Siderise Evidence - Tuesday 9th March 2021 (1/2)

Full transcript

00:00:07 good morning everyone welcome to today's hearing we're going to begin today by hearing further evidence from mr christopher mort of siderise so my first task is to check

00:00:18 of siderise so my first task is to check that mr mort is with us and that he can see me and hear me clearly good morning mr mort

00:00:24 mr mort good morning yes i can good thank you very much well as usual i'm here today with

00:00:30 with my fellow panel members miss istafan and mr akbar

00:00:34 mr akbar good morning good morning and before we uh resume your evidence mr mort i think i'd better take you through the usual

00:00:46 better take you through the usual so to speak can you confirm that you're alone in the room from which you're giving your evidence yes i can thank you can you confirm that you have no documents or other materials with you

00:00:59 no documents or other materials with you yes i can thank you very much and can you confirm that your mobile phone is in another room and that you don't have any other electronic device with you that's capable of receiving messages

00:01:10 you that's capable of receiving messages yes i can thank you very much well the procedure today is going to be the same as it was yesterday your legal representatives again are in the virtual hearing room

00:01:22 virtual hearing room um we will have a short break during the morning i'm not sure whether we will have finished your evidence at that point or not but again the arrangements will be the same

00:01:33 again the arrangements will be the same as they were yesterday is there anything you'd like to raise before we start um no that isn't good very well thank you very much in that case i'm going to invite the stranger to put some more questions to

00:01:45 stranger to put some more questions to you

00:01:46 you yes ms grange when you're ready yes thank you mr chairman uh good morning mr mort

00:01:51 mort good morning when we broke off yesterday i

00:01:54 i was asking you some questions about the cider eyes marketing literature and i have a few more questions on that topic before we turn to some of your specific involvement in the grenfell tower project

00:02:07 the grenfell tower project can we return to a document uh at sil50227

00:02:13 sil50227 this is the ciderised brochure entitled cavity barriers for rain screen cladding dated november 2013 which we were looking at yesterday

00:02:26 so there's the the front page we can see the date in the top right hand corner and i want to go back to page three now and um

00:02:38 now and um look at that paragraph there on the right hand side in the black text now i asked you about the the seal reaction times of one minute but i now want to ask you something else about that paragraph we can see that it says

00:02:51 that paragraph we can see that it says that sidewise have tested a range of horizontal cavity barriers to the above mentioned standards with c or reaction times of one minute and seal temperatures remain below 180 degrees c and then it says and maintaining the um

00:03:05 and then it says and maintaining the um integrity and insulation requirements that that's what e i stands for isn't it integrity yes as detailed in table one for up to 120

00:03:16 120 for integrity and 60 for insulation and then we can see in table uh one can you see that first product there the horizontal barrier for 120

00:03:28 horizontal barrier for 120 and 90. yes um and under thickness millimeters it says 15 by 75. does that mean it's actually 1.5 by 75

00:03:40 does that mean it's actually 1.5 by 75 that's the intermessage on its own right so the intermediate strip is

00:03:45 strip is one point five times 75 five minutes right i see yes so um we can see it saying there very clearly that these

00:03:56 clearly that these barriers can go up to 120 minutes integrity and we look at the report that's referred to there there is a test report with a number 328 279

00:04:07 report with a number 328 279 can we go to that report again sil

00:04:12 50212 and i want to look again at page 31

00:04:21 and we get the integrity results at the top of that page in the table now we can see from this table that only specimens

00:04:30 specimens a and d have achieved the integrity requirement of 120 do you see that

00:04:37 see that that's correct and that refers to the 120

00:04:41 120 product in the table of the data sheet yes um so specimen a was 120 millimeters thick

00:04:49 thick specimen d was a graphite in tumescent specimens um b and c were 90 millimeters thick and 75 millimeters thick respectively can you just help us as to why even

00:05:02 can you just help us as to why even though only two of those have got over the 120 uh why are the results in b and c not reflected in the marketing literature they are if you go back to the table and

00:05:14 they are if you go back to the table and go back to the marketing literature and read the paragraph again it says performances up to 120 minutes right table then it has in there for

00:05:25 right table then it has in there for products b and c 90 minutes integrity i see okay so you're satisfied are you that they're

00:05:32 they're comfortably within those limits yes yes okay

00:05:36 okay now um this document that's uh entitled cavity barriers for rain screen cladding

00:05:44 cladding if we go back to page one of that document sil50227

00:05:54 so that's its title cavity barriers for rain screen cadding it's right isn't it that nowhere within this document or any similar marketing literature uh has cideris expressly stated that

00:06:06 has cideris expressly stated that those barriers have never been tested as part of a rain screen system but have only ever tested been tested between concrete lintels that's not made clear

00:06:18 concrete lintels that's not made clear is it i'm

00:06:20 is it i'm not in this context no but as i explained

00:06:25 explained yesterday testing cavity barriers on the furnace test the temperatures are higher on the furnace than the failure criteria for an eight for one for so therefore cavity barrier would not be

00:06:36 so therefore cavity barrier would not be the weak

00:06:38 the weak uh component within an eight four one four test

00:06:41 four test yes i i i understand that's your evidence i think the discussion yesterday on the 25 millimeter air gap and the panel movement um i think it needs to be

00:06:52 needs to be understood that the intumescent at 1.5 thick has an expansion coefficient of 25 to 1. so it will expand to 37.5 millimeters

00:07:06 so it will expand to 37.5 millimeters so it's over engineered for 25 millimeter gap yes i understand you're saying that about the cavity barrier but this is um a document that is entitled cavity

00:07:18 um a document that is entitled cavity barriers floor rain screen cladding and i just wanted to be clear on the point that in this document it does not state

00:07:27 state i appreciate you say the reasons why that is but it doesn't state that the barriers have been tested between concrete lintels and not with a rain screen barrier on the

00:07:39 with a rain screen barrier on the outside

00:07:40 outside as i said yesterday this document contains

00:07:45 contains the reference to the test reports we frequently supply data sheet and the test report to the end user so they get the full picture

00:07:56 they get the full picture yeah now let's just look at another document now this is ryd303992

00:08:05 this is a another siderise document

00:08:10 from march 2015.

00:08:14 sorry no ryd three zero three nine nine six two and that's got four zeros the one on the page

00:08:26 zeros the one on the page ryd three zero three nine nine six two yes so this here's a document from march 2015. you can see that it says version 1.4 march 2015 in the top right hand side

00:08:38 top right hand side and this is uh entitled cyber eyes horror rh horizontal and rv vertical cavity barriers for use in the external envelope or fabric of buildings

00:08:49 fabric of buildings and at the top we can see in the the part with the picture facades horizontal and vertical cavity barriers four rain screens and if we go on to page three we have

00:09:08 and if we go on to page three we have some similar text to that which we saw in the document we were just looking at on the right hand side and i'm not going to ask you about that yet again we've gone through those points but i want to ask you about

00:09:19 points but i want to ask you about some text about the 50 millimeter air gaps on the bottom right hand side there side rise rh 50 open state horizontal cavity barrier for maximum 50 millimeter air gaps do you see that paragraph

00:09:31 air gaps do you see that paragraph yes and if we could just go down the page so we can see the text underneath it says their siderise have tested a range of horizontal cavity barriers with 50 millimeter air gaps to

00:09:43 barriers with 50 millimeter air gaps to the above mentioned standards with seal reaction times of less than one minute and here it says full closure at two minutes 22 seconds

00:09:54 minutes 22 seconds so um you are using a full closure figure at this point in in the marketing literature yes this is a different void size and a different type of

00:10:05 void size and a different type of intumescent so that is being used in 25 millimeters so therefore the reaction times are different yes i understand that and i'm going to take you to the report that this is based on i understand it's based on

00:10:16 is based on i understand it's based on different

00:10:17 different products and different tests but i'm just pointing out that here you have we had a debate yesterday about seal reaction times here what you have done is refer to a full closure time of two minutes 22

00:10:29 full closure time of two minutes 22 seconds yes i believe that is a copy of the text that's within the test report yes let's look at that now if we look at that it's the bm trader test report it's a sil 50288

00:10:44 it's a sil 50288 page 18.

00:11:00 yes so this is a table that we looked at yesterday

00:11:03 yesterday and um the i think the two minutes 22 seconds comes at the bottom of that page in relation to the time it took for the cavity to seal for cavity barrier a yes

00:11:17 cavity to seal for cavity barrier a yes yes now can you help us so cavity barrier a was a 50 millimeter gap but cavity barrier c was also

00:11:29 but cavity barrier c was also a 50 millimeter gap and you can see if you look at the it's it's that's helped we can see in the table

00:11:35 the table it's signified by two hashtags and the two hash symbols below show that that cavity was sealed at three minutes 19 seconds

00:11:47 three minutes 19 seconds now can you help us as to why it's the two minutes 22 seconds that's in the product literature rather than showing a range of 2 minutes 22 to 3 minutes 19.

00:11:58 22 to 3 minutes 19. well if you go back to the product descriptions in this test report you'll see there's different types of quantities of intumescent in that image right

00:12:08 right that is the reasoning why i see so you're only advertising the product that meets the two minutes 22 seconds is that what you're saying is the only that is the product we're using for manufacturer yes right and

00:12:20 using for manufacturer yes right and you're not using the one that's sealed at three minutes 19 no right okay as i explained yesterday these are r d tests where you put multiple

00:12:32 d tests where you put multiple variations of a product on a test to get the optimum result i see um and then um

00:12:43 um and then um just moving away from the marketing lecture now but before we go to your grenfell

00:12:47 grenfell uh project work can we just look at a document from january 2015 sil 406559

00:12:57 this is an email chain relating to a belfast hospital project and if we look in the second email down in the chain

00:13:10 in the chain we can see on the 19th of january 2015 kelvin williams uh that's a sidewise employee yes he was yes yes says to barnaby carrick

00:13:23 he was yes yes says to barnaby carrick he's also with insider eyes he says hi bar and he attacked is referring to an email and he says this he says in the second

00:13:34 and he says this he says in the second paragraph chris m issued a statement that all requests for these products would have to be okay by him

00:13:44 now um can you recall what that statement was and what products that have been okayed by you yeah if you if you look at the subject title yes belfast hospital msds and technical

00:13:57 yes belfast hospital msds and technical data sheets i at the time we were looking at resource level within the business as to how often we have these inquiries directly through

00:14:09 we have these inquiries directly through to us to supply data sheets and msds information to a customer

00:14:15 customer as opposed to our website yes and what does msds stand for material safety data sheet yeah so it's basically a uh i was keeping a

00:14:27 so it's basically a uh i was keeping a tally

00:14:27 tally on the number of times this was happening right on the number of times that you had to supply data sheets to customers on projects yeah whereas as opposed to our downloads yeah and why were you keeping that tally

00:14:39 yeah and why were you keeping that tally what what was it like i said to literally two seconds ago it was to

00:14:44 it was to understand any resource in level we needed within the business for that part of the works i see so you could understand that you might need to make resources available to provide technical support

00:14:55 support for those products for those projects for the product generally

00:15:02 i understand let's turn now to the grenfell tower refurbishment project specifically and we if we can start with an email at sil six zeros

00:15:13 an email at sil six zeros through 30

00:15:24 this is an email um it's if we can blow it up a little it's uh from kevin lamb

00:15:31 lamb to barnaby carrick at siderise and it's sent on the 11th of march 2015 and we can see that mr lam asks further

00:15:42 and we can see that mr lam asks further to your recent help with horizontal and vertical fire breaks within our rain screen cladding we wonder if you could assist with what would be the normal fire rating required

00:15:54 would be the normal fire rating required and then he goes on the building is a domestic block of flats 24 stories fully over clad with acm rain screen cladding internal party

00:16:05 rain screen cladding internal party walls will be 120 minutes in your experience what would the rating be for horizontal and vertical breaks this would help us to propose hopefully the correct product for

00:16:16 hopefully the correct product for building control to approve so we can see that kevin lam who was is working for harley at this point is asking for advice from siderise on those questions

00:16:29 siderise on those questions and we can see that this query is forwarded to you on the same day if we look at sil six zeros 34

00:16:46 so we can see that on the same day the 11th of march 2015 mr carrick emails you and he said and it

00:16:57 mr carrick emails you and he said and it it says regarding harley curtin wall limited

00:17:00 limited and he says hi chris please could you check if the following response is suitable and then he sets out a response

00:17:08 response a suggested draft response we would confirm that to meet the requirements of approved document b diagram 33 and table a1 item 15 the area between the compartment wall and outer cladding

00:17:18 cladding needs only to be a cavity barrier 30 minutes integrity and 15 minutes insulation which would mean that our open state cavity barrier system and then you give the name of the system the 90 30 and the 30 30

00:17:32 the 90 30 and the 30 30 so 1930 for the horizontal barriers and the 30 30 for the vertical barriers would be suitable now can you recall receiving that email with mr lam's query i can yes

00:17:49 can you help us as to um what mr lam was referring to when he says that cider eyes had provided him with recent help with horizontal and vertical fire breaks

00:18:00 breaks can you help us as to what help cider eyes had already provided um i have had no um interaction with harley

00:18:11 um interaction with harley really prior to this i believe there was a previous project where we had supplied some current qualifier barriers on um generally um

00:18:22 um generally um ricky k who is extremely experienced in this

00:18:25 this part of the sales would be given um advice based on what's contained within the data sheets so there may have been some of that going on um

00:18:36 going on um from our email chain we have no direct correspondence prior to this this on the project

00:18:42 project so you can't help us um i mean we'll be hearing from mr k is the next witness you can't help us as to what advice harley had been uh sorry cider eyes had been providing up to that point no

00:18:53 to that point no no um and we can see that at this time you were made aware from mr lam that grenfell was going to be clear overclad in

00:19:01 in acm rain screen cladding do you remember noting that at the time no yesterday in your evidence you said for the transcript this is at page 73

00:19:13 for the transcript this is at page 73 day 102

00:19:15 day 102 that you weren't aware of what panels were used on the grenfell project now having seen this email exchange can we agree that in fact you were made aware that this

00:19:27 in fact you were made aware that this was

00:19:27 was acm rain screen cladding at the time in the context of that email i may have read it

00:19:36 read it but i was more reading the response from barnaby

00:19:41 yes but in checking mr carrick's response presumably you would have read the request in the first place otherwise you wouldn't have been able to help but the ac

00:19:49 the ac the atm isn't clarified as to what it is as in what performance standard no i understand what grade it is or anything yes i acknowledge it's an acm

00:20:01 anything yes i acknowledge it's an acm but there is no grade against that acm yes but you knew at the time that it was an aluminium composite material rain screen cladding panel

00:20:09 panel yes yes were you ever told what type of insulation was going to be used at grenfell tower no did you ever think about asking for

00:20:20 no did you ever think about asking for that

00:20:20 that information as part of um providing mr lam and harley with advice on the project

00:20:27 project if you look at my further emails where they've asked for further information i've asked them categorically for specifications for fire strategy etc which they failed

00:20:38 for fire strategy etc which they failed to produce yeah we'll come on to those emails in just a moment um if we now go to your response to mr lam's query on the 12th of march 2015 if we can go to sil

00:21:00 6038 so here we can see you email mr lam on the following day 12th of march 2015

00:21:11 on the following day 12th of march 2015 copying in mr carrick and others at siderise

00:21:14 siderise and effectively you you have adopted mr carrick's suggestion yes um i believe the situation was kevin lam chased for response barnaby was

00:21:25 was either out on business or annual leave so then

00:21:29 so then you afforded his response yes and and in this email you've confirmed that to meet the requirements of approved document b the area between the compartment wall

00:21:40 the area between the compartment wall and outer cladding needs only to be a cavity barrier 30 minutes integrity and 15 minutes insulation which would mean that your open state cavity barrier system would be suitable yes yes are you advised on the suitability

00:21:52 yes are you advised on the suitability of your system uh given the request that was made and you um

00:21:58 you um you say below that if you need to cut if you need me to comment on a specific detail please forward over and i will respond immediately you apologize for the delay and you also attach diagram 33

00:22:09 attach diagram 33 so that they can see that below and we can see from page seven of this document run that diagram 33 has been provided by you at that time

00:22:22 provided by you at that time and you've also provided some standard details some sideways standard details if we look for example at page five you provided some standard details relating to the side of eyes products

00:22:33 relating to the side of eyes products yes

00:22:34 yes yes we can see on the right hand side in the label to that drawing it's headed sideways standard details compartmentation now you did not in this email

00:22:48 now you did not in this email say anything about the suitability or risks

00:22:52 risks associated with using cavity barriers in conjunction with acm rain screen cladding that's right isn't it that's correct can you explain why not

00:23:03 that's correct can you explain why not why not identify those risks when you were responding at this time and we were responding as to the suitability of the product for use within

00:23:14 product for use within a common uh construction environment um the checks on the cladding suitability et cetera et cetera and not the responsibility of sideways that's the

00:23:26 responsibility of sideways that's the responsibility of harley kurt mullin and the fire engineer and the approving authority on the project

00:23:33 you didn't explain that your cavity barriers had only ever been tested between concrete lintels and not in an acm system why was that

00:23:47 we test to the published standard we are not it's for under the cdm regulations the designer of the project is responsible to understand

00:23:58 responsible to understand the overarching uh regulations required they should understand the requirements of approved document b

00:24:08 and the testing for cavity barriers is in compliance with appendix in the table in the linux item 15 counterparts 3015 the overall wall section in section 12

00:24:21 the overall wall section in section 12 of approved document b is the responsibility of the facade contractor and the end users it's not we don't supply the panels

00:24:32 supply the panels why couldn't you have said for example something along the lines of do bear in mind that if the acm cladding fails the cavity barriers will be ineffective

00:24:43 ineffective and we have only tested our cavity barriers in these limited scenarios why didn't you spell out that in your response at that stage we won't be asked that question asked answer this specific

00:24:55 question asked answer this specific question

00:24:57 question yes but wouldn't that be information that it would have been helpful for the design team to be aware of but the design team under the cdm regulations should be aware of that situation anyway

00:25:09 should be aware of that situation anyway it's not our responsibility to enforce the cdm regulations yes yesterday i showed you parts of dr lane's report where she identified the potential mechanism of failure of cavity barriers

00:25:21 failure of cavity barriers when used in combination with acm or other metal cladding panels and you accepted that in general terms the risks about the way in which these cavity barriers might behave

00:25:33 cavity barriers might behave in combination with rain screen panels was appreciated by siderise prior to the grenfell project and for the transcript that

00:25:41 that you said that at page 121 yesterday day 102

00:25:46 102 and you said it was for that reason that cider eyes had called out and and requested partners to undertake more

00:25:53 more testing in conjunction with sideres yes now given your awareness of the risks associated with this combination of cavity barriers in and

00:26:04 in and rain screen panels um why not spell out this risks at this time to the professionals on the grenfell project it's the responsibility of the professionals on the grenade project

00:26:17 professionals on the grenade project to understand this under the cdm regulations yes we are not the designers of the project we did not supply the panels but aren't you in a unique position as a manufacturer of these barriers you have

00:26:30 manufacturer of these barriers you have very detailed knowledge of exactly what testing you've done the limitations of that testing what testing you would like to do in the future in order to better understand

00:26:41 future in order to better understand how it performs in other systems real world systems given you've got that particular unique knowledge

00:26:50 knowledge why not spell out more clearly to the professionals on this project that there were risks associated with using these barriers in this context

00:27:01 using these barriers in this context there

00:27:01 there should and there were people of a higher level

00:27:05 level than ourselves on this project like the fire engineers the architects the consultants the building control etc etc who have been through the approval process

00:27:16 approval process for these panels it's not for us to question the approval courses for those panels

00:27:22 panels we only manufacture and supply our barriers yes i mean we know that um around a year before this in march 2014

00:27:33 around a year before this in march 2014 you'd met with celetech so we spoke about this yesterday and you were advising

00:27:37 advising jonathan roper that it was very important that these barriers have a solid surface or i think in your words they're hard bound to activate against you were spelling that out to celetex

00:27:49 that out to celetex why not identify that clearly to the grenfell professionals when they're seeking your advice about the suitability of your barriers on their project okay

00:28:00 of your barriers on their project okay i'll come back to what i just said under the cdm regulations and the project there are people on that project who are contracted to approve and control the process

00:28:13 approve and control the process we supply one component into that process

00:28:17 process the overall approval for the panels that project were not our responsibility yes i i understand that um to put it another way um if you're providing a product

00:28:30 um if you're providing a product into a construction system and you know that there's a risk that it's not going to work well with another project product that you are aware of you're told about why isn't it reasonable for you to

00:28:44 why isn't it reasonable for you to point out that your barriers aren't going to be effective if used in combination with that product

00:28:51 again i'll come back to the same point sideways are not responsible for the design of the project we have to assume that others

00:29:02 we have to assume that others at a higher level within the project so the fire engineers the approving authorities have done their due diligence and proven that the panel is going to be used on the project are suitable for using the project that

00:29:14 are suitable for using the project that is not sideways responsibility we're not contracted to do that

00:29:20 do that we give advice on a free basis we're not contracted to give advice we give advice on a free basis yes okay to your knowledge can you help us

00:29:31 knowledge can you help us was this the first time that cyderize had been contacted about a project involving acm cladding or had siderise supplied cavity barriers

00:29:42 or had siderise supplied cavity barriers open state cavity barriers on projects where acm cladding was being used before this

00:29:50 our emails have been scrutinized and passed over to the inquiry we cannot find

00:29:55 find another inquiry that contains the words atm however we supply we were supplying material at the time through third-party distributors as well

00:30:08 through third-party distributors as well we could have been supplying materials to projects i had atm on nice we're a manufacturer carrier we do not see the end use of every project even now we don't see the end use of every project

00:30:19 see the end use of every project yes but that's helpful i think what you've confirmed is so far as you can ascertain

00:30:24 ascertain and i appreciate you may have been using third-party um distributors so you wouldn't always know but so far as you can ascertain you can't see evidence of cider eyes providing their cavity barriers on a

00:30:36 providing their cavity barriers on a project involving acm before this point yes

00:30:39 yes i cannot see technical queries come through now yeah okay let's move forward in time now to the 30th of march 2015. if we can go to sil 6068

00:31:02 this is an email from ricky k of cider eyes

00:31:06 eyes to to you on the 30th of march 2015 and what he's done is he's pasted into this email a communication from john hoban of rbkc

00:31:18 a communication from john hoban of rbkc building control which had been sent to harley studio e and others ryden on the project and we can see that mr hoban is saying in his email if we

00:31:31 mr hoban is saying in his email if we look at the main paragraphs he says please find details below a copy of an email sent to various persons on the 20th of march 2015 concerning the topic relating to firestopping of the

00:31:43 topic relating to firestopping of the compartment floors to the building i would advise you that is my interpretation of diagram 33 of approved document b is that the detail between compartment floors and the external cladding is not

00:31:55 floors and the external cladding is not a cavity barrier therefore it must be fire stopped to at least the standard of the existing compartment floor 120 minutes therefore the methods described in clause

00:32:06 described in clause 9.13 would not be appropriate in this particular case so that that's you can see what advice the building control officer was giving and that's been sent to you

00:32:17 and that's been sent to you now mr k sends this to you with no covering email can you recall speaking to him about it around this time quite possibly do you have any recollection of what you discussed

00:32:29 recollection of what you discussed no now um you deal with this email in your witness statement if we can just look briefly at that um so back to your statement and page five paragraph 25

00:32:45 and you say here you say i believe that mr hogan was confused between the requirements of a fire stop and cavity barrier

00:32:52 barrier this is still an ongoing misinterpretation of approved document b to this day i still get professionals requesting 120 minutes fire resistance despite having

00:33:03 minutes fire resistance despite having explained to them that on testing to bs8414 part 1 or part 2 the maximum achievable is 30 minutes due to the duration of the test regardless of the performance of the

00:33:14 regardless of the performance of the cavity barrier the facade is always the weak

00:33:17 weak link in this respect although diagram 33 of approved document b details the requirements some professionals choose to ignore this diagram and still request that the fire resistance of the

00:33:29 request that the fire resistance of the barrier should meet with the fire resistance of the floor i.e 120 minutes however installing 120-minute fire barrier is not required and will not increase the performance of the cladding element so

00:33:40 element so you give your explanation there um as to why you think mr hogan was confused uh at this point

00:33:51 confused uh at this point um just going back to the main part of that paragraph on the previous page

00:34:00 i i i think you've made this point already but can you explain why you're referring to 8414 testing there and the maximal achievable of being 30 minutes due to

00:34:11 achievable of being 30 minutes due to the duration of the test why are you referring to that in this context

00:34:16 context because you it's you're looking at a system performance overall and the weakest link in the system performance is not the

00:34:28 in the system performance is not the cavity barrier the cavity barrier is are not magic who 20 as we discussed yesterday if you have for example a

00:34:40 if you have for example a fire door tested for two hours and you install it into a wall that is one hour

00:34:47 one hour the weakness is not the fired up the weakness is the wall so therefore the performance of the door although it's proved for two hours is reduced to one hour and that's exactly the same in this situation

00:34:59 exactly the same in this situation if you've got uh you can install 120 minute

00:35:03 minute five barriers yeah on test they will give you 120 minutes on a furnace test but if you put them into a system test they are not the weak link the weak link are other elements

00:35:14 are other elements and the maximum achievable duration of the test is 30 minutes because it's a 30-minute test yes did you ever

00:35:21 you ever explain this um to the professionals on the grenfell project who was seeking your advice from time to time did you ever explain the facade is always the weak link

00:35:32 always the weak link and you explain this link back to the 8414 test and why uh why it was that part of the system that they really needed to be focused on rather than the cavity barriers

00:35:43 rather than the cavity barriers unless there's an email i haven't

00:35:48 and um in terms of why you've not raised those limitations can we refer back to the answers that you just gave a moment ago when i was asking you why you never raised these risks with the professionals on the ground

00:35:59 the professionals on the ground it comes back to we haven't got no design responsibility on the project we are not contracted for design there's fire engineers there's consultants there's architects there's a proven authorities they are the ones who are responsible

00:36:12 they are the ones who are responsible for the project now you say at paragraph 26 of your witness statement on page six we don't need to go to it that it's likely that you spoke to mr k about this email although you're

00:36:25 k about this email although you're not able to specifically recall does that remain the position that you can't recall

00:36:31 recall specifically discussing this with mr k although you think you probably would have done

00:36:36 have done correct we can see moving forward with the documents if we go to sil 6070 that mr k responded to mr hoban's

00:36:48 that mr k responded to mr hoban's email

00:36:52 and this picks up on something you were mentioning earlier that ricky k goes back in this email to ben bailey

00:36:59 bailey john hoban and he says uh this is the 30th of march 2015 dear or please can somebody forward over a drawing of the build build-up of the cladding so that my technical officer can evaluate and forward an official

00:37:11 evaluate and forward an official response with a siderise product specification um and when he's referring there to my technical officer is that you that he's referring to yes he is yeah

00:37:25 and so it's right isn't it that you considered that you needed a drawing of the overall build-up in order to provide an official response from sidereel's yes yes

00:37:35 yes and if we now turn to um the response to this

00:37:41 har404006

00:37:49 so we can see from this that on the 30th of march

00:37:52 of march 2015 ben bailey of harley responds to ricky k copying in kevin lam and mark stapley

00:38:03 copying in kevin lam and mark stapley for harley and he says please see details attached showing the section through the system and general location of fire breaks relative to window frames

00:38:14 of fire breaks relative to window frames in the cladding zone best regards ben and then we can turn to the drawing that he attached or the foot the first drawing this is

00:38:30 har404008

00:38:34 and um yes just a note in that covering email

00:38:38 email um that mr bailey was talking about see the attached showing this section through the system and the general location of fire breaks relative to the window frames in the

00:38:49 relative to the window frames in the cladding zone and this is what he's attached

00:38:52 attached yes yes

00:38:55 yes yes at this time and you say in paragraph 28 of your statement you say we don't need to go to it that you weren't copied into this email however it was either forwarded to you or shown to you as you then marked up

00:39:07 or shown to you as you then marked up this drawing requesting three sections which you labeled as a a b

00:39:12 b b and c c so so that's the drawing and we can see the fire breaks on it the horizontal ones below and the vertical ones on the column yes to the

00:39:24 vertical ones on the column yes to the sides

00:39:25 sides and then if we turn to the next document in the run

00:39:33 ryd3037412

00:39:36 ryd30 37412

00:39:45 we can see that ricky k has um responded to ben bailey saying to enable us to assess please see attached markup of section drawings that are required by my technical officer

00:39:56 technical officer and if we turn to the markup this is

00:40:01 ryd3037413

00:40:09 and if we could blow that up what we see is some red pen annotations on this drawing where you've identified three sections section a a b b and c

00:40:23 section a a b b and c yes can you see those yes and and is this your writing yes it is and and you've indicated that we can see from the label there that you want section a a

00:40:34 want section a a going through the cladding you want section bb going through the sill and you want section three three showing that total section so you can see the whole thing yeah

00:40:56 and um

00:41:00 if we turn now to mr bailey's response to this request for sections this is a har

00:41:07 har three zeros one nine four zero one

00:41:20 three zeros one nine four zero one we can see that ben bailey responds on the 30th of march 2015 to ricky k and copies you in ricky as discussed the two drawings attached represent section a a window head and bb window sill which

00:41:33 a window head and bb window sill which can be

00:41:34 can be combined to create cc as we don't have a drawn detail to cover crop what chris is requesting do you see that yes

00:41:46 do you see that yes and um

00:41:51 did that strike you as odd that they couldn't give you the combined section cc they were only going to give you the window head and the window sill detail separately but not the whole

00:42:02 detail separately but not the whole section

00:42:03 section yes from me i would've expected to see section cc because it gives you the full picture of the makeup yeah and on other cladding products

00:42:14 cladding products projects if you'd requested that would you have normally been provided with that

00:42:19 that it's normal standard construction process yeah

00:42:27 and and was it sufficient i mean mr bailey's indicating here that it would be sufficient simply to imagine combining these drawings to create cc

00:42:36 create cc was that sufficient in your view um with my experience of because i'd get more design i could combine the two right to understand what was going on

00:42:47 right to understand what was going on although section cc would have clarified it

00:42:50 it yeah were you ever given any explanation as to why harley couldn't provide that um full section drawing to you

00:43:02 and we can see um that in these emails people have been referring to fire breaks as opposed to cavity barriers or fire

00:43:14 as opposed to cavity barriers or fire stops it

00:43:16 stops it was it common in the industry at this time for people to be referring to fire breaks as opposed to using the technical definitions in adb it's still common today

00:43:29 it's still common today you people do not use the correct terminology they mix up cavity barriers with fire stopping

00:43:37 stopping they call them smoke stops they call them fire breaks yes it's common errors yes in your experience does that sometimes have the potential to cause confusion

00:43:50 have the potential to cause confusion to professionals working on projects if they're not using the correct language for those items of construction um

00:44:01 it depends on how they caveat the definition of fire break if they say it's a 30 minute fire break then generally people in the passive high protection know about the 30 minute

00:44:12 high protection know about the 30 minute cavity barrier yes i see

00:44:17 yes i see now um if we go then to look at paragraph 30 of your witness statement at this point on page seven

00:44:32 what you tell us here is that you therefore you proceeded based on the information that you've been provided with by mr bailey and you say although i believed mr hobin to be confused as to the requirements as

00:44:44 to be confused as to the requirements as explained above as ricky heck k had already explained the requirements of approved document b and this appeared to have been rejected i proposed a solution to meet with the higher fire resistance that mr hoban was

00:44:56 higher fire resistance that mr hoban was requesting and then um if we can turn to the email that you

00:45:01 that you sent with that proposed solution this is

00:45:06 har3018971

00:45:16 this is an email that you sent to mr bailey ben bailey and to ricky k on the 30th of march 2015.

00:45:26 and you say in the first paragraph i've reviewed the drawing sent over and sketch a proposal to alleviate the issues raised by the building control officer that that's what you mean by bco yes yes

00:45:38 yes yes also on the second page of the attachment i've highlighted the weak link so to speak in terms of fire and i think the bco would have noticed this now we'll come back to that weak link in a moment

00:45:47 a moment you say this in the second paragraph you say the proposal requires the installation of a horizontal 90 60 product in two layers one at the head of the

00:45:59 in two layers one at the head of the window aligning with the compartment floor and the other at the top of the existing

00:46:03 existing up stand therefore two layers of 60 minutes protection that overall would provide

00:46:08 provide if tested over 120 minutes protection at the window locations now is that paragraph effectively describing that doubling up

00:46:20 that doubling up option that you were proposing uh as part of this email yes and it's the in approve document b there is

00:46:32 in approve document b there is a requirement to if needed for the compartment floor to extend the compartmentation to the external leaf of the building

00:46:43 to the external leaf of the building so you're extending the compartmentation to that leaf regardless of the fire performance of that external leaf yes it's documented and improved documentary yes yes thank you and and we saw in the

00:46:56 yes yes thank you and and we saw in the first paragraph that you've also highlighted what you're calling the weak link so to speak in terms of fire yes yes and you prepared two sketches is this right the first was

00:47:08 two sketches is this right the first was to show the proposed solution to the building control officer's requirements yes yes and the second was to highlight the weak link

00:47:17 weak link in terms of fire as you saw it based on the design at the head of the window yes and they were separate drawings and had separate purposes is that right correct right

00:47:28 is that right correct right and is it right that you were flagging the weak link point regardless of what solution was ultimately adopted as to the 120 minutes fire resistance

00:47:39 as to the 120 minutes fire resistance correct

00:47:41 correct and um if we can look at this point at paragraph 31c of your witness statement on page

00:47:57 we can see you're dealing with this point at this point in your statement and you say my email also refers to the marked up aaa where i identified a weak link for fire by this i was highlighting that there

00:48:09 by this i was highlighting that there was nothing to stop fire in an internal compartment moving to an external cavity the window head interface with the structure shows that there is a gap it needed some form of protection there

00:48:21 it needed some form of protection there should have been a design to protect this

00:48:24 this as a supplier of a product siderise was not obliged to provide any general advice about fire safety and compliance with the building regulations and associated guidance however in this instance i did highlight

00:48:35 however in this instance i did highlight the weak link i identified despite it not relating directly to cavity barriers it was a clear error and i felt i should highlight it in my opinion harley and or building

00:48:46 in my opinion harley and or building control should have picked it up already it was their issue to deal with i would have expected harley to raise this issue with the main contractor by way of a request for further information

00:48:57 request for further information a design should then have been designed and detailed and put in place by the main contractor and or harley

00:49:05 so um in other words the design that harley had sent you showed a gap between the head of the window and the cavity barrier yes and you and you were concerned that that might provide a route for fire spread

00:49:16 might provide a route for fire spread out of a flat and into the cavity at the head of the window is that right i'll correct you on that there's a gap between the structure and the head and the window yes i understand not the character not a

00:49:29 yes i understand not the character not a gap between the window head and the cavity barrier a gap between the window head and the structure yes i understand we'll look at the drawing in just a moment so you can help make that point then when

00:49:41 you can help make that point then when we get to the drawing um and when you said that the gap needed you talk about it needing some form of protection what did you have in mind when you drew attention to this

00:49:54 we're not responsible for the design they could have been uh a whole number of ways of that gap not being there the location of the window

00:50:05 the window could have been moved back to align with the concrete and sealed to the concrete they could have been metal presence they could have been plasterboards they could have been all sorts of things in there but we were we're not the designers of

00:50:17 but we were we're not the designers of it

00:50:18 it but from the drawing there was no obvious

00:50:22 obvious closure of that gap yeah let's just look at your sketches actually while we're discussing this because it's going to be easier to have it in front of us if we go to har

00:50:38 403948 and um

00:50:43 let's look at page two we'll come back to this page in a moment this is the point at which you've uh highlighted the weak link for fire yes and

00:50:53 and is that your writing in red with the bubble

00:50:56 bubble around the weak link the point you were just making about it being a gap between the concrete and the the cavity barrier can you explain

00:51:08 the the cavity barrier can you explain what you

00:51:09 what you what you mean by that if you look at the drawing where you have the ceiling level drawn you can see in dotted line

00:51:20 drawn you can see in dotted line the existing frame yeah or the window that existing frame would have been sealed through the concrete so therefore would have given you a protection from any direct

00:51:31 protection from any direct passage of fire out into that external cavity

00:51:35 cavity now the window being replaced the aluminium window uh with it within the cloud bubble is outside of the building line

00:51:46 the building line the building line being the concrete yes so there is a gap between that window frame and the concrete

00:51:54 concrete they've got bracketry and things drawn in there but the brackets are normally uh localized to two to three per window so there would have been a gap

00:52:05 gap from the internal to the external yes how they received it or what they received it with but their drawings are very basic

00:52:17 but their drawings are very basic right yeah were these more basic than you would have expected to receive for a project um it depends this could have been a bit an

00:52:29 this could have been a bit an installation drawing and they could be other drawings that give more detail yeah and there are many thousands of drawings on a project yeah we don't see all of them we don't exceed what we are given so we can only comment

00:52:40 what we are given so we can only comment on what we are given yes i understand would it have been possible to position the cavity barrier immediately at the head of the window

00:52:51 if it if it did if you drop that characteristic down it wouldn't have made the difference you still got the gap between the window frame

00:53:00 frame and the structure yes i see and just to be clear you describe it as a clear error did you think that that should have been obvious to anybody looking at the drawings

00:53:13 to anybody looking at the drawings that should have been picked up by any of the senior project team yes and by the building control officer should have been picked up but like i said it should be picked up by anybody the senior project team

00:53:26 yes

00:53:31 now um

00:53:34 the drawings that harley sent you uh and if we go back to the sketch at the top page one

00:53:45 um just to be clear so what you've done on on this sketch is you've suggested you're doubling up solution on the right hand side is that right

00:53:54 right yes so you've got what you've done is it above each window you've put put two cavity barriers

00:54:06 both of 90 60 to give you 180 120 protection yes yeah as you go up the building you would have you got uh one of the sale one at the head one of the sale one at the head

00:54:18 head one of the sale one at the head up the building yes and just to be clear that that doesn't solve the problem with the the head of the window does it that you're addressing

00:54:29 you're addressing this was just your doubling up solution for the uh for the building control officer who wanted 120 yes in reality the windows should be further into the building to align with the existing structure yes

00:54:42 to align with the existing structure yes now these drawings that harley had sent you did not include any cavity barriers at either the jambs of the window or the sill

00:54:51 sill of the windows did you notice that at the time

00:54:55 the time the vertical draw characters are drawn on the drawing um without knowing the makeup of all the bracketry that's within the

00:55:07 of all the bracketry that's within the range screen system the the verticals seem to be logically as close as as possible within that window zone

00:55:19 possible within that window zone again the fire strategy should be detailing these things um it's the vertical cavity barriers

00:55:31 it's the vertical cavity barriers are there it appears from this to be contained within one compartment the fire strategy would be the document that would enforce the

00:55:43 be the document that would enforce the use of character barriers around the windows completely as well we will party to any of that design discussion on the project i see so i think what you're saying in terms

00:55:54 so i think what you're saying in terms of the jams of the window is that is it is this right it wasn't entirely clear from this drawing whether or not the vertical cavity

00:56:05 whether or not the vertical cavity barriers were as close to the windows as they could be yes yes right and what about the sills of the window i mean we can see in the basic drawing that's been sent to

00:56:16 basic drawing that's been sent to you there is nothing remotely in the location of the sill of the window that's why i've drawn it in yes with the dotted line yes right so if we look on the right

00:56:27 yes right so if we look on the right hand side

00:56:30 hand side that that cavity barrier you've added there at the sill location it's not immediately at the sill is it it's still a little bit below it yes i'm in all fairness born there is a schematic

00:56:41 schematic i'm not responsible for the overall design i see it's a schematic drawing from the very poor drawings that were given by harley yes i understand but it did you

00:56:53 yes i understand but it did you um intend that somebody looking at these annotations would appreciate from what you'd put

00:56:57 you'd put here that there also ought to be cavity barriers at the sill of the window there should be but like i said the design team for the project

00:57:08 design team for the project including the fire engineer and the fire strategy they would have they should have discussed the locations of all cavity barriers on the project they should be a within the fire strategy there should be

00:57:20 within the fire strategy there should be clear drawings laying out the location of cavity barriers and fire stopping on the project

00:57:26 project yes did you ever say that to harley did you ever say verbally around this time um these drawings are very very basic drawings you should have something better than

00:57:37 you should have something better than this

00:57:38 this not my place to do that yeah and

00:57:45 yeah and um did you ever um raise this weak link point any more widely than we see in these emails did you ever discuss it with anybody subsequently

00:57:56 with anybody subsequently no let's

00:57:59 no let's return to your covering email har3018971

00:58:14 this was the covering email we looked at earlier where you sent these sketches and just looking at the third paragraph down now you say please note that without specific details of the overall construction

00:58:25 the overall construction of internal linings and or site of the fire strategy for the project i can only offer the proposal above and as this is a refurbishment i would imagine that the internal linings will remain in situ and made

00:58:38 linings will remain in situ and made good to openings only which does not aid the fire strategy now um can you explain to us why you said that in this email

00:58:52 on refurbishment project it's quite um from that drawing you can see there's an existing window frame they do not on residential refurbishment

00:59:04 they do not on residential refurbishment projects they don't move the residents out

00:59:08 out so the existing window frame would remain in place until the external items had been installed then they would remove

00:59:17 remove or crudely remove the internal frame from that drawing they're quite clearly leaving the frame in place and making good around it it's a refurbishment strategy

00:59:31 it it's a refurbishment strategy yes yes did you feel that you were able to advise

00:59:36 to advise with without sight of that fire strategy for the project no because if i like like i said i'm a sideways we're not contracted to the project for the fire strategy

00:59:48 to the project for the fire strategy they will be a a higher-end fire engineer and or business

00:59:53 business that will write a specific fire strategy for the project yes detailing all the requirements for uh the safe

01:00:04 for uh the safe yeah use of the building in the event of a fire yeah mr k says in his witness statement for the

01:00:11 the transcript this is a page two paragraph seven he says that sideres always request

01:00:16 request as much information as possible from the customer in particular the fire strategy yes

01:00:21 yes yes that's correct and um how might the fire strategy have influenced or changed your advice um it wouldn't have obviously changed my

01:00:33 wouldn't have obviously changed my advice but that i gave but it would have given me a further

01:00:38 further uh insight as to how this was going to be constructed yes without sight of those documents i can't really comment on the quality of what that document would have been yeah

01:00:49 have been yeah but i would expect right cavity barriers to

01:00:52 to be defined in the fire strategy i'd expect compartmentation to be defined in the fire strategy and that's not just in terms of fire performance but actual location and

01:01:04 location and where they would expect to see these components of passive fire protection yes yes

01:01:11 yes yes yes thank you that's helpful um mr k goes on to say that fire strategy trust strategies are rarely provided on construction projects when they're asked for by siderise do you agree with

01:01:24 asked for by siderise do you agree with that

01:01:25 that um

01:01:29 leading up uh roll it back if you'd be pretty grandfather we would request five strategies quite a few the initial response worth

01:01:40 quite a few the initial response worth would be

01:01:41 would be well we haven't got one um depending on the relationship with the customer you might say well you have got one because you used it

01:01:52 have got one because you used it in your tender documents um because as a as a business if you attend as a facade business pretending on a project the fire strategy should be partly attended documents

01:02:04 attended documents that you receive um now without fail every time i ask for a fire strategy

01:02:11 strategy it appears right yeah that that's post the grenfell fire yes correct yeah and that's not to say there are more five strategies that are still the same quantity of buildings and

01:02:23 still the same quantity of buildings and still the same quantity of fire strategies it's just now that uh the facade industry are more aware yes thank you now um for completeness we

01:02:34 yes thank you now um for completeness we can see that on the 2nd of april 2015 if we go to

01:02:37 we go to sil 50158

01:02:43 um this is an email a couple of days later

01:02:48 later from mr bailey to mr k copying you in

01:02:58 yes so um ben bailey to you to ricky k and and copy to you on the 2nd of april 2015. uh he says morning ricky as discussed please see drawing attached showing the

01:03:10 please see drawing attached showing the placement of the fire break at the head of the window the bco has agreed to the definition of a cavity so i believe that the 3015 equivalent product can be used so he's telling you in the second

01:03:22 used so he's telling you in the second sentence of this email yes that the building control officer has now agreed to it being a cavity barrier yes yes yes and um if we just look at the drawing that was

01:03:34 if we just look at the drawing that was sent through at this point har three zeros one four five three three

01:03:51 what we can see is what was sent appears to be

01:03:55 to be um well we know it to be one of the studio e tender drawings and if you look in the top right hand side we can see that mr bailey ben bailey has highlighted a proposed section

01:04:07 proposed section if we could blow that up a little what we can see is that in this drawing in fact the cavity barrier is placed immediately at the head of the window do you see that

01:04:19 window do you see that yes do you remember looking at that no and it was sent through and did you ever have any further discussions with harley mr bailey or mr lam about this after this time

01:04:40 lam about this after this time and then just again just for completeness we can see you respond on the same day if we go to sil 50169

01:05:02 you this is you to mr bailey and mr k second of april same day and you say hi ben

01:05:09 ben sense at last from the building control officer so i take it the meeting for tuesday is not needed if you need any further assistance in the future please do not hesitate in contacting us

01:05:20 please do not hesitate in contacting us um so just to be clear did you ever receive any confirmation back from harley that they had understood the point you were making about the weak link

01:05:31 about the weak link at the head of the window no and and you didn't

01:05:37 didn't follow up on that at any stage afterwards

01:05:46 sorry yeah did you say no just then i said no

01:05:49 said no right

01:05:52 and given that that you were flagging a potential life safety fire issue did it occur to you to follow up on it and to check that harley had understood

01:06:04 and to check that harley had understood the point you were making i had given the advice in good faith to the project they should be experienced enough to

01:06:16 they should be experienced enough to heed that warning and there's others there were responsible for the design of the project we weren't responsible for design

01:06:25 design they could have been using a whole like i said a whole host of different materials not side of materials to close that gap

01:06:31 that gap yes it wasn't evident from that drawing yes

01:06:35 yes um can we go now to um har three zeros one nine zero one two at page two h a r three zeros one nine zero one two

01:06:46 zero one two um these are some exchanges um that occurred in june 2015 on the subject of vertical

01:06:52 vertical cavity barriers and some queries that were raised

01:07:10 har sorry it's coming up now yes so in the middle of the page there on page two we can see that on the 17th of june

01:07:20 june 2015 ben bailey emails ricky k subject grenfell tower vertical fire breaks and he says i'm after some technical advice we're putting vertical fire breaks up the building

01:07:32 fire breaks up the building where they are party walls i've marked where these are on the attached drawing will we have to install the verticals anywhere else like on the corners of the building

01:07:41 building so we don't fall foul of some regulation etc so that's the request and then we can see from the bottom of page one

01:07:51 page one in this chain if we go up to the bottom of page one that mr k forwards this email chain this email to you for a response he says crit hi chris please may i ask you to respond to below email from ben

01:08:03 you to respond to below email from ben with some advice about the location of the vertical fire barriers marked up drawing attached and then we can see from the top email of page one that you respond

01:08:16 and you say we need hibern we need further information in order to respond in order to respond as follows this is you to ricky k copying in ben bailey and and you say you need

01:08:28 bailey and and you say you need elevations the fire strategy report and then nhbc or not and then upon receipt barney people will be able to respond

01:08:36 respond accordingly um now just can you explain briefly why you considered that you needed

01:08:43 needed those documents to be able to provide a response

01:08:47 response um they had only sent over a blurred floor plan of the building just one section of

01:08:58 of the building just one section of the building in order to understand the how the propane is made up you need more information

01:09:10 you need more information um and this is again you see i'm asking if the fire strategy because in the fire strategy it should be clear as to where the vertical brakes are yes in there um

01:09:21 are yes in there um i'm asking about the nhbc or not because approved document b requires vertical barriers

01:09:29 barriers at uh party poor locations or changing direction

01:09:33 direction on the building nhbc i've got a higher requirement with requirement every six meters yeah so i just needed to understand

01:09:44 what was required for that yeah that works and you've told us at paragraph 35 of your witness statement we don't need to go to it that you cannot recall and can find no trace of

01:09:56 cannot recall and can find no trace of ever receiving these documents or a response to these queries from harley is that correct that's correct do you remember ever chasing up on this request

01:10:08 chasing up on this request it'll come out in the next chain of emails this was happening very very quickly i sent this email and then

01:10:20 i sent this email and then a phone call for myself and ben bailey to agree

01:10:23 to agree the locations on them right they're under pressure on site to get this work done right so this is normal

01:10:31 normal it happens in the construction industry all too often unfortunately you put a request information and then you get an irate site manager on ranting wanting information now yes

01:10:43 ranting wanting information now yes without giving you the full picture yes i see yes let's turn to that email if we go to sil 50108

01:10:53 this is an email from mr ben bailey to you dated this 22nd of june 2015.

01:11:02 and he says

01:11:07 chris to confirm my understanding from our conversation we need vertical fire breaks on the columns grids a1 a5 d1 d5 as well as the party walls question mark so

01:11:18 walls question mark so as you just said a conversation happened on the telephone yes where mr bailey pressed you for advice yes yes um how are you able to give advice to him

01:11:29 how are you able to give advice to him if you haven't received the documents you'd requested that would have been discussed during the phone call um and i

01:11:39 um and i it would indicate we just need to know are they needed on various locations which i confirmed to him

01:11:47 to him and this should be a diagram here marked up

01:11:50 up where they are uh required yes so i was just responding to the information that was given um but they didn't have whether they

01:12:02 um but they didn't have whether they didn't have the fire strategy or the other documents i can't say but certainly from the time scale of the date stamp and timestamp on my request

01:12:13 request to this phone call it's a case of the emails received and formed in before the end of the day to get this resolved yes yes would you agree from this exchange and from um other

01:12:25 from this exchange and from um other exchanges that we've seen that harley was relying on you and and siderise generally for design advice in relation to cavity barriers

01:12:36 advice in relation to cavity barriers wouldn't say it's design advice how would you

01:12:39 would you how would you categorize it it's um

01:12:44 they're looking for advice as to the locations of the county buyers we're not responsible for the design they should themselves be fully conversant with the location

01:12:58 be fully conversant with the location requirements of the cavity barriers from approved document b and from the fire strategy on the project yes did it concern you that harley appeared to be dependent on your advice

01:13:09 to be dependent on your advice as to where to place cavity barriers and did not appear to have any independent expertise in the matter even today we still get queries even

01:13:20 even today we still get queries even from

01:13:21 from facade consultants and fire consultants as to can you clarify the location of cavity barriers so it's not unique to harley

01:13:32 so it's not unique to harley we we still get inquiries today yes and back then was that normal at the time for especially this specialist cladding subcontractor to repeatedly approach a manufacturer

01:13:43 to repeatedly approach a manufacturer for advice on cavity barriers yes

01:13:49 and just finally on this topic did you ever provide harley with any advice about the positioning of cavity barriers within the architectural crown at the very top of the building i wasn't even aware there was a crime right oh

01:14:02 even aware there was a crime right oh the bill like i said if in that email well i've asked them for the elevation drawings

01:14:07 drawings the fire strategy yeah that thing if they had supplied that information to me i may have been able to see

01:14:15 to see what else was going on but we can only respond to the information that we are given

01:14:19 given yes we're not contracted as part of the design team so we don't have access to all the documents right now um my final topic is about installation and post fire inspection

01:14:31 post fire inspection if we go to paragraph 55 of your witness statement on page 14. strange forgive my interrupting you but um do you have any idea how long this final topic might last it's fairly it's fairly brief mr

01:14:43 it's fairly it's fairly brief mr chairman um i've got about six or seven pages of notes i may not get it done in five minutes but i would be reasonably confident of getting it done in 10 to 15 minutes if i could be permitted

01:14:55 10 to 15 minutes if i could be permitted to keep going and then we can have the morning break um

01:14:59 um at which time further questions could be suggested right well i'm happy to do that but i thought we just in courtesy asked mr moore do you happy to carry on a bit longer mr mor while we

01:15:08 while we try and finish this line of questions yes certainly yes we'll only get them screen thank you very much

01:15:15 very much so if we go page 14 paragraph 55 you tell us there that on the 18th of july 2018 so over just over a year after the fire occurred

01:15:26 just over a year after the fire occurred i attended grenfell tower to review the installation of the remaining cavity barriers on the project in areas of undamaged cladding and fire damage cladding and then you provide us with a number of

01:15:38 and then you provide us with a number of comments

01:15:39 comments and is it right that at that inspection you were able to inspect the installation of the remaining cavity barriers both in areas of undamaged and fire damaged cladding yes

01:15:49 yes yes and then between paragraphs 56 and 60 of your witness statement you set out basically a list of problems

01:16:00 you set out basically a list of problems that you

01:16:00 that you identified with the installation of the cavity barriers yes yes now i don't want to spend time reading that all out so what i'm going to

01:16:08 to endeavor to do is just to summarize the problems you've identified but please do correct me if i've uh summarized them unfairly or incorrectly so paragraph 56 you're essentially

01:16:20 so paragraph 56 you're essentially saying

01:16:22 saying that in some locations you are unable to identify support brackets or holes for support brackets which suggested to you that cavity barriers either had not been installed at all

01:16:33 either had not been installed at all or had been installed incorrectly without support brackets and perhaps with some silicon yes yes what would be what would be the effect of installing the cavity barriers with

01:16:45 of installing the cavity barriers with silicon

01:16:46 silicon rather than support brackets they're not installed

01:16:50 installed in accordance to our guidance in accordance with how they're tested yes therefore they're non-compliant yeah then at paragraph 57 that begins at the bottom of the page we're looking at

01:17:01 bottom of the page we're looking at there

01:17:02 there you tell us that in areas where the cladding was undamaged the horizontal cavity barriers you observed were not installed in accordance with published installation guidelines and in particular the gaps were too wide

01:17:15 and in particular the gaps were too wide and therefore would not have been closed by the intumescent yes um yes um we talked about

01:17:26 very large differences in um installation guidance instead of being a 25

01:17:34 25 millimeter gap you got 140 millimeter gap um

01:17:38 gap um that's way beyond any form of sensible parameters yes and um in respect of um vertical cavity

01:17:49 and um in respect of um vertical cavity barriers you notice that in some places the horizontal support brackets had been used thereby piercing the end of the cavity barrier yes yes now just to be clear from

01:18:01 yes now just to be clear from recollection when when you looked at the vertical cavity barriers did you actually see full fill vertical cavity barriers having been installed in that vertical position

01:18:14 um there was four there were vertical barriers in there but there was there was gaps and things without seeing the photographs of the full report like

01:18:25 difficult to right yeah it's just because a number of the inquiries experts have seen horizontal barriers and we have photographs of those installed in the vertical position did you see any evidence of that we only

01:18:38 did you see any evidence of that we only could see the barriers that were there at the time they could have been removed right i see and and that piercing that you drew attention to piercing the end of the cavity barrier um the vertical cavity barrier what

01:18:50 um the vertical cavity barrier what would be the impact of that piercing in terms of its fire safety properties if you go back to my notes all of a sudden the psm actually

01:19:01 all of a sudden the psm actually indicated that there was a clear void from the end of the vertical barrier to the cladding

01:19:10 ineffective they weren't installed in accordance with their guidance and weren't installed as they however they've been tested yes and i think at paragraph 60 of your witness statement you actually tell us that the vertical

01:19:21 actually tell us that the vertical cavity barriers had air gaps of up to 50 millimeters yes meaning that the compartments were not sealed so they're supposed to be full fill cavity barriers still uh installed under compression yes

01:19:33 uh installed under compression yes correct

01:19:33 correct and in fact they've got gaps of 50 millimeters yes yes so that and that would render them ineffective is that right correct and because they don't have intumescence do they so

01:19:45 don't have intumescence do they so that's correct yeah and then um just for completeness um at paragraph 59 you also tell us that as with the horizontal barriers there are areas where you were unable to

01:19:56 are areas where you were unable to identify support brackets or holes for the vertical cavity barriers suggesting that either they were not installed at all in those locations or they'd been installed incorrectly yes yes overall

01:20:10 yes overall how would you characterize what you saw during that inspection in terms of the quality of the cavity barrier installation um it is probably of the poorest standard i've ever seen

01:20:23 standard i've ever seen right and you tell us at paragraph 61 of your statement at the end of page 15 that if you had been asked to inspect the installation during the construction

01:20:34 the installation during the construction and it follows logically from your previous answer that you would have said they were non-compliant and you would have instructed corrective actions by which i think you mean remedial work to take place to

01:20:45 mean remedial work to take place to correct all of it yes yes we are very um there's no gray area when it comes to inspection it's either right or it's wrong

01:20:55 wrong if it's wrong and it's a minor and can be corrected it gets corrected if it's significantly wrong like these barriers were they'd have to be removed and replaced

01:21:06 they'd have to be removed and replaced with new material yes would it be fair to say that these were fundamental errors in the installation that no reasonable installer should have been

01:21:18 no reasonable installer should have been making

01:21:19 making correct um now we know it was osborne berry that installed these cavity barriers did you have any prior experience of working on projects in which osborne berry were involved

01:21:34 and what about harley's installation ability

01:21:37 ability had you ever provided installation advice to harley previously i believe there was one

01:21:45 previous project which was a curtain wall project where an old contact of mine terry nichols

01:21:52 nichols requested some assistance on site which i handed over to ricky k yes we're going to come to that in just a moment can we just turn to um something called

01:22:03 can we just turn to um something called the asfp red book um this is sil402093

01:22:12 this is dated june 2016 just to be clear

01:22:23 so this is the red book of fire stopping by the asfp by stopping linear joint seals penetration seals and cavity barriers fourth edition

01:22:34 fourth edition um did you have any involvement in the creation of this guidance yes it did and if we go to page 67 under section 9.2

01:22:48 there's a section-headed installer certification and in the first paragraph it tells us that third-party certification for installers is a process whereby the contracting company employs appropriately trained competent

01:23:00 employs appropriately trained competent staff to install the required passive fire protection system and their work is independently ordered audited by site inspections from the third-party organization and a full record system is required as

01:23:11 and a full record system is required as part of the scheme and then it tells us what an installer certification check involves and then um if we look below that bold text two

01:23:23 if we look below that bold text two paragraphs down it says the asfp recommends that all passive fire protection is installed by third-party certified

01:23:31 certified installers certificated installers in the case of firestopping this is particularly important as firestopping is often covered up and inaccessible after installation so it is important to get it right

01:23:43 it is important to get it right on installation so presumably as you were involved in this guidance you would have been familiar with these recommendations yes yes and similar recommendations appear

01:23:54 yes and similar recommendations appear in the proof document b did you ever have a conversation with harley

01:24:01 harley about whether they ought to be carrying out the installation of the siderise cavity barriers using third-party certified installers no i wouldn't have that conversation

01:24:12 no i wouldn't have that conversation with them

01:24:15 did you ever discuss in any way that the competency of the installers ought to be evaluated by harley no um

01:24:25 no um and then just finally that weyland house project

01:24:29 project that you mentioned if we go to sil 50321 at page two

01:24:50 this is an email dated the 19th of december 2014. it's in relation to the weylands house project

01:24:57 project and the subject is fire break lama firm and

01:25:00 and it's from ricky k to terry nichols of harley

01:25:04 harley but it's cc to you do you see that yes and um just for context mr swales tells us at paragraph 66 of his witness

01:25:15 tells us at paragraph 66 of his witness statement we don't need to go to it that ciderise had supplied cavity barriers to harley on four separate projects in 2014 to 2015 and one of those was weyland house

01:25:27 weyland house does that does that sound right to you um

01:25:31 um i wouldn't have

01:25:36 an overall view of what sales right uh were sold right to your knowledge was this the only time the only other time that cider eyes had uh inspected the work of harley

01:25:51 had uh inspected the work of harley on a project um it's it was a function of ricky k's duties um if it is the only one that is

01:26:02 duties um if it is the only one that is the only one i wouldn't be aware of rookies every day-to-day movement right yeah and then we can see from the content of the email that mr kale she says from my site with visit to site

01:26:15 she says from my site with visit to site on the 17th of december i'd like to make the following comments with regard to the install of our lambotherm this is the curtain walling fire stopping system in a vertical application on your development at weyland house yes

01:26:27 development at weyland house yes yes so so this is curtain walling it's not uh

01:26:31 not uh cavity barriers in cladding yes correct and

01:26:36 and um it would appear that mr k had attended weyland's house to undertake an inspection um just to be clear where cider eyes ever requested to undertake a similar inspection at grenfell

01:26:48 inspection at grenfell no was that service ever offered to harley

01:26:52 harley the the inspection service um that would have been part of the normal sales

01:27:00 sales uh negotiation and discussion between ricky and harley kurt mullin it's a service we offer and have offered since i joined siderise in 2002.

01:27:13 i joined siderise in 2002. it's it's always a service level right we've always offered it and and we don't need to go to all the detail of the email but i'm going to summarize it appears from the text of the email

01:27:23 the email that mr k found a number of problems based on his inspection including some fire stops being installed in an incorrect orientation some had been installed under insufficient compression

01:27:35 insufficient compression there were concerns over whether the correct quantity of brackets had been used

01:27:39 used some of the fire stops had been cut too small or cut poorly leaving gaps now um would you agree that a number of those installation issues do appear to

01:27:51 those installation issues do appear to be similar to the problems you identified on your inspection of grenfell tower after the fire

01:27:58 fire um different product different magnitude i see so they looking at this they um there are issues

01:28:09 looking at this they um there are issues um there but they're nowhere near the magnitude of the issues that were on crenshaw i see i see um so just to confirm did this prompt any consideration within

01:28:21 consideration within siderise as to whether you ought to be offering to inspect the works at grenfell tower just a few months later um like i said i wasn't uh responsible for

01:28:32 like i said i wasn't uh responsible for the account um i wouldn't have put the two together okay mr chairman um thank you for that uh

01:28:40 uh extra time um i've come to the end of my questions

01:28:44 questions perhaps have to have the normal morning break and then we can take in any questions well just so you understand where we are mr mort we'll we'll take our morning break now we always have a break when council

01:28:57 now we always have a break when council finished asking questions just to give them a chance to check there's nothing they've overlooked and also to give other people who are following the hearing a chance to suggest further questions so

01:29:09 to suggest further questions so it's not quite the end we'll come back at quarter to 12 please and at that stage we'll see whether there are any more questions that we need to ask you all right okay and uh as before please

01:29:20 all right okay and uh as before please no talking to anyone else about your evidence or anything to do with it while we're on the break okay all right good see you in a bit later on thank you very

01:29:36 much

01:45:03 welcome back everyone we'll now see whether there are any more questions for mr mort

01:45:08 mr mort first thing is to check that mr mort can see me

01:45:11 see me and hear me can you mr mort yes i can good thank you very much um well ms grange do you have any more questions mr mort

01:45:20 mort yes just one question mr chairman thank you

01:45:23 you yes mr mort um so we saw this morning that you did review the system design drawings and you identified the weak link despite in your own words it not being

01:45:34 despite in your own words it not being relevant to the cavity barriers and it not being your responsibility can you explain how doing that is consistent with your reasons for not alerting harley to the risks and limitations of cavity

01:45:45 to the risks and limitations of cavity barriers in an acm rain screen system

01:45:52 the system or the facade designers plus the whole project team should be aware under the cdm requirements of all

01:46:03 requirements of all the relevant approved documents not just approve

01:46:07 approve document b but a l m k whatever approved document is relevant to that building the project team should be fully aware of that document on the requirements of that document

01:46:18 that document and the requirements of the testing needed to comply with those documents the weak link was such a glaring obvious issue

01:46:30 a glaring obvious issue that i had to highlight that there was a i could not see how that was designed to be closed yes i see that but how was the the risks and limitations of cavity barriers in an

01:46:42 limitations of cavity barriers in an acm range screen system how was that to be gleaned from the relevant approved documents at the time

01:46:51 it's within the uh section 12 of the external wall section of document b like i said we manufacture and supply

01:47:02 and supply counterparts we're not responsible for the external world design our paneled choice or panel testing that's the responsibility of the project team and

01:47:13 team and we have to assume that they've done their due diligence and complied with that section right yes thank you very much yes thank you mr chairman those are all the questions that we have for this witness

01:47:24 witness right thank you very much well mr mort um not as many questions as there might have been

01:47:29 have been uh anyway it just remains i think now for me to thank you very much for making yourself available to give evidence to the inquiry i think all the members of the panel have found it really interesting

01:47:40 have found it really interesting and helpful to hear what you've been able to tell us and so we are very grateful for your willingness to give evidence there aren't any more questions for you so now it's sufficient for me to say well

01:47:52 it's sufficient for me to say well you're free to go and thank you very much and goodbye thank you and goodbye

01:48:00 right at this stage we will have a another short break while we reorganize matters for the next witness so um that will take 10 minutes or so

01:48:11 so um that will take 10 minutes or so i'm going to say that we will aim to resume at midday with the next witness or as soon as possible

01:48:19 possible when all the arrangements have been made good thank you very much

02:15:09 welcome back everyone i'm sorry about the delay which has been slightly longer than

02:15:13 than we were expecting but we are now ready to go on

02:15:17 to go on and our next witness is mr richard k of siderise i'm just going to check that he's

02:15:22 he's there and able to see me and hear me yeah yeah good morning

02:15:32 you should on the screen in front of you the words of the affirmation which you're going to make do you have that there uh i do yeah could you please then make the

02:15:44 do yeah could you please then make the affirmations by reading out the words in front of you i do solemnly sincerely and truly declare and affirm that the evidence i shall give shall be the truth the whole truth and nothing

02:15:55 the truth the whole truth and nothing but the truth thank you very much um now we have to go through one or two formalities before we actually start taking your evidence can i ask you please to confirm that you're alone in the room from which

02:16:07 you're alone in the room from which you're giving evidence is that right yes thank you can you confirm that you have no documents or other materials with you that's correct and can you confirm that

02:16:18 that's correct and can you confirm that your mobile phone is in another room and you don't have any other electronic device with you that's capable of receiving messages yeah thank you very much indeed now you

02:16:29 yeah thank you very much indeed now you might like to know that your legal representatives are in the virtual hearing room that is they can follow your evidence they have the power to intervene if they think it's really urgent

02:16:40 think it's really urgent but we have other means of their contacting our council if there are problems so i'm going to ask them to keep their microphones and cameras switched off in all other circumstances um

02:16:53 in all other circumstances um i hope we're not going to have problems with the sound or the vision but if we do we'll have to take a short break while the technical support people iron them out um

02:17:04 iron them out um we'll have a break for lunch at the usual time and we also have a break halfway through the afternoon if you need an

02:17:11 need an additional break at any time will you just indicate that and we'll try and accommodate you um is there anything you'd like to ask me

02:17:22 is there anything you'd like to ask me or raise

02:17:23 or raise before we start taking your evidence awesome

02:17:26 awesome right thank you very much well in that case i'm going to ask mr laking to put some questions to you yes mr leaking when you're ready thank you very much mr chairman and members of the panel and

02:17:38 mr chairman and members of the panel and thank you very much mr k for attending today to give evidence it's very much appreciated can i start by confirming that you can see and hear me clearly correct sir ken yeah thank you very much

02:17:51 correct sir ken yeah thank you very much if you have any difficulty understanding any of the questions that i ask you please ask me to repeat them or to put the question in another way and and if you

02:18:02 in another way and and if you feel you need a break at any point as the chairman has said please just let us know and please also try to keep your voice up so that the transcribers who are on this call and are writing down

02:18:13 are on this call and are writing down what you say and get a clear note of your evidence absolutely and one point that we ask all the witnesses a nod or a shake of the head doesn't go

02:18:24 a nod or a shake of the head doesn't go down on the transcript so please endeavor to say yes or no in answer to the questions thank you very much um you've made one witness statement so could i please take you to that it's a sil50304

02:18:37 that it's a sil50304 please

02:18:43 can i ask you to to confirm is that your witness statement it's correct and if we go to the last page that's at page 10 we can see it's dated the 28th of september 2018.

02:18:56 september 2018. and is that your signature indeed yeah and have you had an opportunity to read that witness statement recently uh yes i've reviewed my own statement and can you confirm that the contents

02:19:07 and can you confirm that the contents are true

02:19:08 are true absolutely 100 have you discussed your statement or your evidence with anybody else before coming here to give evidence today

02:19:15 today no so i'd like to start with some questions

02:19:19 questions about your background and your experience and your role at siderise um a paragraph three of your statements that's at page one you say you've been employed by siderise

02:19:30 you say you've been employed by siderise since the first of april can we just have a look at that um in the second line do you see that there right can i ask ev what you did before you joined siderise

02:19:42 joined siderise uh i actually had a year out um went travelling but prior to that my previous employer was guilty uh gp so within the construction sector where i acted as

02:19:54 where i acted as um manager of the portsmouth guilty centre

02:19:57 centre before being then out on the road as one of their external sales representatives um i then left there sometime in 2010 um took a year out like i said

02:20:08 in 2010 um took a year out like i said went traveling came back and joined siderise due to my previous experience at hilltop and how were you recruited to siderise um my

02:20:19 to siderise um my father was working for siderise at the time there was an opportunity that came up for

02:20:24 up for a external account management role and construction account manager role which i applied for went through the standard interview processes and secured the job based on my previous

02:20:35 and secured the job based on my previous experiences at hilton now is it right that you were initially employed as a construction account manager is that right yeah and what were the

02:20:47 is that right yeah and what were the qualification requirements of that role um it was mainly a sales role so there's not too many qualifications to be a sales account manager required it was really based on my

02:20:58 required it was really based on my experience with guilty i'll be selling to similar clients my target market was similar being construction accounts because it was more generalist obviously we have systems that are not just suited

02:21:10 we have systems that are not just suited for facade sector and at the time my role was looking at interiors and facades when i was first employed for the business so uh so yeah it was it was it was a broad spectrum of sort of target uh market for our range

02:21:22 sort of target uh market for our range of products at the time yes i see and would it be fair to say therefore that the role didn't require any technical qualifications uh no i mean obviously we had dedicated technical resources within the team

02:21:34 technical resources within the team so um yeah it was more sales business development commercial perspective and do you hold any technical qualifications uh no official technical qualifications

02:21:47 uh no official technical qualifications just outside of obviously my product knowledge

02:21:49 knowledge uh within the business i have to have a clear understanding of how our systems perform the applications they're using wouldn't be very good at my job if i didn't so uh yeah i have a clear understanding of our products and their applications

02:22:01 our products and their applications yes i see and prior to joining siderise had you had any training or education in the application of the building regulations or the guidance in approved document b

02:22:12 or the guidance in approved document b or any of the other approved documents was something i picked up on i mean it's part of our standard cpd delivery so as part of the learning curve for for my job role

02:22:24 curve for for my job role um frequently delivering scripted cpds that are scripted by you know our marketing and technical teams at the time

02:22:31 time um to ensure that the external uh sales teams are delivering the same message um to to the wider market so yes my understanding was really learnt from frequent delivery of things like

02:22:44 from frequent delivery of things like cpds

02:22:45 cpds when you are talking about cpds there um just to clarify that's continuing professional development that you gave rather than continuing to professional

02:22:56 rather than continuing to professional development that you were subject to is that right uh yeah obviously i shadowed many of our senior more senior people within the business prior to them me taking over and doing

02:23:07 prior to them me taking over and doing concern conducting cpds myself um but like i say the the presentations were scripted so you know you you're going as per um you know our marketing and

02:23:18 you know our marketing and technical teams clear instructions so uh but yeah obviously as you're presenting it you're learning about it so that's kind of how i learned about you know the regulatory requirements surrounding the products that we were

02:23:29 that we were specifying for use or selling for you some

02:23:32 some on projects and price adjoining siderise had you had any training or education in respect of fire engineering no and at the time of the grenfell

02:23:44 no and at the time of the grenfell project where you were a member of any professional uh bodies or organizations not personally you say a paragraph three of your witness statement so that's sil 50304 at page one

02:24:00 sil 50304 at page one that you were promoted to national facade's manager in 2015. do you see that there yep and you confirm that at the time of the grenfell

02:24:11 confirm that at the time of the grenfell tower refurbishment you were the national facade manager is that right that's correct yeah do you recall when about it was in 2015 that you were promoted

02:24:23 that you were promoted not specifically probably at the start of the year i would have thought as just part of the end of year review of roles within the business i would have i would have assumed it would either be end of uh so first of

02:24:34 it would either be end of uh so first of april end of financial year it would have been um as of uh january 1st so one of the two i can't be sure you

02:24:42 you um can you describe what this new role involved

02:24:46 involved the role of national facades manager well because prior to that being construction account manager which was being generalists looking at interiors looking at facades we realized our focus

02:24:59 we realized our focus product range was more [Music]

02:25:03 [Music] applicable to the facade sector and it was an area of the market which we wanted to focus on and that to generate sales we felt we had a

02:25:11 had a a a market leading offer at the time from the site service and technical and uh product testing perspective and we wanted to put a lot more focus on to that uh to that market sector so

02:25:23 to that uh to that market sector so i was moved into uh into that role as a more

02:25:27 more like i say market specific role rather than just being a generalist construction accountant and can you briefly explain your role in the hierarchy of positions that side

02:25:38 the hierarchy of positions that side arise

02:25:40 um my role in the hierarchy of positions i mean at the time being national facade manager that wasn't a management of any particular team

02:25:50 team it was me covering uh covering the country living down in brighton not ideal

02:25:54 ideal geographically but i certainly did a lot of traveling back then um so yeah it was really managing our national set of accounts um so when it's national facades manager

02:26:05 um so when it's national facades manager there was no particular team working underneath me it was just me covering the country from an account management perspective of our target facade set of contractors and what about senior to you who did you

02:26:17 and what about senior to you who did you report to

02:26:19 report to um back then i was reporting to it might have been my father at the time for a very short period of time and then um christopher hall who was

02:26:32 and then um christopher hall who was brought in as sales director for the business

02:26:34 business um not entirely sure of the top of my head of the time frames there um but yeah it was it kind of worked coincided with when i moved into the national

02:26:44 national massage manager role my father then moved into more of an export role so global role and at which point then both of us reported directly to the sales new sales director

02:26:55 director uh we might have been called commercial director but then entirely sure with the role but that would have been chris hall and are you still employed by side to rise yeah

02:27:05 rise yeah in general terms and very briefly can you explain to us what products cider eyes manufacture and provide on my side of the business that i work for we have our special

02:27:16 that i work for we have our special products side very separate to us um but they are cavity barriers and fire stops

02:27:22 stops for various facade types be it masonry ventilated rain screen curtain wall system

02:27:29 system as well as various acoustic upgrades that we can provide to um assisting with noise control in curtin

02:27:35 curtin buildings as well so that in terms of product range that i look to promote obtain specifications for in sale they are the set of product ranges that

02:27:46 they are the set of product ranges that i predominantly deal with on a daisy daily basis and target for sales yes and at paragraph four of your statement you say that your role was to

02:27:57 statement you say that your role was to look after key accounts and to generate new accounts for the business and can i just ask you what you considered a key accounts to be the market leaders um the the guys that

02:28:10 the market leaders um the the guys that were taking on the biggest contracts and and and obviously the contractors that we wanted to be working with on the most iconic projects um a key account for us could be based on

02:28:21 on uh current level of spend for an existing customer or if they're a prospect you know what their potential level of spend would be um and and and yeah they were ones that i was targeted with focusing for direct

02:28:33 i was targeted with focusing for direct business

02:28:34 business now we'll discuss siderise's relationship with harley in more detail later

02:28:38 later but was harley considered a key account uh

02:28:42 uh not because they weren't an already purchasing account and they were one of a list of my key development accounts that i was sort of targeting

02:28:51 targeting knowing that they secured a quite a significant amount of working around the london and south east area um and yeah there were knowledge of of some of the personnel that worked there and and felt that we

02:29:03 that worked there and and felt that we perhaps

02:29:04 perhaps due to relationship may get issue in you know on my standard approach when i was prospecting which is part of my run what about celetex

02:29:16 celetex what about celetex were they considered to be a key account they would never have been uh a company that would have ever procured our materials so no they would not be anyone that i would have been

02:29:27 anyone that i would have been proactively looking to engage with now um can we turn to mr swales's witness statement

02:29:33 statement uh briefly that's that at sil50306 at page eight i want to look at paragraph 31.

02:29:44 i want to look at paragraph 31. now mr swails is the chief commercial officer at siderise is that right this is correct yeah um and if we have a look at paragraph 31 it says there that cider eyes recognize that installation

02:29:56 cider eyes recognize that installation is crucial to the function of its product and so we do provide assistance either through instruction by the data sheets and stroke or on-site training additionally in september 2016

02:30:07 training additionally in september 2016 a youtube video was launched as well as the app january 2016. in addition to installation training post installation inspection is also offered there is no additional charge for this

02:30:17 for this there has however traditionally been a slow update to this which is why we clarified the extent of the cider eye site services offer and actively began to promote these in 2016.

02:30:27 2016. part of this was the development of an app that would provide assistance to contractors to correctly install the materials and subsequently inspect and report on the installation the use of the app provides a standardized and detailed means of

02:30:39 standardized and detailed means of checking that the key elements of product installation have been undertaken correctly so our pausing there we can see

02:30:46 see that the app was launched in january 2016.

02:30:49 2016. um but mr swail sets out uh at paragraph 29 we don't need to turn to it that it was trialled during 2015 with some of cideriser's key accounts

02:31:01 accounts to your knowledge was harley involved in that trial no no um what about celeste no i'm sorry i spoke over you you want to repeat that answer

02:31:13 to repeat that answer no harley we're not involved with any um part of

02:31:16 part of the development of the app or it wasn't trialled on any of our sites and what about celetex were they involved in its development again we wouldn't be inspecting celetex wouldn't be procuring or

02:31:28 celetex wouldn't be procuring or installing our materials so we wouldn't inspect celetex materials so we'd only ever inspect our own and like i said they were not an installer of our products so no and as at the time of the grenfell tower

02:31:39 and as at the time of the grenfell tower project did key accounts qualify for different or better services from siderise

02:31:46 siderise i wouldn't say different or better um maybe frequency visits that would offer and in terms of complementary visits would be more prepared to uh go the extra mile in terms of assisting

02:31:58 go the extra mile in terms of assisting with more frequent visits you know it was all down to resource really but obviously the higher spending key accounts we would look to offer that you know go that extra mile where we could

02:32:09 where we could you referred there to complementary visits

02:32:12 visits does that mean that for other accounts cider eyes would charge for provision of site services and site visits no no they're always complimentary but

02:32:24 no no they're always complimentary but they were limited um you know again depending on order value if you had a project that was an 18-month program with six blocks um having three complimentary inspections throughout that period is not really

02:32:35 throughout that period is not really going to be sufficient so you know that's down to myself the account manager to agree on the level and frequency of visits up front with the project management team um

02:32:46 team um and and and you know we've maybe then increased to doing two per block rather than it being two throughout the whole duration of the project program um it was just something that would sought out an early stage and that to

02:32:57 sought out an early stage and that to confirm

02:32:58 confirm um and again it's depending on project program and and overall project value to siderise whether or not we there was um you know resource that could be pumped in to

02:33:09 in to facilitate the inspection needs yes i see

02:33:13 see now returning to your witness statement at sil 50304 page one a paragraph four

02:33:27 you say that in the third line down at the time of the grenfell tower refurbishment in 2015 my focus was on growing siderise's market share this included converting our business

02:33:38 this included converting our business from distribution-led inquiry stroke sales

02:33:41 sales to direct inquiry stroke sales where appropriate could you just describe briefly what are distribution-led inquiry stroke set bills

02:33:51 bills we would the the market-leading distribution uh on the installation side um you know we'd often see receiving enquiries for which were um

02:34:04 receiving enquiries for which were um you know if we then required further technical info everything was always dealt with them via a third party and these distribution um um people that were approaching us these third parties were

02:34:15 these third parties were they could be supplying 200 different products to the same project so their actual experience and knowledge of of our product was was rather limited so we would prefer to always deal with the

02:34:27 we would prefer to always deal with the end user

02:34:28 end user or the installer in terms of assisting with design um and a lot of our competitors are owned by these these third-party distributors so we also found that

02:34:39 distributors so we also found that um a lot of work that we would have put in with architects on designs and specifications that we would have felt that we'd secured when the tenders then go out and they go viral third party it was we were finding a lot of oh yeah we can

02:34:51 we were finding a lot of oh yeah we can process the sidewise but we can also offer you a an alternative albeit perhaps not as as well tested or well qualified for the job and which was the deviation from the spec and we were finding that we were

02:35:02 spec and we were finding that we were being undercut commercially and losing orders based on that and and it was something i identified with my healthy background of really only selling direct to end users not engaging third parties it was a strategy for the

02:35:14 third parties it was a strategy for the business when i joined and and went into being more facade focused was that we need to be dealing with end users a for clarity of design and getting things right

02:35:25 right um and and they weren't really offering these third parties anything more than a credit

02:35:30 credit um we were prepared to take these uh these facade contractors direct because we wanted to hold the relationships with the end users so they were fully aware of

02:35:40 of what our service offered were from the technical and on-site perspective because a lot of that was being lost in translation with these third parties with their reluctance to um introduce us to the end user probably

02:35:51 um introduce us to the end user probably for fear that they'd be cut out of the agreement um so uh so yeah it was more of a focus for the business for me to be approaching end users

02:35:59 end users and targeting end users rather than dealing by distributing it gave us no real indication of what projects our materials will then be used yes i see you say paragraph six of your

02:36:11 yes i see you say paragraph six of your witness statement on page two

02:36:17 and i'll just wait for that to come up so i can show you the paragraph my role is for the most part dealing with the commercial aspects of our customers requirements if i receive fire or acoustic technical

02:36:29 if i receive fire or acoustic technical inquiries i usually refer these to our technical department however if i do receive an inquiry for a standard application which can be answered by our fire or acoustic test data and installation guidance in our data sheets

02:36:41 guidance in our data sheets then i refer our customers to the relevant documents based on my experience of our product range i am able to advise customers on their general requirements if there are specific inquiries i cannot

02:36:52 if there are specific inquiries i cannot deal with then these are referred to our technical department do you see that there

02:36:59 and at the top of this page we can see that you also provide a paragraph for the bottom of paragraph four

02:37:09 um training sessions stroke cpds and you've touched on those already in your evidence

02:37:14 evidence yeah and at paragraph five that you conduct installation inspections and installation training is that right correct and provide mock-up installation

02:37:25 correct and provide mock-up installation on sites

02:37:26 on sites right so in order to take undertake those parts of your role would you agree that it required a degree of technical knowledge or expertise um i mean that's

02:37:37 knowledge or expertise um i mean that's just standard installation and application of our products and if i wasn't

02:37:41 wasn't fully versed on that i wouldn't be very good at my sales job you know these are all just standard things that are generally the process will be

02:37:49 will be design would be finalized um by our design team approved them by the project supervising authorities and once the designs have been

02:37:56 been finalized and accepted by all the key stakeholders on the project that's when i would or our now site services team would then arrive on site and with those set of design details

02:38:07 and with those set of design details that will be approved and then can block the mock-up in accordance with those and fully the installation processes of our products into specific specific details once those details have

02:38:19 specific details once those details have been finalized by all the necessary stakeholders you know such as our technical team and the project supervising authorities so i am responsible for or at the time was responsible for carrying out those things but only after

02:38:31 carrying out those things but only after um

02:38:32 um the engagement from our sort of technical and design team to the project supervising authorities and everyone had been satisfied and approved those details and to move them forward to start out yes i see thank you now we've considered

02:38:44 yes i see thank you now we've considered there some of the general support that you provided to customers and in terms of that general support did you ever receive feedback either directly or indirectly as to the clarity

02:38:55 directly or indirectly as to the clarity of cyber eyes installation guidance for cavity barriers

02:39:00 nothing that i can recall now returning to paragraph six there you say the fourth line from the bottom of the paragraph

02:39:14 and we covered it a moment ago based on my

02:39:18 my experience and knowledge of our product range i'm able to advise customers on general requirements if there are specific inquiries i cannot deal with then these are referred to our technical department so can you just clarify for me um where

02:39:31 so can you just clarify for me um where you draw the line in terms of general require

02:39:33 require general inquiries you can deal with and when you think those need to be passed to the technical department i'd like us to refer you back to my comments about how i frequently deliver cpds and

02:39:44 deliver cpds and the scripted content within our cpds that is offered by our marketing and technical teams a lot of that explains what the minute what the regulatory requirements are and the application of our barriers um so you know stuff that's within the

02:39:57 um so you know stuff that's within the public domain and documents that we publish you know i'm fully versed on but when it becomes to project specific inquiries where designs may deviate from

02:40:08 designs may deviate from standard application or standard installation instruction that's when obviously i look to then engage our technical officers and our wider technical team for their advice and input which is then directly relayed onto the customer

02:40:21 directly relayed onto the customer now you've talked about cpd's continuing professional developments and what would typically be covered in such cpd tools an agenda

02:40:32 such cpd tools an agenda for a typical speaking video and ventilated uh rain screen would be what the regulatory requirements are um specifically how our products are tested at the product level

02:40:43 tested at the product level um then there's guidance on um what tests are available to do full scale testing at the uh at the system level

02:40:54 the system level um and we also talk about the functionality of a ventilated facade and how it needs to function for drainage and ventilation or pressure equalization depending on what

02:41:05 pressure equalization depending on what panel types being used throughout its design life but then how our cavity barriers accommodate those uh standard functionalities of the ventilated facade throughout design but then we'll act to perform a

02:41:16 but then we'll act to perform a compartmentation seal uh in the event of a fire so we we we explain how cavity barriers uh react uh in the event of a fire and like i say the general process

02:41:28 the general process yes thank you um and were those cpg talks uh provided free of charge absolutely come requests they were then and they are now um and presumably that was also an

02:41:39 um and presumably that was also an opportunity for you to market siderise's products to contractors or subcontractors potential customers i mean at the time then reba approved once so we were able to talk about commercial elements

02:41:50 commercial elements as well it was more of a understanding of what the requirements are and then obviously how our our systems are tested to the most relevant statements now we know that from the witness

02:42:02 now we know that from the witness statement of mr swails and we don't need to turn to it that the three most popular cpd presentations at that time were

02:42:08 were one perimeter barrier fire stops in curtain wall facades two cavity barriers in rain screen facades and three sound transmission in curtain wall buildings so just focusing on that

02:42:20 buildings so just focusing on that second presentation cavity barriers in rain screen facades and very briefly what were the contents of that cpd exactly what i just explained and that was the agenda

02:42:31 was the agenda specifically for that cpv thank you that's helpful and did you or anyone else that side rise to your knowledge ever provide uh any of those presentations to

02:42:42 presentations to harley no

02:42:45 harley no did you ever offer any training to them yeah i mean as there was meetings which i'm sure will come to that took place when he whenever it was thirteen

02:42:56 when he whenever it was thirteen fourteen i got remember the dates off my heart

02:42:58 heart um where i visited their office part of my standard introduction to siderise pitch uh should i say

02:43:05 i say is explaining what our levels of service offer are

02:43:08 offer are we would have spoken about the installation of our system in comparison to the one which they were using predominantly on the majority of their projects um so all of that would have been gone

02:43:19 um so all of that would have been gone through

02:43:20 through it's my standard approach and pitch to prospects

02:43:23 prospects as a sales engineer for zadara so yes yes i see we know that siderise produced a range

02:43:30 a range of written guidance we will come to some specific examples later did you have any involvement in the development of any of that written guidance

02:43:39 guidance uh no no those guidance documents are not authored by myself

02:43:46 paragraph five of your statement you refer to providing installation training during site visits can i just ask you what topics would be covered

02:43:56 covered in a training that was provided on site as distinct from the cpds that you've already told us about installation training on site again we'll be looking to engage with technical to see if there

02:44:08 engage with technical to see if there was any design or technical advice that i need to consider when demonstrating the installation installation of our materials can whilst um functionally they're installed

02:44:19 whilst um functionally they're installed in pretty much the same way um how they interface with obviously every curtain wall and and rain screen clouding system design and the subframe that supports and dvhs from project the project

02:44:31 project the project um so so we always recommend and offer installation training even if they've had it before on a previous project the offer is then available again on the next one because how the system will be it's installed in

02:44:43 how the system will be it's installed in the same way in terms of our manufacturer guidance if there's anything that is uh uh bespoke to that particular project that we've dealt with at design stage i would familiarize myself with that

02:44:55 i would familiarize myself with that before then attending site to ensure that what i was demonstrating in terms of uh project specific

02:45:01 specific training uh coinciding with the mock-up um that i would have produced on site um coincided with what we agreed at design stage yes i see

02:45:12 we agreed at design stage yes i see and were there particular recurring issues with the installation of cavity barriers which often needed to be addressed by training in such manner it's not uncommon if people don't take us up on the complementary service

02:45:23 complementary service it's certainly not uncommon for companies that i don't install the system on a frequent basis and come on to us after they've installed a bit of work and they would have said we've got building control out

02:45:34 have said we've got building control out with nhbc out they've highlighted you there at these areas of concerns can you pop down and just do

02:45:40 just do an inspection yourselves and then it's kind of you should have got us in for the installation training at the start and you wouldn't probably have these issues

02:45:47 issues these are all complementary services that are on offer to every single person that is procurement and that's on every single project um you referred there to undertaking

02:45:58 you referred there to undertaking installation inspections um at the time of the grenfell tower refurbishment broadly speaking what proportion of ciderized projects would you

02:46:09 of ciderized projects would you undertake an inspection of the installation on difficult to tell it's a reactive service um it's it's i say part of my uh sales pitch better phrase to prospects

02:46:22 sales pitch better phrase to prospects when i'm looking to bring them on board even existing accounts they are fully aware

02:46:27 aware of the levels of service that are on offer um some take them up on some projects

02:46:31 projects and then what next because they feel they're confident in what they're doing for me to proactively be uh insisting on it on every single job um i'll be working 72 hours a day and

02:46:44 um i'll be working 72 hours a day and many more days a week than i currently do and to be able to facilitate that you know for every single project that every single contractor does normally when we've delivered uh installation training uh to a specific contractor on

02:46:57 training uh to a specific contractor on a specific product um more often than not especially in cloud morning they're going to be installing the same type of their system especially if they're currently manufacturer as well as installer and project the product so how our system would be installed into that

02:47:09 system would be installed into that particular one that project would be like for like on the next um not on every single project we get the request but if we do forget get the request they may well we'll have

02:47:20 get the request they may well we'll have to wait a couple of weeks to resource but um but certainly we would honor those requests were there recurring problems with installation in your experience um there is

02:47:32 in your experience um there is i mean these not before these are very simple systems to install um it's it's there's no rocket science the installation of our systems the areas of non-conformance that we commonly see are really around

02:47:43 commonly see are really around carelessness and workmanship you know leaving one two millimeter gaps um

02:47:49 um you know penetrating our barrier with with various subframes which is you know very common um is accepted on a lot of projects but it's then making good where the penetration's

02:48:01 making good where the penetration's taken place you know one two three four millimeter gaps are roots for for for smoke and possibly for us to be spreading so they're the areas of non-conformance that we generally see from project the

02:48:12 that we generally see from project the project rather than being a complete deviation from what our standard installation instruction is so really it's down the the areas of non-conformance are predominantly due to carelessness and poor workmanship

02:48:26 due to carelessness and poor workmanship did you ever take any steps to ensure that the recommendations arising from your inspections were carried out um again for us to proactively follow up every single one where there's areas of

02:48:38 every single one where there's areas of non-conformance um i mean you'll see on the which i'm sure we'll come to on the wailings house inspection that i carried out uh my closing uh paragraph on on that

02:48:49 uh my closing uh paragraph on on that report was please please reach out to us once you put these uh areas of the suggested remediation right um again for me to keep a log on every single one and follow up every single one is

02:49:01 one is practical we put our recommendations across and it's then kind of up to uh to to to the contractor and then the project supervising authority to ensure that that's been done to allow for sign off

02:49:12 off sign off doesn't come from us that comes from the project supervision authority so really it's over to them after we've we've left our recommendation and you set paragraph eight of your statements that's a sl50304

02:49:26 statements that's a sl50304 on page two and in the first line there siderise recognized that installation is crucial to the function of its product one of the main focuses of the company

02:49:37 one of the main focuses of the company is installation specifically providing assistance to his customers

02:49:41 customers you then go on in paragraph eight to detail a range of sources of installation advice that cider eyes provide and i'll summarize those now

02:49:52 provide and i'll summarize those now data sheets which include written installation instruction installation training installation inspection and then over the page to page three

02:50:04 and then over the page to page three a youtube video and an installation inspection template by the eye auditor app yeah so a range of sources of guidance for customers is that right

02:50:16 of guidance for customers is that right they're all upon request or they're in the public domain many of these things so

02:50:20 so you know easy for everyone to access and we'll come to it in more detail shortly but it's right that you inspected the fire stopping installation at weyland's house on that harley project didn't you

02:50:35 i'm sorry i'm not sure that the um audio picked up your answer there correct you hear me then yes thank you and if we turn to your email report

02:50:47 email report that's at three sil one on page two

02:50:53 you identify there a number of problems with the installation and again i will summarize those but if you think i've summarized them unfairly then please correct me but you deal

02:51:06 then please correct me but you deal there with installation in the incorrect orientation the second bullet point down insufficient fixings of the brackets and inadequate or no compression of the

02:51:19 inadequate or no compression of the product

02:51:21 product no rft tape where the products were joined and then over on page two my apologies page three uh the vertical fire barriers sitting between the

02:51:33 fire barriers sitting between the vertical cladding rails have been cut too small

02:51:35 too small so air gaps between the fire stopping in the structure in light of the extensive guidance on installation that side rise appears to have deemed necessary and

02:51:46 have deemed necessary and the number of problems you identified there at weyland's house would you agree that installation is not a straightforward process uh it is a straightforward process

02:51:57 uh it is a straightforward process um i mean this was quite shocking if i'm honest um to see this many areas of non-conformance on the system that if you were to witness the installation of it you would kind of

02:52:08 the installation of it you would kind of query um especially with the installation guidance that was was readily available to harley and how they got so many elements of this role um so this was actually quite an extreme

02:52:19 um so this was actually quite an extreme example of of quite a astonishing amount of non-conformances here i would i would say that this was certainly unusual to see this many

02:52:31 certainly unusual to see this many um in relation to this particular product

02:52:35 product can we turn now to sil50s227

02:52:41 and this when it appears will be a ciderised brochure entitled cavity barriers for rain screening cladding and we can see from the top right hand corner that it's dated november 2013 issue one do you see that

02:52:54 november 2013 issue one do you see that there

02:52:55 there and is this a document that you were familiar with uh i can't recall many moments ago it's it's it's

02:53:03 it's it's forever evolving but yeah i'm sure at the time i would have seen it and if we look there under the heading benefits there's a list of bullet points and the penultimate bullet point is ease

02:53:14 and the penultimate bullet point is ease of installation do you see that yeah so would you agree that cider eyes were presenting in their marketing material

02:53:22 material that one of the key benefits of its cavity barrier product was that it was easy to install if you can imagine having a sheet of rock wool

02:53:31 rock wool cutting it in a certain direction sticking two brackets into it and then fixing into the wall whilst from job to job there may will be certain interfaces and obstructions

02:53:42 certain interfaces and obstructions in terms of the actual uh installation process for that particular product as you've probably gleaned from my site and from actual explanation there that's all there is to it and then joining up the joints with uh with tape

02:53:54 the joints with uh with tape um there's there's not really an awful lot of rocket science to it and there's there's a lot of uh technicalities that go into the composition of our particular product to ensure that it performs in the way that it does

02:54:05 it does um but in terms of installation it's a very very very simple system to install and like i said the non-conformances that we use at ec or that i usually pick up on from project the project are general just carelessness um so

02:54:17 are general just carelessness um so holes being punched stuff being treated on site

02:54:21 on site um you know not with the product not being handled probably properly being damaged holes then appearing within and which are simple things to remediate right understand as a non-conformance

02:54:34 right understand as a non-conformance when i'm out and inspecting yes it would um would you agree that presenting the cavity barriers as easy to install might suggest to a potential customer

02:54:45 potential customer that lesser skilled installers would be required then it was in fact the case but what sorry lesser scaled lesser skilled installers i'll put the question again

02:54:56 again would you agree that presenting the cavity barriers as easy to install in the product literature might suggest to a potential customer that lesser skilled installers were

02:55:08 that lesser skilled installers were required than was actually the case um

02:55:14 really i mean it's it's just you know advertising at the product so is is is simple to install it doesn't suggest that um someone less qualified than a standard facade installer

02:55:25 standard facade installer you know it doesn't really really it's just advising that it's a it's a it's a simple system to install which it is and you say in the penultimate line of

02:55:36 and you say in the penultimate line of your witness statement on paragraph eight if we turn to that sal 50304 at page two

02:55:43 page two thank you very much in addition siderise have always to my knowledge i'm just finding that

02:55:57 and this is on page two of the witness statement my apologies penultimate line at the bottom of the page

02:56:05 page there it is in addition cider ice have always to my knowledge offered their customers installation training and post installation if we go over the page

02:56:18 inspection our full service offer which outlines our on-site support as in the siderise site services document which since 2016 has been available on the siderise website

02:56:30 available on the siderise website so can we turn to that document which is at

02:56:38 sil404265 we can see this is a document entitled ciderized site services version 1 january 2016 in the top right hand corner do you see that there

02:56:50 hand corner do you see that there is yeah and is it right that this is a composite document which sets out all of the services that ciderise offers to its customers yeah yep and can you help us with why it

02:57:02 yeah yep and can you help us with why it was felt this document was needed in january

02:57:06 january 2016. um it was us identifying in the market that we were perhaps offering something our competitors weren't um we wanted to formalize that offer into uh

02:57:17 into uh an official document that we could look to communicate with prospects that we're looking to bring on board and we felt it was something like it differentiated ourselves from from from other manufacturers in the market uh to

02:57:28 other manufacturers in the market uh to offer these extra levels of service that we were

02:57:31 we were already mined for were becoming more um more requests for within within the market and we were looking to develop an offer and to meet those market demands

02:57:43 and to meet those market demands this is as we can see from the top right hand corner version one so would it be fair to say that this was the first time that siderise had published

02:57:51 published one composite document an official document to outline our offer but that's certainly not to say that the contents within this document were not available at much earlier

02:58:03 not available at much earlier it was just something that was more formalized um as our um you know company grew and our our service offer was was evolving

02:58:14 was was evolving yes i see and it says that under the heading

02:58:17 heading the siderise technical team offers a wide variety a wide range of services to ensure that everything from product selection to final installation runs smoothly so would it be fair to say therefore

02:58:28 so would it be fair to say therefore that prior to 2016 and this document being published customers would have to make an express request to find out what support services siderise could offer

02:58:40 services siderise could offer um no it was my responsibility to ensure that any prospects that i was bringing on board and my general account management were all fully versed on the uh on the levels of service that were on offer and it was a

02:58:52 service that were on offer and it was a standard part of my pitch to any prospect that i was looking to bring on board who would subsequently place orders for our materials

02:59:00 materials i can confidently say that the likes of harley would have been acutely aware of the services that were offered to them because they actually took us up on those offers on the wayne's house project which was prior to

02:59:12 project which was prior to what happened at grandfather you know the installation that commenced at grenfell so they were aware of the levels of service that were on offer because they took us up on them and i carried them out yes thank you and mr chairman i note the

02:59:25 yes thank you and mr chairman i note the time i wonder whether that might be an appropriate moment to take the lunch break yes i think it would thank you well now mr k we're gonna have a break now so that we can all get some lunch we will uh resume at two o'clock please

02:59:38 we will uh resume at two o'clock please and i have to ask you please uh not to speak to anyone about your evidence or anything relating to it over the break all right

02:59:47 thank you very much see you at two o'clock thank you

03:00:01 you