance of open state cavity barriers
00:27:37 cavity barriers if tested to an 8414 test yes
00:27:42 well and also whether attested to an april 1 4 or not in a real-world situation the rain screen
00:27:50 screen and the presence of combustible insulation could dramatically impact on the performance of open state cavity barriers in a real world situation yes
00:28:01 the i will reiterate the cavity barriers were still performed to the level of performance tested providing the bounding structures remain in place so therefore
00:28:12 therefore yes if one of the boundary structures fails then the cavity barrier is redundant
00:28:18 redundant yes if there's no external surface there to
00:28:21 to for it to butt up against it's ineffective yes yes and that is the same for all pacifier protection the bounding structures have to remain in place
00:28:35 yes um and then if we look back at that paragraph
00:28:39 paragraph um we can see in the last sentence it's referring it says the association for specialist fire protection asfp is currently investigating the development of a test procedure
00:28:50 development of a test procedure specifically for rain screen cavity barriers which will assess these issues was that referring to the tgd 19 test that was subsequently developed developed yeah yes it was and the cwct
00:29:01 developed yeah yes it was and the cwct were present at the drafting of the document as well yeah can you just help us um so far as you were aware were there ever any discussions with um the department for communities and
00:29:12 um the department for communities and local government or you know mhclg as it now is about adding tgd 19 to approve document b are you
00:29:21 you aware that as to whether there can be such discussions i'm not aware of any discussions no okay
00:29:29 i'm going to ask you some questions at this point now about celetex's bs 8414 part
00:29:35 part 2 tests that were carried out in 2014 if we could look at mr swales's witness statement first on this point that's at sil 50306 page 17
00:29:47 that's at sil 50306 page 17 and i want to look at paragraph 63
00:30:00 so he says there up to the date of the refurbishment and and he's referring now to the grenfell refurbishment siderise had actively participated in six
00:30:10 six bs 8414 part one part two system tests in the uk and the uae when i state actively i mean that cider
00:30:21 when i state actively i mean that cider eyes were invited to participate by the test owners such as celetex extratherm and kingspan these occurred between
00:30:29 between 2012 and may 2015. the cladding utilized for these tests were either rain screen boards or terracotta tiles the insulation was either pir phenolic
00:30:40 the insulation was either pir phenolic or stone wool insulation and then he says all of the tests were passes
00:30:46 passes other system tests may have been carried out using the siderise product without our knowledge which is not unusual now just on that um he says there that there were these
00:30:57 um he says there that there were these six eight for one before tests and all of the tests were passes and we'll come on to it in a moment it's right though isn't it that the first celetex
00:31:05 celetex test that cider eyes had its cavity barriers in was a fail in february 14 yes
00:31:12 yes yes it failed through uh panel failure i believe yes so that's not quite correct is it that all of those tests were passes
00:31:25 that's correct
00:31:30 now and mr suarel says on the previous page if we look at page 16 at paragraph 61 first sentence um and this is just for the points of
00:31:41 um and this is just for the points of doubt really but he says to my knowledge a system test incorporating acm panels did not take place before 2016. do you see that yes and i think that accords with the
00:31:52 and i think that accords with the evidence you just gave to us but can you just confirm that yes it does
00:31:59 so when mr swales is saying in that paragraph before that we just looked at 63 that the cladding used for the pre-refurbishment tests was either rain screen boards or terracotta tiles
00:32:10 terracotta tiles to be absolutely clear none of those were acn products were they that's correct and they were all
00:32:18 all can you confirm non-combustible cladding products
00:32:22 products i can't confirm that they were totally non-combustible without seeing the european designation for each of the votes but i suspect that they were of
00:32:33 but i suspect that they were of a high performance yeah okay
00:32:38 now to your knowledge did those pre-refurbishments uh pre-grammar refurbishment tests involve open state cavity barriers or only full face horizontal cavity barriers open state
00:32:50 horizontal cavity barriers open state open state horizontally and fall filled vertically right and do you recall when you first met with celetex to discuss bs 8414 testing
00:33:02 i didn't meet them until after the first test i see okay let's look at mr roper's witness statement at this point this is
00:33:14 witness statement at this point this is at c
00:33:14 at c e l three zeros one zero zero five two at page eight c cel three zeros one zero zero five two
00:33:25 c cel three zeros one zero zero five two page eight and i want to look at paragraph five point six
00:33:37 so um he's talking about con sometime around 2013 here in his witness statement you can see that from the next paragraph
00:33:45 paragraph 5.7 where he goes on to october 13. but he says in 5.6 before that he says it was around this time that i was first introduced to chris mort of siderise
00:33:57 mort of siderise who wanted to install the fire barriers free of charge he wanted to team up with a well-known installation provider his suggestion was that he would install the fire barriers free of charge if we mentioned his company
00:34:09 mentioned his company in the literature which we did
00:34:13 now um he's talking about as i said about a time period that appears to be around october 2013. it's not entirely clear
00:34:23 clear um but do you recall either meeting or being put in touch with and introduced to jonathan roper at that time our initials
00:34:34 jonathan roper at that time our initials discussions were only via email um and his statement there suggested we install the firebase free charge is categorically wrong because we do not install
00:34:45 do not install fire barriers on 8414 tests um that isn't the spec a specialist work of the cladding installer we're not we're not licensed on the access
00:34:56 we're not licensed on the access equipment um so we wouldn't install the cavity barriers at all those house they've been installed by their cladding uh
00:35:05 uh installer and like i said earlier all our correspondence was via email in the first instance i see is he right that you were keen on
00:35:16 is he right that you were keen on teaming up with another company in order to undergo bs 8414 system testing as i said earlier we were keen to team up
00:35:26 up with anyone who was willing willing to undertake an 8414 test in the industry
00:35:35 did you offer him your products free of charge for that testing you said you wouldn't install them but did you actually offer to provide
00:35:47 but did you actually offer to provide them
00:35:47 them free of charge for somebody else to install
00:35:51 install yes we still do that today right so you didn't charge him for the products yeah for that testing and
00:36:04 was there ever a plan for cider eyes to install them or was your understanding that
00:36:08 that it would always be installed by seller texas
00:36:12 texas facade yeah correct we wouldn't insult barriers now then moving on if we look at page 12 now mr roper's statement paragraph 5.26
00:36:35 he says that he says i forget it thank you it says i visited the bre facility in watford prior to the first test whilst construction of the test rig was ongoing a process which took several
00:36:47 was ongoing a process which took several days
00:36:48 days rob attended with me that's rob warren and the rig was constructed by patrick patch
00:36:54 patch jones who was a contractor provided by simcoe
00:36:57 simcoe i believe that he may have had assistance from one other person but i cannot remember who this is and then he says chris mort of siderise installed the fire barriers
00:37:08 installed the fire barriers now to the best of your recollection what role did you have in terms of the fire barriers in relation to that first february 2014 test supply only i would not have installed the fire
00:37:20 i would not have installed the fire barriers i'm i wouldn't have been licensed to use the access equipment to install guard barriers if i had attended
00:37:28 attended the bre it would have been to carry out a toolbox
00:37:32 a toolbox training for pat jones but my feet would have remained on the ground and i had only been there to just explain to him how the barriers
00:37:44 how the barriers should go together other than that i've had no involvement whatsoever i cannot confirm if i did attend or not for that toolbox talk i see your record of it
00:37:55 i see your record of it so yes you began that last part of your answer if i had attended the bre do you have any recollection of attending the bre in relation to that february 2014 test
00:38:07 in relation to that february 2014 test um our email chain with celtx is quite well documented and they were very keen to keep us
00:38:18 and they were very keen to keep us at arm's length away from anything to do with the test
00:38:24 because of confidentiality did you provide um patrick jones who was there on behalf of simcoe did you provide patrick jones with guidance on how to install the cavity barriers
00:38:38 on how to install the cavity barriers i can't recollect specifically given patrick jones guidance i could have or may have the description that he gave the inquiry last week of the person attended was
00:38:49 last week of the person attended was certainly wasn't me because i was in my early forties and certainly not bowling
00:38:57 and the photographs i've seen since uh grenfell of the installation of the cavity barriers there's a number of issues there that
00:39:09 there's a number of issues there that i certainly wouldn't have permitted to go ahead if i had seen the quality of the installation okay as you say mr jones has said it is
00:39:21 okay as you say mr jones has said it is all evidence the inquiry that someone from siderise showed him how to install the cavity barriers including he said the phrase how to bend the tabs on the fire barrier that somebody was
00:39:33 on the fire barrier that somebody was there showing him that is it possible that somebody else from sider eyes was there showing him how to install those barriers it is possible right but you don't think
00:39:44 it is possible right but you don't think it was you i don't think it was me because i can't find uh
00:39:50 find uh any email correspondence because there was a there was a strong email to themselves and celotex on this test and certainly we did not check or witness
00:40:02 we did not check or witness the completed installation of the cavity barriers because i said there's a number of
00:40:07 of uh there's at least one fundamental flaw in the installation of the cavity barriers yes so going back to that that other part of your answer and you've just referred to it there you said in the photographs i've seen since grenfell
00:40:19 the photographs i've seen since grenfell of the installation of the cavity barriers there's a number of issues there that i certainly would have wouldn't have permitted to go ahead if i'd seen the quality of the installation are you referring specifically to the first celetex
00:40:31 first celetex test in 2014 that you've seen photographs of that test yes and what is it that you've noticed about the cavity barriers that you say you wouldn't have allowed to go ahead the normal installation
00:40:44 the normal installation of range green systems uh the vertical barriers run continuous and the horizontal uh cut between the vertical barriers on the celtex installation
00:40:56 the celtex installation it is quite apparent that the horizontals run through the verticals on there and also from the photographs they either haven't got sufficient
00:41:08 either haven't got sufficient compression on the vertical or the 25 millimeter air gap wasn't maintained when you say they
00:41:20 wasn't maintained when you say they haven't got sufficient compression on the vertical or the 25 millimeter air gap wasn't maintained are you saying that there should have been a 25 millimeter air gap for the vertical cavity barrier no for the horizontal cavity barrier but
00:41:32 no for the horizontal cavity barrier but where they intersect with the vertical is either they haven't got sufficient compression on the vertical or the horizontals are not maintaining the 25 millimeter
00:41:43 are not maintaining the 25 millimeter gap
00:41:45 gap but they should be at least 35 millimeters in front of the horizontal character of exposed
00:41:53 exposed um stonewall for compression yeah i appreciate you saying you've got um you can't recall attending to assist uh mr jones prior to the test
00:42:04 the test were you made fully aware of the setup of the test rig for that first test prior to the test going ahead were you giving
00:42:12 giving drawings details i saw uh i saw drawings for it those drawings were used to take off the quantity of cavity barriers required
00:42:25 cavity barriers required i see yes now in terms of the test itself
00:42:28 itself did you actually witness that test happen in february 2014 not at all i was there's an email on the system but there was uh requested to
00:42:39 the system but there was uh requested to be excluded from witnessing the test for confidentiality reasons uh from jonathan robert he had discussions with head of marketing and they didn't wish for me to be present i see
00:42:53 wish for me to be present i see and um were you made aware of the results of that test by celetex after it had been carried out yes it was but as to the time scale
00:43:05 yes it was but as to the time scale i couldn't say and was it mr roper that spoke to you after that test and told you about the results i would imagine it would have been
00:43:15 been were you made aware that the mali eternity panels had pulled away from the rig and distorted rendering the cavity barriers ineffective because they had nothing to activate against
00:43:28 yes can you remember who it was he told you that
00:43:38 my correspondence was only with jonathan rob
00:43:41 rob right just for clarity did you ever have any discussions with any other parties involved in that test including the bre did you ever speak to anyone at the bre
00:43:52 no was the uh failure of that test did that strike you as a salutary lesson about how ineffective open state cavity
00:44:03 about how ineffective open state cavity barriers could be in a rain screen system if the failure of the panels occurred the fundamental function of a ranged screen cavity barrier is
00:44:14 screen cavity barrier is not to enhance the performance of the panel
00:44:19 so the handle of the the performance of the cavity barrier is compromised by the inadequacies of other elements it's not the cavity barrier that is inadequate it is the panel is inadequate
00:44:31 inadequate it is the panel is inadequate that is something we can't control
00:44:35 but nevertheless whether you say it's the panel that's the problem or the cavity barrier that's the problem did you appreciate following that test that cavity barriers might be rendered
00:44:46 that cavity barriers might be rendered ineffective if there was failure in the panel that is common knowledge yes
00:44:55 did that make you or anyone else at siderise question whether cavity barriers
00:45:00 barriers should be being used in rain screen systems at all at that point
00:45:08 why not can you help us as to it wasn't something that was thought about there's a demand from the marketplace for captain barriers and regardless whether they're open
00:45:20 and regardless whether they're open state or full fell on that if you were to conduct exactly the same test with a full filled cavity barrier the mode of failure would have been exactly the same is the failure of the panel
00:45:31 the same is the failure of the panel not the cavity barrier so it's irrespective of its open state or fall fill the failure mode of rain screen systems at the failure of the panel system and that come
00:45:42 that come back to my statement earlier of fire stopping regardless of how it's tested
00:45:49 tested it's only as good as as its bounding structure so if you have a four-hour wall
00:45:54 wall and you have a penetration come through that four-hour wall and you fire stop it and then it for every reason that wall is
00:46:05 for every reason that wall is compromised and it's no longer a four-hour wall that fires up although it's been tested for four hours is only as good as the performance of that wall i i appreciate that's your evidence but
00:46:16 i i appreciate that's your evidence but i'm interested in understanding whether anyone
00:46:18 anyone with insider eyes ever gave consideration at this stage to whether there had been adequate and sufficient testing of open state cavity barriers to justify their safe use in rain screen
00:46:31 justify their safe use in rain screen systems
00:46:35 we again we've requested on many occasions
00:46:40 occasions to be involved with eight four one four testing it's we've seen it as we will meet in the requirements of approved document b appendix a in the table 15 we meeting the requirements
00:46:51 the requirements of that element the responsibility in section 12 of a group document b of the external part of the building is not sideways responsibility that's the responsibility
00:47:03 responsibility that's the responsibility of the full project makeup so we unders when instead we comply with the food document b
00:47:14 the food document b appendix a 15 for cavity barriers and we actually over engineered it the requirement is 30-15 we were supplying barriers at 90 30.
00:47:26 supplying barriers at 90 30. right we knew the capital barrier was over engineered for its purpose but the facade industry
00:47:35 where they turned a blind eye or didn't understand the fact it's their responsibility to ensure that the panels were of equal performance to the gravity barrier i see now is it right that in march 2014
00:47:47 now is it right that in march 2014 so after that first failed test in february 14 you arranged a meeting with mr roper of celetex in relation to that february 14 failed test
00:47:57 test yes
00:48:01 now you don't make any mention of that meeting in your witness statement so i do want to ask you about it um we can see confirmation of that meeting taking place if we go to [Music]
00:48:18 cel401976
00:48:26 we can see that this is a meeting request
00:48:30 request from um john roper to sent to himself to jamie hayes and to you
00:48:39 you and we can see it's sent on the 26th of february 2014 and it refers to a meeting that's going to take place at 11 o'clock on the 13th of march 2014
00:48:50 of march 2014 and the subject is rain screen fire development project do you see that yes is it right that you did have that meeting with mr roper on the 13th of march 2014 at celetexas
00:49:03 on the 13th of march 2014 at celetexas premises
00:49:04 premises yes it did and was mr jamie hayes present
00:49:08 present at that time as well i can't recollect can you recall what was discussed at that meeting basically explained that the first test
00:49:21 basically explained that the first test didn't go
00:49:22 didn't go according to plan i wasn't shown any
00:49:28 information at that time in terms of installation of barriers etc etc it was more a case of um can you support us on another test
00:49:40 can you support us on another test um can you supply us with barriers for another test
00:49:48 i see and in terms of can you support us on another test was it just simply a request for more barriers supply material or did you have
00:49:59 supply material or did you have a more in-depth discussion about how those barriers might perform better in a second test
00:50:08 all that would have been discussed would have been
00:50:11 have been the weakness in the test was not the cavity barriers because we've proven from furnace tests that they
00:50:19 that they perform the
00:50:24 word having whatever that unless you have a panel that can last for the duration of the test you were not going to pass this test that's the extent
00:50:37 this test that's the extent of the discussion there was no discussion on materials supply um et cetera et cetera it was just purely a case of
00:50:47 case of they want to understand how the captive barriers worked so i walked them through how you fire test
00:50:54 test the gravity barriers and that the cavity barrier is not the weak link in the chain they're not magic they can't turn a non-fire rated panel into a fire rated
00:51:06 non-fire rated panel into a fire rated panel
00:51:07 panel right and you say that there was a discussion about the fact that unless you can have a panel that can last for the duration of the test you're not going to pass the test yes
00:51:17 test yes um did you suggest that there needed to be
00:51:21 be a stronger panel outside the cavity barrier
00:51:25 barrier to enable it to pass the test not at all we don't get involved in panel specifications did you review the test footage at that meeting
00:51:35 meeting no
00:51:40 were you given a detailed account of as to how the first failure had occurred in the
00:51:45 the falling away of the panels um i was i was just told that it failed and how can you improve the cavity barriers to getting the past
00:51:56 to getting the past test and this is when we went into the discussion of it's not the cafe barrier it's the issue this is how character barriers are tested
00:52:05 tested you need a substrate that's not gonna fall
00:52:08 fall away i see and you remember saying that do you
00:52:11 do you saying you need a substrate that's not going to fall away yes yes um
00:52:19 but did celetex seek any advice from you as to what that substrate might look like not at all because we are not panel manufacturers we wouldn't
00:52:30 we wouldn't give advice on panel material type manufacturer thickness or anything that's not our area of expertise yeah can we just look at what mr roper
00:52:41 yeah can we just look at what mr roper said about this meeting if we go to day 71 and i want to pick it up at page 89 line 10.
00:52:56 so mr roper's asked by mr millett had there been any concerns as a result of the february test about the cavity barriers that had been used and he says um i think what became apparent is that the fire barriers that
00:53:08 apparent is that the fire barriers that were installed on the first test only work by being activated by heat or smoke or fire and expanding upon the inside face of the cladding panel and i think there was some concern around the ability for that intumescent on the end of the
00:53:20 for that intumescent on the end of the fire barrier to expand and close the cavity
00:53:23 cavity so there were some reservations around there
00:53:26 there and then the question did you discuss fire buried designs alongside the use of a six millimeter magnesium oxide and he says yes i believe we did yes
00:53:38 and he says yes i believe we did yes and then questioned so was the use of magnesium oxide a way of overcoming the problem with the cavity barriers not expanding
00:53:46 expanding fully yeah i think what i learned at the time and what i still believe now is that the performance of those fire barriers are entirely dependent on the fire resistance of the cladding panel that they expand onto and then question do you remember
00:54:00 onto and then question do you remember having a meeting with a cavity barrier manufacturer yes who was that cider eyes did you go to the meeting with siderise yes do you remember what you discussed i think i believe jamie was present there
00:54:11 think i believe jamie was present there as well i think we discussed our concerns with chris of cider eyes was that chris mort chris moore yes
00:54:18 moore yes yes and then question and answer about the ability for their product to firstly expand sufficiently to close the cavity and then to work if the cladding panel wasn't there in the first discussion with chris moore about the proposed use
00:54:30 with chris moore about the proposed use of six millimeters magnesium oxide and he says i don't know if i'm honest with you i don't know now having seen that can you recall whether you had any discussion with mr
00:54:42 whether you had any discussion with mr roper about the use of a magnesium oxide board to strengthen the cladding panel at the location of the cavity barriers uh certainly not and if you look back to
00:54:54 certainly not and if you look back to his transcript he had this fixation that the intumescent didn't expand and that the county barrier should be protecting
00:55:05 barrier should be protecting the facade after the panels have fallen away which i would have gone strongly discussed within the fallacy of that is that the cap any form of fire stopping is only as good as his bounding
00:55:17 stopping is only as good as his bounding structure
00:55:19 structure and that proven from furnace test and i've shown him um a furnace or discussed furnace test scenario of the intermediate expanding against
00:55:30 the intermediate expanding against structure and remaining in place for the duration of the test so he had you can see from his discussion he didn't understand how intune essence worked right
00:55:41 worked right i see so an education of how inch message worked even if you didn't mention magnesium oxide board specifically did you have any discussions along the
00:55:53 did you have any discussions along the lines of using a two panel solution by having two two thicknesses of panels
00:55:59 of panels in the gravity barrier location we wouldn't
00:56:03 wouldn't get involved with panel discussions we do not manufacture panels we do not supply panels so i would not have got a discussion with the material that i wouldn't have known any material properties about and certainly would
00:56:14 properties about and certainly would have been involved in any sale of material
00:56:21 just to look at mr roper's witness statement
00:56:24 statement at this point cl3010052 page thirteen paragraph five point three
00:56:42 one he's he says here he says following our internal discussions i sought some advice from the ifc and the bre i spoke to phil about thickening the cladding panel to 12 millimeters
00:56:54 cladding panel to 12 millimeters he means phil clark there and then he says i believe we also spoke about the option of strengthening the fire barrier level with a two-panel solution because it appeared from the february test that the cladding panel had cracked
00:57:05 test that the cladding panel had cracked and fallen away which enabled the fire to jump around the fire barrier at level two i do not think that phil suggested anything specific in this regard so just to be absolutely clear did you
00:57:16 so just to be absolutely clear did you ever whether at that march meeting or at another time have any discussions with mr roper at celetex about using a two-panel solution to strengthen the
00:57:28 a two-panel solution to strengthen the fire barrier level not at all
00:57:36 now we know that celatex did go on and they retested the rs 5000 in a second bs8414 test in may 2014. did you have any involvement in that second test
00:57:49 that second test only in supply of samples
00:57:53 were you made aware of the precise build-up of that test rig no we're just asked for a repeat of the quantity of samples supplied for the first test right so you
00:58:05 supplied for the first test right so you merely
00:58:06 merely supplied again free of charge yes yes um some cavity barriers to use in that second test yes that's correct were you at any point
00:58:18 that's correct were you at any point either prior to the test or after the test made aware that magnesium oxide boards have been installed behind the malia turnip cladding in order to boost the system's fire performance at the
00:58:30 performance at the top levels of the rig not at all so when was the first time that you learned that there were magnesium oxide boards have been used in that test rig
00:58:41 boards have been used in that test rig it was after the grand old fire when the test reports became uh available
00:58:56 if we could look at um dr lane's phase 1 report again briefly now this is blas 5026 page 40.
00:59:15 the paragraph e4.5
00:59:21 dr lane has pointed out here that in the final
00:59:24 final test report and i can take you to that shortly that the provision of cavity barriers is different in the photograph figure 2 in the bre report
00:59:34 report relative to the design drawings figure 7 in the bre report she notes that additional vertical cavity barriers were installed in the test above level 1 but are not shown on the test drawings
00:59:45 the test drawings and that an additional three horizontal cavity barriers were installed in the test
00:59:50 test but is not represented in the test drawings
00:59:53 drawings now do you remember being sent test drawings
00:59:57 drawings in advance of this second test no
01:00:02 um if we can go to the final report this is at bre
01:00:06 is at bre four zeros two four nine seven this is a copy of the finally issued report from the 1st of august 2014
01:00:18 the 1st of august 2014 and i'm going to take you to the two figures that dr lane has picked up on if we go to figure 2 which is on page 12.
01:00:29 page 12. what we can see in this photograph
01:00:33 is that there were four horizontal cavity areas there's one right at the bottom you can just see it in the very corner of the page above the crib another one
01:00:45 above the crib another one at level one another one at level two and another one right at the top of the rig can you see that yes and then there's four vertical cavity barriers so so the horizontal ones are in green and the vertical ones are in blue
01:00:56 and the vertical ones are in blue yes yes um now you said that there were some problems with the way in which the cavity barriers had been installed in the first test did you spot that there were
01:01:07 did you spot that there were difficulties with the way they've been installed in this test only after we had the test report after the grandfather i see
01:01:18 is it the same problem that what you're saying is the horizontal have been cut through the vertical correct i see um going back to this discrepancy that dr
01:01:29 going back to this discrepancy that dr lane picked up on there we can see clearly four horizontal four vertical cavity barriers but if we go to figure seven
01:01:35 seven on page seventeen
01:01:40 and then it's it's not easily clear from this because we can't see all the labels but in essence what she's picked up on is that the vertical and horizontal cavity barriers marked in these drawings
01:01:51 marked in these drawings are not the same as what's in the photograph now um can you help us do you know who made the decision to install more cavity barriers in the test
01:02:02 install more cavity barriers in the test rig than
01:02:03 rig than was shown in the specification drawing no i don't were you asked for any advice about how many cavity barriers ought to be installed in this test right
01:02:22 did you have any involvement with celetex
01:02:25 celetex um after that second may 2014 test uh
01:02:33 test uh no not from recollection though siderise included celetex's bs 8414 part two test of may 2014 on its website as a successful test in which
01:02:44 successful test in which ciderised cavity barriers have been used is that right yes and is it also right that more recently that web page has been taken down and replaced
01:02:56 taken down and replaced with a screen requiring login details to progress further onto the website um i don't i don't know i don't believe so now i believe it's
01:03:08 i don't believe so now i believe it's open forum i i don't know um it's marketing um i don't get involved in the marketing on the website okay is it correct that the public no longer has access to the siderise
01:03:20 longer has access to the siderise product test reports which were previously accessible to the public on your website is that a decision that's been taken by sidereel it's still available on the website
01:03:31 website they're still available are they yes all the product testing of the sidewise products for all for the range screen systems yes i see now if we can turn to
01:03:44 cel403214 there's a celetex monthly report um that i just want to take you to this is from june 2014. um
01:03:58 is from june 2014. um so we can see celatex monthly report june 2014
01:04:02 june 2014 and if we go within this report to page nine
01:04:06 nine we can see under the heading 5.5 it's got npd
01:04:15 update possibly new product development update
01:04:18 update and we can see it says uh in the first bullet rs 5000 above 18 meter solution due for launch 4th of august at regional meetings and then in the second bullet it says
01:04:30 and then in the second bullet it says fulfill cavity in-house testing commence spoken with siderise re-assisting with manufacture first test cycle due early august can you help us as to what that's
01:04:42 can you help us as to what that's referring to
01:04:46 if it's full filled cavities i would imagine they have product ranges that go into masonry construction
01:04:58 right so can you remember there being some form of a collaboration between ciderise and celetex about fulfilled cavity barriers at this time
01:05:10 fulfilled cavity barriers at this time um it might not have been with myself it might have been with um sales team so does that does it follow you have no recollection of this that's correct
01:05:22 that's correct um i want to ask you now about um some meetings you had or meeting with arab
01:05:29 arab that you refer to in your witness statement if we can go to sil 50298 page 13 and i want to turn to paragraph 47 of your statement
01:05:44 here you are describing a meeting that took place with uh dr barbara lane and her colleague charlotte robin and yourself and andrew k of cider eyes on the 1st of december
01:05:57 k of cider eyes on the 1st of december 2014 is that correct yes can you recall that meeting yes i can now prior to that meeting you'd send a preparatory email if we can turn to it
01:06:08 turn to it sil50323
01:06:10 sil50323 at page two
01:06:13 this is an email from you to dr lane on the 16th of september 2014 we can see that from the date sent
01:06:24 that from the date sent and you've said in the beginning of that dear barbara in preparation for our meeting on thursday i've attached some typical test reports and engineering judgment documents for background information and a list of discussion points below
01:06:37 a list of discussion points below and then we can see from the first heading
01:06:41 heading that obviously a key part of your meeting appeared to be discussing the requirements for testing for fire stops and curtain walling is that right yes um and then we can see there's a second
01:06:53 um and then we can see there's a second heading
01:06:53 heading at the bottom of that page open state cavity barriers as utilized in rain screens so is it right that was a topic that you
01:07:02 that you were wanting to discuss at this time yes so this is in september 14 yes this was a a follow-on to a cwct meeting that had occurred at arab
01:07:15 cwct meeting that had occurred at arab fire
01:07:16 fire some weeks previous right which is minuted
01:07:19 minuted i see yes thank you and um we can see that you say in the following bullet points um in the first point currently there is no official bs or en standard
01:07:32 there is no official bs or en standard for testing these products what is your view
01:07:35 view asfp have published a technical test standard attached do you see this as an acceptable test methodology for cavity barriers
01:07:44 barriers and then um you say cen technical working group tg9 working on a test standard bsi also starting to work on a test standard
01:07:55 standard basis of reaction to closure time of seal sub five minutes do you think this is suitable
01:08:03 so um from those bullet points would it be fair to say that at this stage
01:08:10 stage the testing that was being developed was certainly not standardized and it was very much
01:08:14 very much still developing would you agree yes and if we turn to the next page of the email there are more bullet points you say in the first bullet you say
01:08:26 you say in the first bullet you say bs841 for testing it appears that there's an increase in the number of tests being carried out however how real is the data as tested materials are not being utilized on projects
01:08:40 and then second bullet misinterpretation of cavity barriers versus fire stops into external cavities discussion and then in the fourth bullet you say products being utilized that
01:08:51 you say products being utilized that either have no testing or very subjective testing what is arab's view
01:08:59 now um can you just help us um with that first bullet at the top of the page bs8414 testing it appears that there's an increase in the number of tests being carried out
01:09:10 tests being carried out however how real is the data as tested materials are not being utilized on projects can you remember what the concern was that you wanted to discuss with dr lane
01:09:21 wanted to discuss with dr lane um yes i know that sideways barriers have been used in something for one protesters as we've previously discussed
01:09:33 previously discussed but sideways we were not seeing an increase in sales against projects and that we knew captivated be using so materials are being substituted
01:09:46 and etc it's just
01:09:52 it's just highlighting the issue to them that they may be specifying barriers on a project but the barriers that they specify in aren't necessarily being used i see so
01:10:04 aren't necessarily being used i see so are you saying that substitute cavity barriers were being used from the ones that had been tested in eight for one for tests yeah or none at all i see is it were you also drawing attention to
01:10:17 is it were you also drawing attention to the fact that some of the cladding panels that were tested materials were not being utilized on projects i they weren't realistic cladding panels um back then at that stage probably not
01:10:32 i see and and you're obviously drawing attention
01:10:36 attention to the fact that there isn't a standardized test standard for these types of
01:10:41 types of open state cavity barriers and did you ever have any discussions with anybody within government or those drafting approved document b to that effect that there was no
01:10:52 that effect that there was no recognized standard for testing of open state cavity barriers no i haven't
01:11:05 now you sent a summary email the next day after the meeting on the 2nd of december
01:11:12 december 2014 to andrew k and stephen swales if we go to that that's at sil 50331 at page two
01:11:23 and if we could look at the top half of that page
01:11:27 that page it's from you to your colleagues internally with insider eyes and it's dated the 2nd of december 2014 and it's subject arab fire key
01:11:38 and it's subject arab fire key points um this seems to be a bullet point summary of the meeting you say hi steve andy yesterday i feel we had a very successful meeting with professor barbara lane and charlotte robin with regards to fire
01:11:50 and charlotte robin with regards to fire issues that exist for facades and key points below and then if we can go to page three of this document at halfway down the
01:12:02 of this document at halfway down the page we can see a bullet point which begins if we zoom in in the middle of that page there's a bullet point right in the middle that begins
01:12:14 middle that begins agree it says um arab agree that the asfp test guidance for open state cavity barriers although not perfect
01:12:23 perfect is a good step forward in terms of testing and they will request this on all projects that they are working on now can you help as to why arab had said
01:12:34 now can you help as to why arab had said that
01:12:35 that it was not perfect but a good step forward
01:12:38 forward that test guidance can you recall what you were told
01:12:43 fire test standards are continually reviewed
01:12:47 reviewed they are never perfect even now so any published en standard would be published
01:12:54 published as it starts to get used then you find out some of the imperfections in there so when it comes back for re review
01:13:02 review those imperfections are trying to be ironed out yes i i understand that mr moore but just can you think back to this meeting and the notes of this
01:13:13 to this meeting and the notes of this meeting
01:13:14 meeting can you recall what you were told by arab about why it was not perfect but a good step forward they didn't elaborate anything more than that statement
01:13:23 statement i see and below that immediately below that there's a a sentence which begins arab agree
01:13:35 sentence which begins arab agree sorry um yeah below that it says they were encouraged of our involvement in cn tc127 tg 9 and bsi fsh22 as this actually may allow for
01:13:47 fsh22 as this actually may allow for standards to be developed that reflect real world scenarios and would gladly comment on any development work which i will present to the cen and bsi at the next meeting as experts can be
01:13:58 at the next meeting as experts can be drafted into developments for comments on standard so um would it be fair to say that you had discussed with arab that
01:14:09 you had discussed with arab that um there needed to be the development of real world scenarios in terms of this testing
01:14:17 testing i did testing of products yes and it was more of a invite to try and get arab
01:14:28 more of a invite to try and get arab to become involved with british standards
01:14:33 to comment on the actual standards i think not comment after they've been published the comment during they were being developed at this point and thinking back to the state of play when
01:14:45 thinking back to the state of play when you wrote these notes were you of the view that ciderizer's open state cavity barriers had been appropriately comprehensively and reliably tested such
01:14:56 comprehensively and reliably tested such that they could be marketed for use in rain screen systems to the standards that we needed to comply with with the product of the appendix a in terms of 3015 requirement yes
01:15:09 in terms of 3015 requirement yes but what about for real world scenarios did you think that the cavity barriers had been appropriately comprehensively and reliably tested for the real world scenarios that they were going to encounter in rain screen
01:15:21 were going to encounter in rain screen systems
01:15:22 systems that's a bigger question for the rain screen planning panel market we have openly requested
01:15:33 we have openly requested to participate in testing and nobody came forward so unless the industry moved forward together we can only test the standards that are available to us
01:15:47 available to us i appreciate you saying that's a bigger question for the rain screen paddling panel market but does it follow from the fact that you say you were opening with openly requesting to participate in testing
01:15:58 testing that you did think that it was important that there were more comprehensive tests carried out of these open state cavity barriers in rain screen systems
01:16:10 rain screen systems the performance of the rain screen cavity barriers as i previously stated is not a function of an eight four one four test the function of eight four one four test is to test the complete
01:16:21 is to test the complete system and the mode of failure on eight for one for test of the panels so whilst sideways are tested to a furnace test where the temperatures
01:16:32 where the temperatures are higher than those exposed to rna414 test
01:16:37 test the capture value isn't the weak link and that
01:16:40 and that is acknowledged across the industry
01:16:45 yes but just to ask it in a different way um
01:16:48 way um did you think at this time that it was important that ciderises cavity barriers were tested in real world scenarios to see whether they could be appropriate
01:17:00 to see whether they could be appropriate for rain screen systems we are tested as far as we could on our own we needed partners from the industry to partner with us to test further only a handful of
01:17:13 to test further only a handful of partners came forward as it's been highlighted in steve's wales's witness statement we can't force the green screen manufacturing industry to test with us
01:17:24 to test with us and we are not the experts in green screen panels so it needs the expertise from that market to design their panels and how they uh retained onto this test
01:17:38 retained onto this test one yes i see mr chairman would that be an appropriate moment for the afternoon break yes i think it would we'll have a break now mr mort uh please remember what i have said to
01:17:49 uh please remember what i have said to you earlier about the importance of not discussing your evidence with anyone else and um we'll come back at 25 to 4 please all right thank you then thank you very
01:18:10 much
01:34:40 welcome back everyone we're ready to continue with the evidence of mr mort mr are you there can you hear me can you see me all right yes i can thank you thank you very much
01:34:51 yes i can thank you thank you very much ready to carry on then yes sir thank you well ms grange when you're ready then thank you yes thank you um yes at this point i want to go back to dr lane's report again her phase 1
01:35:03 dr lane's report again her phase 1 report
01:35:03 report and look at blas 5011 page 77
01:35:22 and i want to look at what she says at 11 20.45 and following yes right at the bottom of that page there's three paragraphs i want to read so um
01:35:33 i want to read so um dr lane here uh has reviewed the test report information for the siderise cavity barriers and she says at sub paragraph 45 there both test reports
01:35:45 both test reports sil and then she gives the names and those are the test reports that we've some of the test reports we've looked at today and both assessment reports only consider the performance of the lamboth
01:35:57 performance of the lamboth cw rsh cavity barriers installed in cavities formed between two autoclaved aerated concrete lintels then she goes on this construction is substantially not representative of the
01:36:08 substantially not representative of the on-site grenfell tower installation where the cavity barriers are installed between concrete and polymeric acp rain screen padding panels and then at 47 she says i therefore conclude none of
01:36:19 47 she says i therefore conclude none of the disclosed evidence received to date for the horizontal open state cavity barriers
01:36:24 barriers is representative of the construction at grenfell tower and therefore cannot be relied upon as evidence of their suitable fire performance in that context now um do you agree
01:36:37 now um do you agree that none of the testing undertaken by cider eyes provided a sound basis upon which to conclude that ciderizer's open state cavity barriers were safe to use in a rain screen
01:36:48 were safe to use in a rain screen application involving acm panels
01:36:54 not at all the whole premise of testing cavity barriers to published and developed standards is to ascertain the performance of the cafe barrier in isolation
01:37:07 cafe barrier in isolation not in its finished state it's responsibility of the fire engineer on the project or consultants on the project
01:37:14 project to take all the fire resistance and or reaction tests for all the elements to come to that conclusion
01:37:26 i see there's no um a test available for sideways to be able to test
01:37:34 to test carefully barriers between concrete and what she's describing is polymeric acp there is no there is no test available to do that from a furnace test perspective
01:37:45 from a furnace test perspective i i appreciate that's your answer but but just going back to my question can we agree
01:37:51 we agree that none of the testing undertaken by siderise provided a sound basis on which to conclude that ciderizer's open state cavity barriers were safe to use
01:38:01 use in rain screen applications involving acm panels i i disagree as i as i've stated and i'll state again the purpose of testing crafty barriers on a furnace
01:38:12 on a furnace is to test that as a unique element of construction it is the
01:38:20 understanding and the need in the industry that other engineers other fire engineers or consultants take every element of fire performance
01:38:31 take every element of fire performance of
01:38:31 of every element of construction to bring them together as an overall assessment for a project to say
01:38:38 to say yes that is fit for purpose you you don't you don't
01:38:47 test a the acp panel is only tested for reaction to fire it's not tested for fire resistance so the fire engineers on the project or
01:38:59 so the fire engineers on the project or the consultants on the project or whoever is responsible for bringing all that information together they're responsible to assess the whole package or insist on an eight for one
01:39:11 package or insist on an eight for one full test
01:39:12 full test yes i i fully appreciate that you're saying it was somebody else's responsibility on the grenfell project this is your evidence to make a holistic assessment of that
01:39:23 make a holistic assessment of that system looking at all the elements and the fire performance but but just standing back um and thinking about the test evidence that was available on the cavity
01:39:34 that was available on the cavity barriers
01:39:35 barriers can we agree that the evidence that was provided
01:39:39 provided didn't provide a sound basis on which someone could conclude that those barriers were safe to use in rain screen applications involving acm panels no we can't conclude on that
01:39:50 acm panels no we can't conclude on that no because we have tested to comply with the food document be appendix a and test it on the furnace test
01:39:57 test it is somebody else's responsibility within the project chain to make that connection yes and um is it fair to say that at the time the
01:40:10 is it fair to say that at the time the panels were provided on the grenfell project and will come to your specific involvement in the project in due course but is it fair to say that at the time the panels were provided on the grenfell project you were aware
01:40:22 you were aware that there was a significant risk that the product might not perform properly in such an arrangement if there was a
01:40:30 was a failure of the cladding panel external to it
01:40:34 to it but then i come back to my previous statement of fire stopping or cavity barriers are only as good as abandoned structures that's right across passive fire protection if a bounding structure
01:40:45 protection if a bounding structure is the weakness then that is the weakness
01:40:49 weakness we cannot control those weaknesses yes did you ever say that to any of the professionals on the grenfell project that the product is only as good as the
01:41:00 that the product is only as good as the bounding structures um i can't recollect unnecessary in the documentation i can't recollect that yeah i don't think we see
01:41:11 yeah i don't think we see sidereel saying that at any stage saying clearly to the professionals on the project
01:41:16 project by the way our products are only as good as the as the products which bound them and they may not be able to work effectively if
01:41:27 effectively if those other products do not stay in place in a say in a rain screen system i wasn't aware
01:41:34 aware of what the panels were on the grenfell project
01:41:38 project so i could not make that assumption are you saying you weren't aware that these were
01:41:43 were aluminium composite material panels correct
01:41:47 correct okay we'll come to your specific knowledge um later and i want to ask you at this point about some questions about extended application assessments um
01:41:58 application assessments um first of all can you explain what's meant by that terms in the way that sideres have used them extended application assessments
01:42:07 you can within reasonable uh within uh reasonability you can extend the application of a
01:42:19 application of a product if you have other supporting evidence
01:42:23 evidence to support that extension in so extended field application x app so in terms of
01:42:30 terms of cyrus price we had have on file um test evidence and supporting evidence that
01:42:37 that the products work in larger voids than what we tested for the open state cavity barrier the intumescent gap remained the same
01:42:49 the intumescent gap remained the same the in tumescent type remained the same the extension was to the stonewall part of the barrier and we had evidence that supported us
01:43:00 supported us to extend that stonewall okay yes i understand you're slightly anticipating some of my questions there but i think what you mean by an extended application
01:43:11 what you mean by an extended application assessment is you take data and you work out whether the product can be used in other scenarios other than the scenarios in which you've tested yes exactly that yeah if we look at mr
01:43:23 exactly that yeah if we look at mr swales's witness statement at this point if we go to sil 50306 page 14 paragraph 52
01:43:36 we can see that he says um with the above results and that's the results that we've been going to with the test evidence we've looked at earlier
01:43:45 earlier sideres were able by extended application x-apps to assess the performance of the barriers in larger cavities
01:43:54 and if we turn now to a document sil50204
01:44:00 sil50204 page 22
01:44:14 sil 502 yes thank you this is the extended field of application assessment for sideriser's horizontal 25 mil 90 30
01:44:26 horizontal 25 mil 90 30 cavity barriers um we can see so if we go back out again from the document we can see yes in that very top left hand corner
01:44:38 very top left hand corner we can see it says siderise r8 horizontal 25 galvanized and then it's the 90 30 minute parity barriers and we can see
01:44:50 30 minute parity barriers and we can see the void size 301 to 425 millimeters yes yes so this is an extended application assessment for void sizes of that extent
01:45:02 assessment for void sizes of that extent and if we look in the bottom left hand corner we can see that you've signed this
01:45:07 this as the group technical officer can you see that and it's dated the 23rd of june 2017
01:45:14 2017 so just after the grenfell tower fire yes
01:45:17 yes yes so is it right that you completed this x-app assessment for this cavity barrier for use in voids between 301 and 425 millimeters at this time we had
01:45:30 at this time we had uh the an unofficial uh extended field of application within our system this was actually formalizing it yes can you explain why it was that an
01:45:41 yes can you explain why it was that an extended application assessment was carried out at this time on the 23rd of june 2017
01:45:46 june 2017 what what had prompted it um it was just requested from the business was that in response to the grenfell tower fire that it was requested
01:45:57 tower fire that it was requested i couldn't say you were never told that no
01:46:03 we can see at the top of the page under the heading scope
01:46:08 if we go back to the top of the page states this document relates to the production of xnap assessment which are offered in the absence of specific fire resistance test results following the guidance given in passive
01:46:20 following the guidance given in passive fire protection federation guide to undertaking assessments in lieu of fire tests yes yes and then underneath the bullet points
01:46:29 points right at the bottom of that page it says except assessments will vary from relatively simple judgments on small changes to a product or construction through to detailed and often complex engineering
01:46:41 detailed and often complex engineering assessments of large or sophisticated constructions this document is set out to assess the non-complex changes and or assessment for complex assessments on a project or
01:46:52 for complex assessments on a project or product
01:46:53 product basis a full engineering judgment would be undertaken now what steps did you take when present preparing this x app to ensure that you were following the passive fire protection federation guide
01:47:05 protection federation guide to undertaking such assessments in lieu of fire tests we had um further down the page you will see
01:47:12 see we had a test evidence of the parent
01:47:19 stonewall product being certified for larger voids than what we had tested did you consider that you were appropriately qualified to conduct an
01:47:30 appropriately qualified to conduct an assessment of this nature where you're extrapolating from data and applying it to larger void sizes yes
01:47:41 did you seek any outside or third party assistance when producing this assessment to validate the conclusions that were drawn in it
01:47:51 can you help why not why not get a third party to
01:47:55 party to validate this it wasn't required at the time as in not required by by side arise in terms of its internal processes
01:48:05 processes required wasn't required by sideways not required by approved document b
01:48:11 and is it right that these x apps were conducted by sideres on a product by product basis rather than doing a generic x app is that right did it ever occur to you that there might be a
01:48:24 ever occur to you that there might be a difficulty with siderise essentially certifying their own products for use in these extended applications without any external third-party sign-off or check
01:48:35 external third-party sign-off or check no and is it right that you concluded if we go back to the document under the heading conclusion that an extended application to voids up to millimeters could be permitted yes
01:48:53 so you can see under conclusion side rise horizontal barriers 90 30 maximum permissible void size of four to five millimeters
01:49:03 now um this exact post dates the supply of horizontal cavity barriers at grenfell for voids of between three two six and
01:49:14 for voids of between three two six and four
01:49:14 four to five millimeters yes yes had any um except assessments been conducted
01:49:23 conducted on siderise open state cavity barriers prior to the 23rd of june 2017 yes they had but not in this formal way so when you say they had they had but
01:49:35 so when you say they had they had but not in this formal way where they documented those x assessments they would have been
01:49:43 through uh electronic way through a bill and materials through an electronic system
01:49:49 system this is more of a formal documentation of that
01:49:53 of that what does that mean they would have been through electronic way through a bill of materials through an electronic system was there actually a documented analysis of how these products could be used in
01:50:05 of how these products could be used in bigger void sizes
01:50:08 as i said there would have been a discussion on can we supply these larger sizes we have the supported evidence so it was done in a factory control
01:50:21 so it was done in a factory control electronic format rather than in a formal
01:50:24 formal document i see
01:50:28 and can we now turn to page 29 of this document
01:50:33 this is the x app for
01:50:37 the horizontal cavity barriers 120 60 product so again was it the same process that and we can see at the bottom in the
01:50:48 and we can see at the bottom in the conclusion you've signed off on this yes exactly the same process and you've concluded that these 120 60 horizontal barriers
01:50:59 120 60 horizontal barriers can be used up to void sizes of 425 millimeters yes yes
01:51:07 yes and how could cydar eyes have been sure prior to these x apps that the products could be used in void sizes up to those dimensions without having either
01:51:20 dimensions without having either conducted some testing or conducted a rigorous except assessment we had carried out an exa assessment however it wasn't in this format
01:51:36 so we have the historic data all we've done in this form is formalize it into a
01:51:43 it into a formal document right and is it right that some subsequent testing did take place in october 2017 and november 2017
01:51:54 and november 2017 to validate this in an actual test condition
01:51:57 condition yes can you explain how cider eyes were able to supply cavity barriers for voids between three two six and four to five millimeters at grenfell tower when it appears that no
01:52:08 when it appears that no testing to those void widths or any extended application assessments had been undertaken at that time as i just stated the x-app applications had been undertaken
01:52:20 x-app applications had been undertaken but not in that formal form so they had been undertaken previously i see
01:52:26 see we're not aware of any documentation being provided to the inquiry that supports these informal assessments having been made um would there be such documentation in existence
01:52:39 without looking into arc i wouldn't say there was actually formal documentation um it's within the electronic system the whole system
01:52:51 electronic system the whole system and just turning now briefly and i i don't think i need to go through this exercise in detail again because i think you
01:52:58 you you will agree most of this um in terms of the testing and certification of sideriser's vertical cavity barriers this time not the horizontal ones can we agree that those were also the
01:53:09 can we agree that those were also the subject of extended application assessments for the void sizes used at grenfell but those
01:53:15 those assessments were only carried out after the grenfell fire in june 2017 yes as i've said previously the formalization
01:53:26 formalization of those assessments into the form that you were presenting were carried out after the grant film inquiry as dated on performance but we were had uh
01:53:37 performance but we were had uh through our electronic process that process
01:53:40 process in the background for existing products and just breaking down sorry carry on it's common across the fire industry you you um
01:53:51 the fire industry you you um you test x y and z and the project comes up and asking for x plus y plus because of the need to supply
01:54:03 because of the need to supply the project with the you haven't got the time frame with the tester priorities in order to get in to test all these things of all the time
01:54:11 the time so that's where it comes from yes but but we did see in a number of the test reports earlier and i specifically drew your attention to it that it made clear that
01:54:23 that it made clear that that those test reports could only support
01:54:26 support uh the use of the products up to those void sizes yes yes now that's where the pfpf document and others we had that test evidence that said it was tested to
01:54:37 was tested to that size then we had other supporting evidence
01:54:41 evidence that said the the stonewall part of it would have been tested and certainly made for larger so therefore
01:54:48 therefore that was the changing element not the intumescent intumescent remained same we had other support and evidence saying that the stonewall was suitable for larger voids so
01:54:59 was suitable for larger voids so therefore
01:55:00 therefore we made the assessment that you introduced that larger stone wall element in there including the steam standard size of the instrument then you can extend
01:55:11 can extend the scope and we have proven by future testing
01:55:15 testing that our uh validation is correct right yes and for the vertical cavity barriers it's right isn't it that you'd only tested up to a void width of 300
01:55:26 only tested up to a void width of 300 millimeters prior to the grenfell fire from memory possibly yes and then after the fire what we see in the documentation on the 23rd of june 2017 you did extended applications
01:55:39 2017 you did extended applications for voids between 301 and 400 millimeters yes yes and they're signed by you again no third party validation there's no need for the body validation there's no requirement for it
01:55:51 validation there's no requirement for it and then with vertical cavity barriers some testing was done in april 2018 for voids of 450 millimeters yes yes and the void sizes at grenfell for the
01:56:02 and the void sizes at grenfell for the vertical cavity barriers were between 391 and 425 millimeters yes um i rely on your information on that
01:56:13 um i rely on your information on that that
01:56:13 that there's a product called range yeah and again can you explain how that came about how you were able to sell those vertical cavity barrier products for use at grenfell tower when there had been no tests or formal
01:56:26 when there had been no tests or formal extended application assessments for those void sizes before that we had third-party certification for voids up to score sizes excuse me i
01:56:38 up to score sizes excuse me i interrupting strange i wonder whether you can help me mr mort i'm sure the confusion is entirely my fault but i'm trying to understand how you can have an extended application for
01:56:51 you can have an extended application for um vertical cavity barriers which i think by definition don't have any intumescent properties do they no they're solid barriers yes and presumably
01:57:02 presumably they close off the whole of the distance between the sub between the substrate and the cladding panel correct well i don't understand then how
01:57:14 correct well i don't understand then how we have extended application if you've got a
01:57:17 got a 250 mil cavity barrier it's a 250 ml cavity barrier but i obviously don't understand so but we had
01:57:26 we had we have third party certification on uh other products that use the same parent stonewall that allowed us to extend the scope i'm just thinking as a matter of fact
01:57:37 just thinking as a matter of fact what how do you i don't understand how you have an extended application for a 250 ml cavity barrier which is solid and in relation to a
01:57:49 which is solid and in relation to a cavity of much larger words you have test evidence and you have the third-party certification evidence that allowed you to extend the scope of that
01:57:59 that and we have proven without any doubt that these that our assessments that were made
01:58:07 were made historically are proven to be correct we have tested 450 millimeter bytes and proven that our assessments all right well correct what what do you put into the 450
01:58:18 what what do you put into the 450 millimeter void stonewall barrier or lamellas barrier is it are you just saying it's the extended application you make a bigger barrier with the same material yes exactly good thank you and i now do
01:58:32 yes exactly good thank you and i now do understand it and i'm grateful to you thank you very much thank you yeah that's helpful um marketing material i i want to ask you some questions now about ciderises
01:58:43 some questions now about ciderises marketing material and product information and and i'm gonna try and do this broadly chronologically looking at some of the older marketing material and then some of the more recent and focusing
01:58:54 some of the more recent and focusing predominantly on the marketing material that was in place at the time the barriers were selected for use at grenfell tower now um i want to start with something called datasheet0314
01:59:06 called datasheet0314 if we can go to sil402588
01:59:15 this is an early data sheet that cider eyes produced
01:59:21 we can see that in the bottom right hand corner it says 0314 and our understanding is that this was drafted in march 2002 does that sound right
01:59:33 2002 does that sound right um from the livery yes yeah we get that for the for the transcript from paragraph 44 of mr swales's witness statement on page 12. and if we pan back out again we
01:59:45 page 12. and if we pan back out again we can see that this data sheet explained under the heading introduction um i'm going to read out what it says it says the cavity between curtain walls and fire compartment walls floors
01:59:57 and fire compartment walls floors needs to be sealed with a fire stop to the same fire rating as the compartment wall or floor a particular problem is posed by the use of rain screens where the fire stop cannot fill the full
02:00:08 where the fire stop cannot fill the full width of the cavity as the rain screen requires a typical 25 millimeter air space to carry out its function lamitham have developed a solution that can be
02:00:19 can be used to overcome this problem standard cw curtain wall fire stop solutions for curtain walling are stopped
02:00:27 stopped and modified at our factory to include an aluminium full face to the outside edge to which is bonded a continuous intumescent strip in the event of direct exposure to fire when subjected to heat the intermediate strip will expand and
02:00:39 the intermediate strip will expand and fill the air gap left within the void and then it says although the fire stop will not seal the cavity at the rain screens
02:00:46 screens it will restrict the movement of smoke and hot gases as much as is practical and then it says the loss prevention council reference refers and that was the letter
02:00:59 refers and that was the letter that we looked at earlier from the loss prevention council yes yes where they said it will restrict the movement of smoke and hot gases as much as is practical
02:01:11 um so um is it right that at this stage cider eyes was marketing its um
02:01:23 its um cavity barriers in in rain screen applications
02:01:29 based solely on that letter received from the loss prevention council
02:01:35 um back in 2002 i had only just joined sideways so yes i believe it was yes
02:01:43 and it's right isn't it at this point that
02:01:47 that cider eyes haven't carried out any testing of those open state cavity barriers at all the tests that we saw they began in 2007 yes
02:01:58 yes well the discussion started in 2006 the tests
02:02:02 tests yeah i mean either way that um that's several years after this marketing literature yes yes due to the lack availability of
02:02:13 yes due to the lack availability of a specific fire test yes i i appreciate that but
02:02:18 that but but i think we can agree that ciderise was marketing its cavity barriers for rain screen systems as early as 2002 yes yes
02:02:31 um can we now turn to um a technical paper on cavity barriers in rain screen facades this is a sil402428
02:02:42 and this is a technical paper which was presented at a facade conference on the 1st of november 2012 at bre innovation park
02:02:54 we can see that at the top there sidewise technical paper fire cavity barriers in range screen facades facade conference first november 2012 bre innovation park
02:03:05 bre innovation park were you present at that conference do you remember attending that yes i was and do you know who presented this paper was that you or somebody else that would have been steve swears mr
02:03:17 that would have been steve swears mr swales yes and if we go to page eight and we look in the fourth paragraph down
02:03:29 and we look in the fourth paragraph down under the so it's under the broad heading design of cavity barriers and it says four paragraphs down proprietary clarity barriers such as the lamifer cwrs rainscreen cavity barrier
02:03:41 lamifer cwrs rainscreen cavity barrier are available which partially block the cavity and have a strip of intumescent material
02:03:45 material at the front that can expand to block the cavity in a fire and then there's reference to figure four which i think we see if we could just come out again we can
02:03:56 if we could just come out again we can see that in the bottom right hand side of this page
02:04:02 sorry there you can see there's the figure showing the cavity bearer being installed to maintain a residual gap of 13 to 25 millimeters depending on the type of project
02:04:13 the type of project and then if we go back up to the the words of this technical paper so after that paragraph it then says cavity barriers may be tested following the principles of bs 47620 or bs en 1366 part 4.
02:04:28 47620 or bs en 1366 part 4. tests are generally conducted with the barrier in a cavity between walls of fire resisting construction and performance with rain screen panels may be different do you see that there yes now that last
02:04:41 do you see that there yes now that last part of the wording uh is identical to that which we saw in the cwct
02:04:47 the cwct technical guidance note 73 yes very similar yes yeah so can we take it that cider eyes had um was it this way around taking on
02:04:59 um was it this way around taking on board the view of the cwct that performance in rain with rain screen panels may be different um
02:05:05 um i think it's uh bi-directional i think the cwct
02:05:10 the cwct take on board what we were saying and we were taking on board what they were saying
02:05:13 saying i see being present at this
02:05:18 conference and do you know whether at this conference any more information was provided to attendees about how performance with rain screen panels
02:05:30 how performance with rain screen panels might differ or was it just that broad statement um it was a presentation made um which i believe is still available on
02:05:41 which i believe is still available on youtube
02:05:43 youtube i see and then slightly further down that column if we can look at that column again
02:05:57 we can see
02:06:00 two paragraphs below the one we were just reading it says when the temperature does rise they may take a significant time to form a seal this time delay may not be significant in a test where the cavity is empty
02:06:11 in a test where the cavity is empty but may be significant in practice if there is combustible insulation in the cavity
02:06:16 cavity which could be ignited in the time taken to seal the cavity now again pausing there that wording is exactly the same as that which appears in
02:06:23 in cwct technical note 73 yes it would seem to be yes and then the presentation continues it says below that consequently the intumescent activation
02:06:35 consequently the intumescent activation and volume expansion are key properties as the time to full cavity closure is considered critical and note it says there the time to full cavity closure is considered
02:06:46 cavity closure is considered critical and then it says the lamitham cwrs
02:06:51 cwrs is designed to fully close the cavity in under two minutes in fire test conditions yes yes
02:07:02 so we can see it's representing that closing the cavity within two minutes would be sufficient to protect against the risk of combustible insulation yes well as we explored earlier on in the
02:07:14 well as we explored earlier on in the day
02:07:15 day our tests at this stage included combustible insulation above and below the cavity barriers the evidence is there from test reports that it does work
02:07:24 work and does protect the insulation above the cavity barrier well did you have that in 2012 this is november 2012 i think you may have had that slightly later than this
02:07:36 have had that slightly later than this in 2013 and 2014 was what we looked at earlier
02:07:40 earlier yeah and i now want to ask you about something called datasheet2110 um now you can take it from me that in 2013 siderise
02:07:54 2013 siderise was sending this data sheet to um harley um to harley curtin wall of at that stage um you can take it from me for example that on the 5th of august
02:08:05 for example that on the 5th of august 2013 ricky k of cider eyes emailed tim lovell of harley in relation to a project at 10 trinity square and this data sheet was attached and
02:08:16 and this data sheet was attached and then on the 19th of august ricky k also emailed mark harris of harley in relation to the wayland house project and again datasheet2110 was attached so it's a
02:08:27 datasheet2110 was attached so it's a data sheet that was being used by harley and sent sorry used by siderise and sent to harley in 2013. if we can go to that document now
02:08:39 2013. if we can go to that document now it's sil404672
02:08:48 and we can see that uh the heading of this
02:08:51 this is um lambeth cwrs curtin wall rain screen cavity barriers for rain screen cladding do you see that yes and it's
02:09:02 do you see that yes and it's data sheet two datasheet2110 are you familiar with this data sheet yes i am and did you technically review this data sheet to ensure that it was
02:09:13 this data sheet to ensure that it was accurate
02:09:14 accurate i would have at the time and we can see i want to look at the introduction this introduction session yes on the page and if we look on the right hand
02:09:25 page and if we look on the right hand column at the bottom we see in the final paragraph it says this
02:09:30 this lamithm cwrs has been tested by warrington fire research center wfrc in their opinion the product represents a practical
02:09:41 represents a practical fire cavity barrier solution for this particularly demanding condition
02:09:48 and we can see that um two warrington fire test reports are referred to in the next section we go down the page
02:10:02 in the middle column in bold there's specific test data referred to and that test data is the two tests that we've looked
02:10:13 data is the two tests that we've looked at
02:10:14 at the first two tests we looked at today from february 2007 and august 2010 yes yes now
02:10:25 yes now going back to that paragraph that i just read about x over warrington fire of wellington fire's opinion can we look back at that again top of the page
02:10:37 the page we've already looked at the documents stemming from those tests and nowhere does it say that the product represents a practical fire cavity barrier solution for this
02:10:48 fire cavity barrier solution for this particularly demanding condition i.e for rain screens can you help us what was the basis for claiming that this was warrington fire's opinion
02:10:58 opinion of your products the on the next on the section below there's two separate assessment documents
02:11:09 you've only preferred you've only referred to the test reports you haven't referred to the assessment document
02:11:15 yes if if we go below are you referring to the assessment reports
02:11:25 yes and that second assessment report dated the 20th of september 2011. again they're they're the ones we've
02:11:36 again they're they're the ones we've already looked at today yes yes yes
02:11:41 and nowhere and we can we'll go to that those assessment reports i can take you particular to the second one nowhere in those assessment reports does it say
02:11:52 in those assessment reports does it say that in the opinion of warrington fire the product represents a practical fire cavity barrier solution for this particular demanding condition does it
02:12:02 does it without reading the documents 100 front to back
02:12:05 to back i couldn't answer that question well you can take it from me that nowhere do we see that phrase and in fact what we see in those worrington fire assessment reports and i was careful to
02:12:17 assessment reports and i was careful to take you to them this morning were quite significant limitations of use
02:12:24 use again and again repeated in those assessment reports making clear that the the tests that had been carried out and the assessments that have been carried out were only applicable to the construction
02:12:37 were only applicable to the construction that was
02:12:38 that was being dealt with in those tests yes on the test reports yes and in fact let's look at that second assessment report
02:12:46 report this specific leak does touch on range screens and let's see what it says sil 50211
02:12:57 this is that assessment report 20th of september 2011 we go to page four
02:13:06 under rain screen we did look at it earlier today but i want to remind you of it
02:13:11 of it at the end of this page this report does not consider the fire resistance performance of the rain screen element or whether the fire spread may occur as a consequence of collapse or failure of the rain screen
02:13:23 or failure of the rain screen the approving authority or regulator should decide whether it is necessary for the rain screen to be fire rated whether it's of an appropriate construction whether separate tests or assessment evidence is necessary
02:13:34 assessment evidence is necessary now that is all that this report said about
02:13:37 about rain screen specifically so going back to the marketing material datasheet2110 now we go back to that again yeah and you
02:13:50 we go back to that again yeah and you were asking me to comment on non-non-technical marketing section technically i would review this
02:14:01 section technically i would review this from
02:14:02 from the tables of materials i wouldn't be i am not a marketer i'm not into marketing i wouldn't have reviewed this from a marketing perspective i see i would have reviewed the tables
02:14:14 i see i would have reviewed the tables of contents of fire ratings and void sizes etc etc can we agree that that's not an accurate statement of the opinion that warrington fire
02:14:26 of the opinion that warrington fire expressed in any of those tests or assessment reports that opinion could be expressed verbally i can't confirm that but if that opinion had been expressed verbally you would have known about it
02:14:38 verbally you would have known about it wouldn't you as technical officer beside her eyes
02:14:40 her eyes i did not write this test report like i said i've been asked i was probably i was definitely asked to review this technically technically i would review the fire redeems and the five performance i would
02:14:51 redeems and the five performance i would not
02:14:52 not review marketing
02:14:57 can we agree now sitting here today that that
02:15:00 that statement in their opinion the product represents a practical fire barrier cavity barrier solution for this particularly demanding condition that that is certainly not something that we see in any of the test reports
02:15:13 that we see in any of the test reports or assessment reports that we have looked at today i can agree it doesn't come up in any of the test reports the assessments but i cannot agree that it has not been discussed
02:15:24 has not been discussed in other areas so why not being party to discussions i see so are you saying that there were parallel discussions going on between your marketing department and between
02:15:37 your marketing department and between warrington fire about how those tests could be represented i don't know because i wouldn't have been involved in it if there were discussions i wouldn't have been involved in that it's not
02:15:48 have been involved in that it's not likely though is it that there were those parallel discussions and you not knowing about them surely you're the technical officer who's commissioned those assessment reports you confirmed that this morning yes but i i
02:16:01 yes but i i it is delegation this other areas i work on the technical aspect and the testing aspect of the business i do not work on marketing i'm not a marketeer
02:16:15 i see so your remit was solely to check the figures that were being quoted what in the tables in this marketing literature and not to look at any of the written
02:16:26 and not to look at any of the written statements that were being made that's generally what happens in technical reviews i already do the technicality of it but in those circumstances isn't
02:16:37 of it but in those circumstances isn't there a risk that what's being said in the marketing literature is technically inaccurate or misleading
02:16:48 is technically inaccurate or misleading i don't believe it is misleading i believe it was a genuine um understanding at the time i don't see that as misleading
02:17:01 i don't see that as misleading and you believe just to be clear you believe it's a genuine understanding because you think do you that there would have been some verbal statement by x over sorry by warrington fire
02:17:12 fire that was the origin of that statement yes
02:17:16 yes quite possibly and yet we don't see that written down in any emails or any documents that have been disclosed to the inquiry there's lots of discussions and lots of different levels right across the
02:17:28 different levels right across the industry in all levels um the it's been proven time and time again that cavity barriers function for the use within rain screen
02:17:40 function for the use within rain screen we have over hundred eight four one protests
02:17:43 protests on record and there was lion's share of those as you've said this morning there's only a handful carried out before grenfell these are all postgrad film the project
02:17:54 these are all postgrad film the project teams are now waking up to the fact that they have to demonstrate that the systems work for compliance we haven't changed what we do the facade
02:18:05 we haven't changed what we do the facade industry have changed what they do yes thank you i understand that but i i i'm
02:18:11 i'm i'm just seeking to get to the bottom of how a statement like that can have appeared inside a risers i can't answer it you can't answer that
02:18:23 and
02:18:27 if we look at page two of this data
02:18:36 sheet we can see in the table at the bottom right at the bottom there there is um
02:18:47 a number of statements made about the maximum void sizes for the products do you see that there yes well that's actually for the bracket
02:18:58 yes well that's actually for the bracket type
02:19:03 i see so where it says it's for use in voids
02:19:06 voids of between of up to 325 millimeters and 425 millimeters you're talking about the brackets are you and not the cavity
02:19:17 the brackets are you and not the cavity barriers themselves there yes because if you look on the left hand side it says bracket reference
02:19:29 we've looked at the express limitations that were in the warrington fire test reports and and um assessment reports for example
02:19:40 assessment reports for example it was clear that it they've been tested only between concrete elements and those limitations were spelt out in the report again and again can you explain why this
02:19:52 again and again can you explain why this data sheet doesn't spell out any of the limitations of the siderise testing that had been
02:20:00 undertaken um you if you look at any passive fire protection data sheets from any manufacturer anywhere across the world
02:20:11 world they do not relate back to that you're testing an element to give you that elements performance it is then for
02:20:22 that elements performance it is then for the fire engineers on the project to take on board all the fire resistant tests all the reaction fire tests all the bounding conditions to deem if the product is suitable for use or
02:20:33 if the product is suitable for use or not this is about the performance of the barrier in isolation
02:20:39 isolation it doesn't say anywhere within tesla it should be used to be using this this and this it is the responsibility of the fire engineer to take on board all the test evidence
02:20:50 to take on board all the test evidence from all the elements of construction to decide if the building is deemed suitable so are you saying if we go back up to page one where the test report
02:21:02 up to page one where the test report numbers are given
02:21:05 are you saying that it was incumbent upon anybody using this data sheet to i think it's in the section below we see the reports given to obtain copies of those test reports
02:21:17 to obtain copies of those test reports and
02:21:19 and work out from those test reports what the limitations were of the tests that had been carried out yes as free as are published on our website even now
02:21:28 even now we freely share our test data of the products yes but i think we share this we share this data even with the likes of our
02:21:39 with the likes of our come to us asking us for test data we supply them the test data they analyze the test data and then they make their assumptions and their analysis on the data we supply them
02:21:49 them yes i i understand that but but can you just explain i realize what you've said about what the industry generally does but why did cyderize choose not to set out any
02:22:00 did cyderize choose not to set out any of those limitations including the fact that they've been tested between concrete blocks and that the the test report made clear it couldn't verify the use of such barriers in any
02:22:12 verify the use of such barriers in any other configurations other than the ones tested
02:22:15 tested why is that not spelt out very clearly in this
02:22:18 in this type of data sheet in there it says test is using the principles of four scientific pathways en
02:22:26 en 1364 part four et cetera et cetera the reader need of anything needs to understand what the limitations or those test numbers are and it's known across the industry that
02:22:38 and it's known across the industry that passive fire protection generally is tested concretely concrete it's a normal fact the fire engineers nearby know about it barbara lane certainly was clear of it from the
02:22:49 certainly was clear of it from the meeting i had within 2014 they understand the fact that you were testing
02:22:54 testing a component to get the fire resistance performance of that component on its own it has no reflection on the fire performance of any other element
02:23:05 any other element of that construction let's look at another document just before we we break for the day mr chairman i'm um i'm doing reasonably well but i'm afraid i am going to go into tomorrow
02:23:17 i am going to go into tomorrow um but if i can just um look at another piece of marketing material before we break
02:23:23 break yes well that's right but let's not uh push it too far if we're going to come back tomorrow anyway i understand if we can look at sil five sil50227
02:23:42 this is a a marketing document entitled cavity barriers for rain screen cladding we can see from the top right hand side november it's dated november 2013
02:23:53 november 2013 issue one again are you familiar with this document um yes to a point when you say to a point d do you remember being asked to check the
02:24:04 remember being asked to check the technical content of this document i would have checked the tables et cetera
02:24:09 et cetera on that yes this is this is a a refreshing delivery of an older data sheet if we turn to the to page three of this document
02:24:21 document we can see text in the right hand paragraph at the top of the page it says this it says side of eyes have tested a range of horizontal cavity barriers to the above mentioned standards
02:24:32 standards with seal reaction times of one minute and steel temperatures remain below 180 degrees c
02:24:40 degrees c and maintaining the integrity requirements as detailed in table one
02:24:46 now um and and test report wf three two eight two seven nine a is referred to at the end there saying shows evidence of this we've already reviewed that test
02:24:57 this we've already reviewed that test report it was dated the 23rd of july 2013.
02:25:01 2013. if we can just briefly turn to that again sil 50212 at page 31.
02:25:20 if we look at the second paragraph down at the top there
02:25:27 we looked at this earlier but just to remind you in that report what it says is that
02:25:33 is that full closure of each cavity was deemed to occur between one minute and four minutes 38 seconds okay as as i previously went over with you there are many thermocouples on these
02:25:46 there are many thermocouples on these tests
02:25:47 tests if you actually scroll to the bottom of the page there's more of an explanation towards the bottom yeah
02:25:58 the bottom of this page here yes
02:26:04 so it says their test duration the test was discontinued for one of them at one 136 minutes then it says the failure criteria of each specimen was measured after the ventilated cavities had an
02:26:15 after the ventilated cavities had an effective seal by the means of the intermediate properties of the products and the findings was below one minute of the testing the suspended thermocouples reached their peak temperature
02:26:26 temperature and then at one minute as the peak temperatures indicate an effective seal had formed although not full developed to the full 75 millimeter depths
02:26:36 you actually need to finish reading point one because point one clearly states in there at one minute of testing suspended them cap has reached their peak temperature with shields a b and c not breaching the
02:26:48 with shields a b and c not breaching the asp requirements of 180 degrees so the suspended thermocouples have reacted they haven't risen above 180 degrees in the closing phase
02:27:01 above 180 degrees in the closing phase of things so they are they've closed effectively in the wrong the minute for less than a minute i see that's how you interpret that is it that they've that's how if if you
02:27:15 that they've that's how if if you have the time to go into the thermocouple numbers within this test report there are uh thermocouple graphs and thermocouple data and we can analyze
02:27:27 data and we can analyze that this test report is written by a test engineer at warren and fire yes i understand that but going back to the words earlier in the page what it says is
02:27:41 yes this is this is where we talked about it
02:27:46 we can't both talk at once what did you say mr moore okay let me let me finish this off
02:27:54 full closure is deemed to occurred between one minute and four minutes 38 seconds yes what that doesn't say is that the what that says that is full
02:28:06 is that the what that says that is full club
02:28:07 club that is the instrument has developed to the full
02:28:11 the full depth of the seal being tested if the seal is 75 millimeters in depth that the full depth of the 75 millimeters has been developed
02:28:21 developed yes but when you look at the requirements below right to the very bottom
02:28:30 bottom from the suspended thermocouples because this is a combination of thermocouple data and observation so a person having to observe this the thermocouple data has clearly shown
02:28:43 data has clearly shown that the seals reacted in less than one minute
02:28:46 minute because the 180 degree rise as set by the test guidance was not reached so the intumescent at the bottom of the sail has reacted to close the cavity
02:28:59 sail has reacted to close the cavity and introduced the integrity and insulation criteria for that and then over a period of one minute to four minutes through separate observations which we went into the report there's a section of
02:29:10 the report there's a section of observations themselves and a person the engineer would be making observation as to how that information is developed at the full depth of the sale so the 75 millimeters is 75
02:29:21 of the sale so the 75 millimeters is 75 for the 90 it's 90 for 120 120. yes i think i understand what you're saying i think you're saying that you can tell from the thermocouple data that a form of seal has occurred it's
02:29:34 that a form of seal has occurred it's reacted and and a form of seal has occurred within one minute of the testing yes but then it has taken just going back to the language at the top of the page
02:29:45 the language at the top of the page it has taken up to four minutes 38 seconds for full closure to occur are you the whole depth of the cavity barrier to see yes but the
02:29:55 but the insulation integrity criteria was restored
02:29:59 restored in less than one minute because the thermocouples have measured that yes i understand that but going back to the statement made in your and if we go back to the product literature
02:30:11 if we go back to the product literature we were looking at page three of sil
02:30:16 50227 you talk there about steel reaction times of one minute and i appreciate it says seal reaction times but why not state in there clearly that in terms of
02:30:29 state in there clearly that in terms of fully closing the cavity that was deemed to occur between one minute and four minutes 38 seconds because the insulation attack and integrity criterion
02:30:40 integrity criterion was reestablished within the one minute the seal reacted the fact that it developed further into medicines don't stop developing there they
02:30:54 developing there they naturally replenish themselves they continually develop through the duration of the fire test so at the start of the test at time zero the suspended thermocouples are at
02:31:05 the suspended thermocouples are at ambient air temperature they did not rise above 180 degrees and seeded within the minute so therefore the insulation and integrity criterion that's set
02:31:16 and integrity criterion that's set in en 1363 part one or even bs4 centric is reintroduced at that point this is an observation in the test that it continued to grow
02:31:28 in the test that it continued to grow through that period of time and i wonder whether that's a good point scrange yeah so exactly that's what i was about to say but i think if i understand mr mort correctly what he's drawing his distinction between is the
02:31:41 drawing his distinction between is the creation of a seal which he says occurred very quickly and the complete development of the intermission into messengers which takes longer
02:31:52 into messengers which takes longer yeah okay we're going to stop there for the day mr morton i'm afraid i think miss grange has some more questions for you do you miss grange i do because i still need to cover some specific questions in well there's more
02:32:04 specific questions in well there's more a little bit more on the marketing material and then i have to ask some specific questions about the gwenfield project but i will review those overnight
02:32:12 overnight and i will try and do them as quickly as i can tomorrow morning yes now i'm sure that mr mort would like to have some idea of when he can finish this exercise can you give us any help on that
02:32:23 help on that yes i would hope that we would be substantially finished by the first break there or thereabouts well let's make an effort to finish him by the first break then well mr vaught
02:32:34 by the first break then well mr vaught i'm i'm very sorry that we have to ask you to
02:32:36 you to make yourself available again tomorrow i think you may have been warned that that might be the case it's understandable it's not a problem all right well thank you very much anyway we're going to break now um please remember what i said to you
02:32:48 um please remember what i said to you earlier it's very important that you don't discuss your evidence or anything related to it with anyone else at all over the break and we'll resume at ten o'clock tomorrow
02:32:59 and we'll resume at ten o'clock tomorrow morning
02:32:59 morning okay thank you look forward to seeing you then thank you very much bye
02:33:08 you