Studio E architect Bruce Sounes gives evidence about material selection, building control compliance procedures, and value engineering decisions for Grenfell Tower.
00:00:17 yes would you like to ask mr sends to come back please
00:00:29 come back please right mr sons i'm sorry that the break was rather longer than we'd intended there were some practical problems with the technical equipment uh i hope someone told you what was going on yes yes
00:00:40 going on yes yes all right anyway you're ready to carry on uh yes yes thank you yes yes so mr stones i i just want to take you to another we've we've looked up the picture you gave us and we've found another one in the
00:00:51 and we've found another one in the series i think um that you referred to that you were shown at the hayes galleria meeting can we go to sea403516
00:01:05 there we go and that's more of a close-up of the ferrier point project so is that the kind of photo you think you were shown at that meeting
00:01:16 think you were shown at that meeting i do yeah yeah and and the just to be clear the mineral wool is the the pale yellow substance that's behind the cladding and you know instantly it's not there
00:01:28 you know instantly it's not there a pir or other phenolic product because it doesn't have the foil facer with the insulation name on it so you can separate the mineral you can see it's mineral wool you're saying yeah great
00:01:40 saying yeah great thank you and then just another question picking up um on my last theme did mr crawford ever say to you that he had got an
00:01:52 ever say to you that he had got an assurance from x over that the rs 5000 product was safe from a fire point of view so we know rs 5000 is the same as fr 5000 it was just marketed
00:02:04 the same as fr 5000 it was just marketed differently did mr crawford ever say that he'd had that extra assurance from x over
00:02:12 i i obviously watched neil's testimony and i was copied in through those emails september
00:02:24 through those emails september um 14 and march 15.
00:02:29 i think i think you're asking me to summarize all of that no i'm not i'm asking you at the time of the grenfell project thinking back at the time try and forget the the evidence that you heard
00:02:39 heard in the inquiry do you remember mr crawford ever saying to you that he'd got an assurance from x over that the rs 5000 was safe from a far point of view
00:02:55 as i say i thought that was covered in those emails much later i see so so you didn't know any more than within those email chains that were being disclosed at the time
00:03:06 being disclosed at the time yeah and i'm sorry to interrupt you can i ask you is your transcript functioning properly
00:03:13 um no actually it's gone back up to the top again the mind keeps resetting itself every few seconds as far as i can see i think that was part of the problem this morning that
00:03:24 morning that i think it was i i interrupt you only in case you
00:03:28 case you all those behind you need to have it working i mean i could manage without it yours working all right um this is working all right so we don't
00:03:40 um this is working all right so we don't need to stop i can't really it looked to me as though the feed onto the large screens is running pretty normally is that right yeah all right well then i can manage without
00:03:52 all right well then i can manage without it
00:03:53 it let's carry on ideally i would have it because it is helpful for me to have it but
00:03:57 but let's carry on your moment
00:04:02 will you let me know if it's a problem yeah i will then we'll see what you can do
00:04:06 do thank you so now i want to look at an email from september 2013. this is sea four zeros 8790
00:04:23 so if we can just blow up the top half of that for now this is an email from you on the 27th of september 13 to various people on the project including
00:04:34 including some tmo personnel matt smith of max fordham
00:04:38 fordham as well and some artelia people are there
00:04:42 there to each in limb we see um and you say this in the first paragraph dear or we met with harley curtin wall this morning to discuss the project they are very keen and have been tracking the project for some time
00:04:54 tracking the project for some time they are specialists in this type of project and then you've given a link to their web page they pointed to ferrier point as being very similar to grenfell although it is triple glazed and super
00:05:06 although it is triple glazed and super insulated
00:05:07 insulated we had forwarded them sample details and the elevation measure beforehand do you see that there yeah so um
00:05:17 you're referring there to the ferrier point
00:05:20 point project as being very similar and it's the ferrier point project photos you think you were shown in that meeting yes that's correct
00:05:32 did you you say there the ferrier point they pointed to ferrier point as being very similar to grenfell did you interrogate whether the similarity related to the insulation
00:05:44 similarity related to the insulation type
00:05:45 type or solely to the use of acm
00:05:50 um
00:05:54 neither actually i i think it was a tall um cancel block which had been overcloud and the windows replaced i think biggest yeah obvious so that's
00:06:05 i think biggest yeah obvious so that's what made it similar in terms of a project
00:06:07 project yeah i understand now there's no reference
00:06:12 reference here to any specific discussion about the insulation we may come back to some of this in terms of the acm but we can't see anything specifically said about the insulation
00:06:25 said about the insulation in this email is there no now i now want to look at what the nbs specifications said about the insulation this was part of the employer's requirements
00:06:37 requirements and just for the record you you begin to address this at paragraph 286 and following of your witness statement
00:06:46 when you drafted the insulation section of the nbs specification did you ever send that to x over or max fordham so they could comment on that
00:06:57 fordham so they could comment on that aspect of the specula of the specification
00:07:01 well i didn't prepare the specifications um
00:07:04 um you would normally consult with a relevant person while preparing them
00:07:11 them you wouldn't necessarily use them as a checker
00:07:15 checker but i don't recall obviously sending it and when you say i didn't prepare the specification is that because you're saying it was other more junior representatives of studio e that were doing the specification work i
00:07:28 that were doing the specification work i think we discussed this previously i think it was shared somewhere between um thomas wreck and adrian dress and i might have done some of it i i know i did the last
00:07:39 done some of it i i know i did the last but which was a section on revision to the doors right yeah i don't recall doing anything else yeah can we just look at the nbs specification this is sca 50169
00:07:52 50169 it's dated the 30th of january
00:07:56 2014. you see that in the little revisions box the tiny text there uh 30th of the january l1 doors revised you see that there yeah so this seems to have been a a revised version that was issued
00:08:08 a revised version that was issued because there'd been a change to the l20 doors package and then within that can we go to page 63
00:08:19 and this is the start of the 892 rain screen cladding section and then if we go on within that page 73
00:08:32 and we look at the top of that page we blow that up 776 thermal insulation do you see that there yeah and we can see it says manufacturer
00:08:44 and we can see it says manufacturer celitex two lines down and then there's actually the product given bit further down product reference fr5000
00:08:53 fr5000 aluminium foil face both sides do you see that there yes do you know who put together this part of the mbs specification within studio e
00:09:05 i i can't i mean i i can only guess but i think that's that's a bit unfair i know i i was it you that put together this section are you clear that
00:09:17 section are you clear that you did it do it or didn't i'm getting confident
00:09:25 in which case i'm not going to ask you that some of the detailed questions we put to
00:09:29 put to uh mr wreck on this can we just look back at your witness statement um this is sea three zeros one four two seven three at page one one eight
00:09:46 and i want to look at what you say at paragraph two eight seven in the first sentence
00:09:51 you say with regard to the installation i refer you back to paragraphs 43.9 and 116.2 where i discuss how the installation was selected by max
00:10:02 how the installation was selected by max fordham
00:10:02 fordham and then you give the specification for the insulation in the mbs which we've just looked at and i just want to focus on there on the use of your word selected
00:10:13 use of your word selected does it remain your evidence that the insulation was selected by max fordham
00:10:24 they put it forward in the first instance
00:10:27 instance would you agree with me therefore that a more accurate description of what happened is that max fordham suggested the use of a particular insulation product but it was studio e as architect who then specified it
00:10:40 as architect who then specified it in the employer's requirements yes yeah thanks now looking down just a little bit further on in your witness statement at this
00:10:51 on in your witness statement at this point at paragraph 292 on page one two one
00:10:59 you say in third line down on one two one
00:11:06 um you say at this stage we would not go beyond addressing the issues raised by building control in the early meetings specifically on the 6th of november 2012 which adrian
00:11:18 the 6th of november 2012 which adrian jess attended and 17 september 2013 paul hanson's building control comments received 31st december 2013 and the input from x over regarding fire
00:11:30 and the input from x over regarding fire strategy
00:11:31 strategy we would not usually seek to verify compliance of all materials and products prior to submitting a building control full plans application do you see that there yeah now we know
00:11:43 do you see that there yeah now we know that and we'll come to this later when i ask you some questions about building control that you didn't actually submit the building control full plans application until august 2014
00:11:55 august 2014 um and i i want to ask you about that last sentence can you explain why it was studio e's practice not to verify the compliance of materials and products
00:12:07 materials and products prior to submitting a building controls full plans application
00:12:15 well full compliance is only possible through an application as i understand it you you don't know until you've had the um submission
00:12:29 had the um submission verified and and agreed with building control so your compliance is subject to receiving that certificate it all depends on that process i think your more general question is
00:12:41 your more general question is would we um seek to satisfy ourselves that it would comply yes yes that's my that's my general question
00:12:50 question wouldn't you seek to satisfy yourselves about compliance of the materials and products prior prior to submitting a building control full plans application
00:13:03 invariably it's not something you doubt if you've specified something you think is suitable or you have been recommended or suitable
00:13:13 you do not expect to be told once you've submitted with it but do you agree if you don't do an internal check
00:13:24 internal check that the materials are compliant prior to submitting the building control application you're at risk of making a submission that might be non-compliant with the building regulations
00:13:39 i think every application involves a process of agreeing materials with building control and there is some risk attached to that in every every project
00:13:57 on a design and build projects stagey in particular i think it's it's not possible to confirm compliance well not that it's not possible
00:14:08 well not that it's not possible your efforts could come to nothing if the contract makes a change so you're unlikely to
00:14:19 to be sure that you have complied anyway so i think it would be nice it is it is it was not common practice to do a full part b
00:14:31 to do a full part b compliance assessment at stage d or staging
00:14:38 and i think what you've just said is because otherwise you'd be concerned that there'd be a change and it would be wasted work is that what you're saying that'd be one reason yes any other particular reasons
00:14:49 particular reasons building control might take a different view so is what you're saying that effectively what you're doing by putting a building control full plans application it is opening up a dialogue with building
00:15:00 is opening up a dialogue with building control about the compliance of the materials is that what you're saying i think every project we we seek to engage building control at the earliest opportunity to
00:15:11 at the earliest opportunity to understand um issues that need to be addressed yes i think i think that's my experience going back as far as i can remember you
00:15:23 going back as far as i can remember you would see
00:15:24 would see to get building controls input on the salient issues so just to be clear does it follow that there might be building control full plans applications you're submitting where you're not entirely sure that building control are going to
00:15:36 sure that building control are going to agree that the materials are compliant and you're anticipating they might come back
00:15:41 back at you and challenge that
00:15:46 at stage e i would expect them to be minor details
00:15:52 i'm talking about when the full plans application has gone in mr sones are you sometimes putting in the full plans application so that would be after stagey yes
00:16:04 stagey yes full plans in the first instance is the general arrangements and the details usually follow but when those details are submitted are
00:16:15 but when those details are submitted are there times when you're putting those details in and they've got certain products in them and you're thinking to yourself actually some of those building control might
00:16:24 might challenge might pick up on and we might have to discuss that further with them is that
00:16:29 is that part of the thought process obviously if there was any concern we would raise it sooner
00:16:37 sooner and i think i think that that is the root of your question is why weren't we concerned we had no reason to be concerned could you just help me a little further on
00:16:48 you just help me a little further on this
00:16:48 this um
00:16:52 would you satisfy yourself that materials complied with the regulatory requirements before you put them up to building control
00:17:05 them up to building control regulatory requirements and statutory standards well whatever i mean these aren't these aren't the way um people approach the proof document um
00:17:16 um people approach the proof document um well let me explain i'm a little surprised if if you're saying that you would propose materials to building control without being reasonably confident in
00:17:28 without being reasonably confident in your own mind that they did comply with any necessary requirement we were reasonably confident that they complied so you would satisfy yourself are you saying before you put materials
00:17:39 are you saying before you put materials up
00:17:40 up for consideration by building control that they did comply
00:17:45 in our minds we had no reason to be concerned
00:17:51 well that may or may not may not be quite the same thing but anyway on your game it's great oh well the standards as i as you've referred to them before
00:18:03 as i as you've referred to them before imply that that it's a clear cut whereas my experience is the satisfying the requirements of part b is is not so clear-cut it's now that that i understand i just
00:18:16 it's now that that i understand i just wondered what was lurking in this sentence that you've been asked about that you wouldn't seek to verify compliance before you submitted a full plan's application and i just wanted to understand whether you
00:18:29 i just wanted to understand whether you were saying that you would put up materials without being satisfied yourself
00:18:35 yourself of their compliance no i think that's taking it a bit um very wide interpretation of that statement
00:18:43 statement well that's why i'm giving you an opportunity to explain it
00:18:54 where products had been used before in the same instance in the same circumstances whether it be by ourselves or where we were aware in this instance
00:19:05 where we were aware in this instance that they had been used elsewhere we we had a measure of confidence that materials must comply
00:19:17 yeah it's all right yes thank you this was great would you agree that if you don't take
00:19:28 would you agree that if you don't take proactive steps to satisfy yourselves on each particular product project that the materials are compliant that there could be a significant impact on program and
00:19:39 on program and cost if it suddenly turns out that there's a non-compliance in the application
00:19:48 um most definitely there's a risk of impact on program and cost and i think as a lead designer you're thinking of that throughout
00:20:02 you're thinking of that throughout i see in your design okay
00:20:11 is what you've described so this process of saying well if it's been used in a similar
00:20:16 similar type of project we don't have to be you know
00:20:19 know we don't have to be concerned about the compliance do you think that was common in the construction industry at the time was that some an attitude you had to
00:20:30 was that some an attitude you had to other projects within studio e
00:20:35 um
00:20:47 i think if i if i can take the example of the installation yeah there's an email from ledbetter that we received i think it was in
00:20:59 that we received i think it was in january 2013 from a juan medina it doesn't appear in my statements and i have no idea if it's being disclosed but he's responding to to adrian about
00:21:12 he's responding to to adrian about the insulation he says i think you may need to use phenolic because it's a high rise
00:21:20 so if you're asking me was i was studio was it studious policy
00:21:28 i think i think there is a common understanding of where issues are and what is acceptable and i think at that point in 2013
00:21:40 people understood it was acceptable yeah i understand so so if if there had been any any alarm raised from any culture i think it would have come through quickly
00:21:54 if you studio e didn't take proactive steps yourselves to verify compliance before the building control full plans application um when in the process would you expect
00:22:08 um when in the process would you expect compliance of the materials to be addressed either by you or someone else
00:22:15 so you haven't taken those proactive steps prior to the building control full plans going in is it a question of just waiting for building control to come back to you or would you conduct a compliance
00:22:27 or would you conduct a compliance assessment yourselves a positive one at some point
00:22:32 i think you've asked me this before and that is a duty which goes i would argue goes far beyond our role at any point
00:22:48 what i think for instance the the the smoke
00:22:51 smoke smoke ventilator subcontractor did as he engaged in a dialogue from an early point with building control
00:23:00 control to reach an agreement
00:23:03 and that was a particularly difficult item usually in in preparing your designs it's when you get to the final detail design
00:23:15 to the final detail design that you would
00:23:18 to avoid a board of work never mind any impact on the project you would try and understand for yourself that it complied let's take your example the insulation which is what we've been discussing as an example
00:23:29 discussing as an example so you yourselves haven't positively sought to go out and confirm that it does in fact comply you've assumed that from basically the fact you know it's been used on other
00:23:40 fact you know it's been used on other product
00:23:40 product projects
00:23:44 what is the position after the full plans application goes in if if building control don't come back to you and query the insulation does there come another point in the process where you studio e would it
00:23:54 would it would have checked for compliance with the building regulations
00:24:01 not on this project i can't i don't think we would um it's a design and build i'm not sure that the full effect of design builders
00:24:12 design builders is understood by the inquiry it does sideline the original architect's role from what it was pre-innovation
00:24:23 from what it was pre-innovation we're no longer in any sense policing what other people are doing okay
00:24:31 um now before we leave the topic of insulation i just got a few questions about the selection of the insulation after
00:24:39 after the employer's requirements were prepared
00:24:42 prepared and did you ever review as far as you were aware or did studio e review the specification of celetex fr 5000 once the design was changed
00:24:53 5000 once the design was changed to the reynabon acm panels in order to check whether the products were suitable in this different application
00:25:04 did you ever ask harley xova or ryden whether the change of cladding arrangement had any implications on the type of insulation to be used
00:25:16 now in fact we know that it was celatex rs 5000 which was eventually finally chosen for use on the project and not the fr 5000 product do you know when that
00:25:29 product do you know when that substitution took place
00:25:35 um i i don't know no were you aware of that substitution at the time
00:25:44 i might have been i i was copied in on the emails so but whether i was i can't remember do you know why this different celetex
00:25:56 do you know why this different celetex product was selected
00:26:03 i i'm afraid too much time has passed i'm just seeking to understand how how involved you were in that bit of the project because i know by that point mr crawford
00:26:13 crawford was more the day-to-day point of contact within studio e i'm afraid i'm i'm at risk of saying something that overlaps with something that he said and i'm not sure okay
00:26:25 that he said and i'm not sure okay um i do want to ask you something about mr crawford's evidence and what he said he
00:26:31 he he said this is day nine page 139 lines 18 to 20. he said that you were fairly adamant about the appropriateness of using
00:26:42 of using fr 5000 on the project yes that you had been fair he said you were fairly adamant about using the fr 5000
00:26:52 5000 with reference to what was in the nbs specification did you make that clear to mr crawford sorry what was the context mr crawford
00:27:03 sorry what was the context mr crawford said in his evidence that you were fairly adamant about the appropriateness of using the fr 5000
00:27:10 fr 5000 on the project that's what he said and i just wanted to ask whether you recall having conversations with mr crawford in which you were expressing a confidence or being adamant
00:27:21 expressing a confidence or being adamant with him the fr 5000 was appropriate
00:27:29 i can't remember i'm afraid any any conversation that was that definitive okay so i just want to ask you just a few questions about the calc project the kensington academy
00:27:41 calc project the kensington academy leisure center project and then we're going to come on to look at the the big topic for today which will be the acm panels um so you told us on back in march on day seven of your
00:27:53 back in march on day seven of your evidence that you were involved in calc but primarily in the bid process is that right yes um and you also said that you were aware of the specifications for the calc project
00:28:05 specifications for the calc project such as the external wall build-up but that that came later is that right yes
00:28:14 can you recall when you came to know about the details of the external wall build up on the calc project specifically for the school can you recall approximately when you might have known about that
00:28:28 might have known about that i'm not i'm sure what you're going to ask me about the calc facade because i'm not that familiar with it
00:28:35 with it okay well let me ask my questions and and if you're not familiar with it then please say um can we just go to
00:28:45 sca406047
00:28:52 and i want to look at the third email down on that page at the very bottom of the page this is from mr kushel to mr lloyd jones copying you and others in within studio e
00:29:03 others in within studio e and you say david let's stick with wednesday for a design review and then you say this the technical audit for calc would best be carried out by bruce or mark
00:29:14 by bruce or mark or both and then you talk about availability um were you ultimately asked to do the technical audit for the calc project
00:29:27 for the calc project i i can't remember you can't remember so you can't remember whether you did it on the calc
00:29:36 i can't remember sorry i might have done i don't i don't i think um
00:29:46 neil would have formalized it in other words the record would have been i think prepared by him so i might have done but i because i
00:29:57 so i might have done but i because i didn't prepare anything i don't recall i see so you're saying because mr crawford might have prepared the documents for it yeah and more clear to me to you that you yeah he was involved but i
00:30:10 you that you yeah he was involved but i i don't recall being involved it's possible though okay perhaps i can ask then
00:30:15 ask then were you aware that on the academy that the school project and non-combustible mineral insulation had been used in the cladding system was that something you had an awareness of at the time
00:30:30 and there's a document which shows that the build-up was an acm panel with combustible styrofoam insulation backed with a non-combustible mineral insulation
00:30:41 insulation now remember cut the academy was a low-rise building so i'm not suggesting that was non-compliant i'm just asking you whether you knew about that wall build-up and the use of the non-combustible mineral insulation
00:30:53 non-combustible mineral insulation as part of it no no
00:30:58 no [Applause]
00:31:02 okay so let's move now to ask um i'm going to ask you some questions about the rain screen cladding itself the the acm and including the eventual decision to use the aluminium composite
00:31:13 decision to use the aluminium composite material panels can we start by looking at paragraph 71 of your statement this is sea three zeros one four two seven three at page 35.
00:31:29 um and you say this you say after some searching online i approached cep architectural facades limited cep a cladding product supplier with a view to meeting to discuss the project
00:31:42 view to meeting to discuss the project as i recall cep had experience in overcladding residential towers particularly in the midlands where they were based and then you say my recollection is that jeff blades of cep
00:31:53 jeff blades of cep may have met one of my colleagues possibly marcus kiefer on site in april this is 2012 by the way so this is early on um and i met him at our office a week or so later perhaps on the 11th of april
00:32:05 so later perhaps on the 11th of april 2012.
00:32:07 2012. and then you say jeff emailed me detailed drawings for a project called stretford house on 5th of april 2012. they showed a multi-storey brick building with new windows external insulation and acm cladding do you see that there
00:32:20 and acm cladding do you see that there yes
00:32:21 yes now i just want to be completely clear about how cep came to be involved is it right that you were not familiar with cep before this project no
00:32:32 before this project no and you found them as you say there by searching on the internet is that correct
00:32:36 correct yes was there anything particular that drew your attention towards them over clouding of high rise yes
00:32:48 council blocks so you could see that on their profile could you yeah and they're a cladding product supplier is that right um
00:33:01 that's in retrospect at the time i wasn't entirely clear what they did i know they were involved but i wasn't sure if they were a contractor or fabricator supplier i see yeah
00:33:13 supplier i see yeah can we then go to cep3048112
00:33:24 can we then go to cep3048112 and i want to look in the middle of that first page uh to the email yes of the 4th of april 2012 from mr keefer to jeff blades copying you in and he says dear jeff
00:33:37 in and he says dear jeff bruce instructed me to issue you some information regarding the grenfell tower upgrade
00:33:42 upgrade hence find attached our drawing showing indicative existing floor plans in the south elevation as well as photos of the tower since we
00:33:53 photos of the tower since we since we are further meeting with the client on the morning of the 9th of april 2012 we would appreciate your initial thoughts regarding the appropriate cladding systems and the rates associated with them and
00:34:04 and the rates associated with them and then if you have any queries please do not hesitate to contact bruce or myself do you see that yeah and then he says no this is one of five emails because of the size of the attached files
00:34:15 the size of the attached files and so you're asking cep for their uh initial
00:34:18 initial thoughts and then if we can go to mr blade's response this is at sca403941
00:34:32 if we can blow that up so this is his response it's just to you on the fifth of april he says bruce please see the attached details which may
00:34:41 may be of benefit for your meeting on tuesday do you see that there yeah and we can see from the attachments that what he's done is he's emailed you drawing details
00:34:52 drawing details of a multi-story brick building called stretford house which had new windows external insulation and acm cladding um now do you recall having any impressions
00:35:05 now do you recall having any impressions of the details provided to you by cep when you receive them
00:35:12 no i'm i'm i may have opened one or two but at the time given that the project was just
00:35:20 was just setting out i don't believe i looked at them or scrutinized them in any detail yeah did you notice that from the the details that were sent that the cep system involved rockwool insulation
00:35:32 insulation we can see that just to make that good let's look at sca403943
00:35:42 this is one of the details that he sent you
00:35:45 you we can see it's for the stratford house project and the label on the bottom right hand corner and if you look uh on the left hand side the first written label
00:35:56 written label if we can zoom into that yeah it says rockwool duo slab insulation there do you see that yeah but you didn't note that at the time
00:36:07 time did you ever discuss with mr blades of cep
00:36:10 cep what insulation product to use at the gran on grenfell no this was before the u-value um discussion started i mean this was
00:36:22 um discussion started i mean this was within a week or two of within a month of
00:36:26 of our first site visit yeah did you notice um at the time that some of these drawings refer to fire barriers within the cladding build-up i did not notice that at the time
00:36:38 now let's go on to sea403965
00:36:46 and i want to look at the second email down on the first page
00:36:53 this is an email from you to mr blades of the 10th of april 2012 and it's clear from the email that you've arranged to meet at site the following day
00:37:04 um when this email is sent and because you say in the beginning we would like to meet at site tomorrow rather
00:37:12 rather than our office and you say the site address is a little complicated you give the address i might need to leave before you get there and then in that last paragraph on that page you say it's important to be
00:37:24 that page you say it's important to be discreet while we are there as the political context for the development and the development of the adjoining site is very sensitive i would refrain from discussing with residents or staff who you might meet or
00:37:35 residents or staff who you might meet or discussing drawings where anyone can see them there is enough misinformation about on the estate and we don't want to add to it unwittingly now i'm going to come back and ask you
00:37:46 now i'm going to come back and ask you about this in the context of the whole question of resident engagement um separately but just it's part of the chronology here um did you end up meeting mr soones on
00:37:59 um did you end up meeting mr soones on site
00:38:00 site sorry mr i think your presence you are mr mr blades on site the next day i don't think i can't remember meeting him now
00:38:08 him now do you recall do you recall that have any recollection of meeting you said i might need to leave before you get there so it's possible it was mr kiefer that he met well i'm pretty sure i didn't meet
00:38:19 met well i'm pretty sure i didn't meet him on site um i'm i think marcus might have met him on site that's the memory i'm trying to to draw on
00:38:32 memory i'm trying to to draw on um you say in that email that the political context was sensitive um the political context for the development and the development of the adjoining site is very sensitive
00:38:44 the adjoining site is very sensitive why did you say that what was the reason for that
00:38:48 for that um prior to this i had received an email from
00:38:56 mark anderson in the tmo warning me or speaking to someone in the tmo
00:39:04 tmo um saying that any well well go back to the context the context was the development of the calc projects
00:39:13 projects [Music]
00:39:15 [Music] the developments on the joining site is very sensitive and there had been
00:39:22 some objections raised to that development um the reason i think i might have warned him is to not discuss things openly was that email from mark anderson
00:39:34 openly was that email from mark anderson i see okay okay now as you said just a minute ago in your statement you said that you think you met jeff blades at your offices the next day on the 11th of april 2012.
00:39:47 the next day on the 11th of april 2012. that was a paragraph 71 of your statement mr blades recalls that it was a meeting on site
00:39:55 on site um and we can see here that you've emailed him the day before about a meeting on site um do you think looking at this now that you may have been mistaken that it was at your offices and that in fact it was
00:40:06 at your offices and that in fact it was at sight
00:40:08 at sight i thought there were two different days sorry um
00:40:12 i remember meeting jeff i i can't remember meeting him on site okay i don't remember that
00:40:20 if the meeting was at sight mr blades would have seen it would have been obvious wouldn't it that grenfell tower was a building over 18 meters high yes yeah
00:40:32 do you have any dis memory of any discussion with mr blades around the 11th of april 2012 about the performance of cladding in fire was
00:40:43 the performance of cladding in fire was that discussed at all at this early stage with him not to my recollection though now after the meeting with with mr blades there was a design team meeting
00:40:55 team meeting number one on the 19th of april 2012. for the transcript the notes of that are at tmo one triple zero one one four three and we don't need to turn
00:41:07 four three and we don't need to turn that up but following that meeting you wrote to the tmo i want to look at that this is sea404051
00:41:21 i want to look at that this is sea404051 now this is an email date of the 20th of april 2012 to mr anderson
00:41:28 of the tmo and i want to focus on what's said in
00:41:32 said in the second paragraph about the cladding there you say um so just to put this in context you seem to be talking about engagement with the planners
00:41:43 planners that had run on until 2 p.m that's in the first
00:41:46 the first part of that first paragraph and then you say this the comments on the appearance sorry in the second paragraph you say this the comments on the appearance of the tower were limited
00:41:58 tower were limited but the both ed and james were uncomfortable with the suggestion of aluminium cladding plastic and croiden were the words used and a render system would be their first preference
00:42:09 preference with a request to consider leaving concrete columns exposed and then you've got this is likely to be problematic they sound very amenable to meeting when we're ready the pre-application charge
00:42:21 we're ready the pre-application charge is no longer an issue any on calc but they were not sure about grenfell do you see that there yeah so i just want to ask you um about those comments about how uncomfortable planning were at
00:42:33 about how uncomfortable planning were at this stage about the suggestion of aluminium cladding did you take it from the meeting you'd had that acm would be unlikely to get through the planning process
00:42:47 um i don't mention acm and i wouldn't have automatically inferred acm from that i see so you're saying
00:42:56 saying that what had been suggested was just aluminium cladding is that right
00:43:03 in fact i would even go so fast to say the emphasis on the materiality is maybe not fully what they were communicating they were communicating a
00:43:14 they were communicating a plastic effect that a flush block can achieve if it's all
00:43:22 covered in a panel a seamless featureless panel um system and i think that's what they refer to as plastic it looks like a plastic box i see so you're right so i don't think
00:43:33 you're right so i don't think i don't think that that's possibly
00:43:38 at this point when we're talking in such general terms i i don't think the because they did eventually agree to element you might don't think it was the material itself that they
00:43:50 it was the material itself that they were objecting to yeah it was just the concept of having a metal
00:43:54 metal featureless panel featureless block yeah
00:43:58 so was the plan as concerned based on appearance yes yeah did anybody at this early stage raise any concern about fire performance you you wouldn't
00:44:11 about fire performance you you wouldn't expect
00:44:12 expect well that that is obviously handled by building control not by planning yeah and we see from the rest of the second paragraph of the email
00:44:23 of the second paragraph of the email that the planners also suggested a render system as their first preference can you just explain to us so people understand what is a render system
00:44:35 it's quite complicated um is it effectively kind of sticking material to the existing concrete kind of plastering material onto it a substance
00:44:46 substance for this application you would be looking
00:44:50 looking at an insulated render system of which there are numerous on the market some of which apply a reinforcement mesh directly to
00:45:01 apply a reinforcement mesh directly to the insulation and then build up a sometimes very thin layer of
00:45:06 layer of um we call it render plaster yeah on top of it because it's very thin it invariably involves a lot of polymers it's a it's a reinforced polymeric of
00:45:19 it's a it's a reinforced polymeric of some sort um and they get more involved with um
00:45:23 with um backing boards and cavities but but fundamentally they're in a trial done surface yeah can you just explain briefly why that wasn't preceded why was that not really
00:45:34 wasn't preceded why was that not really thought about any further
00:45:38 i i think it comes up in com conversations later but uh any render even a polymeric type which you wouldn't expect
00:45:49 polymeric type which you wouldn't expect to repaint builds up can pick up a lot of dirt and invariably can crack at corners at junctions and needs to be
00:46:01 corners at junctions and needs to be repaired and cleaned frequently for it not to look very unsightly yeah so i think in the lifespan of the planning application the idea of
00:46:13 the idea of a render fell away for those reasons yeah is it fair to say that at this stage the selection of materials for the cladding was largely driven by aesthetic considerations that that was
00:46:25 aesthetic considerations that that was uppermost in people's mind yes now can we look at paragraph 111 of your witness statement this is sca 3014273 at page 52.
00:46:41 i just want us to read that together you say on the 27th of july paul duncan of the tmo emailed me and asked for information for the resident's newsletter regarding the proposals
00:46:52 newsletter regarding the proposals the same day blaine cagney emailed him attaching images for the newsletter including one for the vmz composite which said it had a polyethylene core fr fire retardancy
00:47:06 polyethylene core fr fire retardancy i recall that we were still researching cladding options at this stage i note that in an august 2012 version of the kctmo project newsletter the cladding with the most favorable reception from the residence
00:47:18 reception from the residence consultation was a zinc cladding system illustrated as vmz composite with a polyethylene core fr fire retardancy do you see that there yeah
00:47:28 yeah now again in a separate topic i'm going to come to the question of resident consultation and what the residents were shown in terms of different
00:47:36 different cladding options um but i just sticking with the theme of acm there you refer to um mr cagney sending mr duncan uh
00:47:49 mr cagney sending mr duncan uh images of potential cladding panels can we just
00:47:53 we just look at that information that was sent by mr cagney it's at sea four zeros five three three zero
00:48:07 and this is for the bmz vm zinc composite panel
00:48:14 and um we can see it said there that um in the top middle of the page that vmz composite is a system made up of two sheets of zinc
00:48:25 sheets of zinc and a high density mineral rich core combining the qualities of the zinc with the rigidity and flatness of composite
00:48:33 composite this combination offers unique architectural possibilities for facades on new or renovated buildings do you see that there yeah and on the right there's a little diagram and
00:48:44 diagram and the label at two says polyethylene core fr brackets fire retardancy do you see that there yes now did you know what polyethylene
00:48:55 yes now did you know what polyethylene was at the time
00:48:59 not more than that it was a plastic did you know anything about its fire performance no
00:49:08 did you understand what these references to fr
00:49:11 to fr fire retardancy meant at the time in terms of fire performance
00:49:17 um if our
00:49:22 if i had not seen the fire return retardancy ended i would have just said fire rated i would have just read this meaning fire rated
00:49:33 rated do you remember noticing at the time that it
00:49:36 that it said fr fire retardancy in relation to this product
00:49:41 i can't remember the circumstances where i asked blaine to send this but i don't think i looked at it okay and there's the words in the in the middle which we read as well saying a high density
00:49:52 high density mineral rich core and does it follow from your answers that you didn't think about that phrase either in terms of what it might mean in terms of fire performance
00:50:06 when you sent this sheet had you or anyone else at studio e as far as you were aware investigated whether these vm zinc composite panels would comply with the building
00:50:17 would comply with the building regulations and the guidance in approved document b for buildings over 18 meters no at this stage we were just researching options yeah
00:50:29 was there any particular reason why this panel sheet for this bmz composite was sent to
00:50:36 sent to mr duncan of the tmo can you remember what the rationale was for sending for singling out this product and sending the detail to him
00:50:50 i know that well i don't know but i can't remember i haven't tried to piece this bit back together in my mind but i know that we had a
00:50:59 had a public engagement or resident consultation yeah around the state yeah and i believe we presented several options yeah on the boards
00:51:10 yeah on the boards we didn't i don't think at that stage we had samples
00:51:15 and i i think that the request to put something in the newsletter was came out of that that um evening event yeah and i think that's
00:51:26 um evening event yeah and i think that's where this that came from okay did you give any consideration at this stage to using a panel with an fr fire retardancy call no
00:51:37 fr fire retardancy call no did you think to check with x over whether this type of panel would be appropriate for use on the grenfell project
00:51:45 no now we know this was not the main panel that you ended up including in the uh for the main part of the mbs specification we'll come to that
00:51:56 specification we'll come to that in due course when we look at the proteus honeycomb panel um can we now go to sca405
00:52:06 [Applause]
00:52:13 and if we can blow that up we can see from this that it's on the 7th of august and it's you emailing mr anderson and the dunk mr duncan of the tmo copying in a number of others including
00:52:25 copying in a number of others including some at max fordham about the project
00:52:30 and it appears to be about a meeting that you've had with the planners that morning you say mark uh mark and i had a positive meeting with edward george this morning now edward george was one of the rbkc
00:52:42 now edward george was one of the rbkc planners wasn't he yes yes and you say in the second line he was comfortable with the zinc agreeing the joints on the triangle pilisters could be accentuated
00:52:53 pilisters could be accentuated do you see that there yeah now when you said that he was comfortable with the zinc
00:52:59 zinc what exactly did you mean did you mean he was comfortable with the aesthetic look of zing yes the appearance that's yeah when
00:53:10 the appearance that's yeah when discussing elevations that's not the only thing that planners look at but that's in this context what he was looking at yeah so it was that that made him comfortable was it yes yeah
00:53:22 now can we turn on to your statement at paragraph 114 this is sea three zeroes one four two seven
00:53:29 seven three at page 53 there you're dealing with the email of the 7th of august 2012 which we've just looked at and i want to focus on the last two sentences in the last five lines
00:53:45 you say
00:53:51 in terms of building control compliance this is five lines up from the bottom in terms of building control compliance at this stage i don't believe anyone then would have highlighted this
00:54:02 anyone then would have highlighted this of being of particular relevance to cladding selection we all believed we were choosing cladding products that had been used many times before do you see that there
00:54:14 many times before do you see that there yes and i want to ask you about that last phrase so just to be clear by august 2012 you've not yourself investigated whether the panels you were
00:54:25 investigated whether the panels you were considering complied with the building regulations no and i think we established this earlier
00:54:33 earlier in your evidence that you've made an assumption that they must be compliant because
00:54:37 because they've been used on other projects is that right yes yeah
00:54:49 would you agree though that you didn't know the specific context in which such materials had been used on other projects you didn't have full details of other projects at this time
00:55:00 details of other projects at this time so you wouldn't know the full context in which
00:55:03 which no those panels have been used now if we can go on to look at paragraph 136.6 of your statement that's on page
00:55:18 65. now there you go on to talk about a meeting on the 16th of october in 2012 at your offices where
00:55:31 in 2012 at your offices where cep introduced studio e to debbie french we just read this paragraph you say on the 9th of october 2012 jeff blade cep emailed me regarding a meeting to discuss the rain screen
00:55:42 meeting to discuss the rain screen materials
00:55:43 materials i have no record of why he called me but my recollection is that he thought we may be interested in a zinc composite panel that rayna bond offered i recall that i met jeff and debbie
00:55:55 i recall that i met jeff and debbie french of rainer bond and our office calendar records it as having happened on the 16th of october 2012
00:56:02 2012 at studio e llp's office and then you say while i do not recall much of the detail of the meeting in these short sort of product representative meetings
00:56:13 sort of product representative meetings usually i would have talked them through the drawings and then they would discuss finishes sizes fixings and details my recollection is that jeff
00:56:24 and details my recollection is that jeff and or debbie brought product samples to the meeting including i think a paint effect zinc acm amongst other metal effects rayna bond offered do you see that there yeah
00:56:36 yeah and then a little bit further on in that paragraph you say i do not recall cep or raina bond discussing the plastic core of the panels nor providing any recommendations for buildings over 18 meters in height
00:56:48 buildings over 18 meters in height raynabon's name would continue to come up in the next stage in conversations with the contractors however we never approached them directly for advice nor luca bond who i've been aware of since i was a student
00:57:00 i've been aware of since i was a student so um we have all that did you um i think it was september last year we came across in our office the some of the material that we gathered
00:57:11 some of the material that we gathered from yes and i think you sent that to the inquiry at the time yeah you have seen that i believe we've seen that i'll double check but i think we have seen that um so you've helpfully
00:57:22 um so you've helpfully explained uh the meeting here um in your experience is it common for a supplier
00:57:30 supplier that was cep to broker a meeting between a particular manufacturer and an architect does that occur frequently on projects
00:57:43 hmm
00:57:50 i'm sorry you're i think this was an unusual meeting yes i agree but i wouldn't have thought anything untoward about it
00:58:01 anything untoward about it no i'm not suggesting anything untoward i'm just asking you how common it was that
00:58:05 that a supplier like cep would would set up a meeting with a particular manufacturer did that strike you as unusual at the time
00:58:14 time [Music]
00:58:20 not really unusual it wasn't i mean it was an unusual meeting yes because but but it also was logical because he knew we were interested in zinc
00:58:29 zinc yeah yeah round upon had this um paint effect
00:58:33 effect sink yeah when you say it was an unusual meeting why do you say that well i think he approached us rather than we approached him i see specifically on this some
00:58:45 i see specifically on this some material choice now you said there that you don't recall the details of that meeting but you say it's likely that you talk them through the drawings for the project
00:58:55 project um would that have given an indication of how high the tower was at that meeting would you have talked about the fact it was a multiple-story residential block i
00:59:08 multiple-story residential block i i believe i would have
00:59:12 now you've indicated that the discussion at this meeting was around raynabon zinc panels do you recall was anything about
00:59:19 about costs discussed at this meeting
00:59:30 i can't remember any specific conversations about cost but um so you can't recall whether anything might have been said at that meeting about zinc being too expensive in the light of the budget did you have
00:59:42 in the light of the budget did you have any such discussions i don't know if it was as i say i can't remember any specific discussion about cost but i think it's understood that an aluminum product would be
00:59:53 that an aluminum product would be cheaper than a zinc product okay you understood that at the time did you yeah did you understand at the time of this meeting that there was a difference between
01:00:02 between zinc composite material panels and pure zinc panels yes you knew the difference between a composite panel and a yeah do you know whether aluminium
01:00:15 yeah do you know whether aluminium composite panels were mentioned as an alternative at this meeting
01:00:22 well that i think i believe that think patina which i believe there is a sample of in that
01:00:31 folder file of samples was a an acm with a zinc effect painted on i see but do you remember discussing that at the meeting
01:00:42 discussing that at the meeting that aluminium was another option other than zinc composite
01:00:49 we're looking at various options yes
01:00:53 do you remember any specific discussion about fire safety at this time no or about fire performance of particular panels
01:01:02 now i now want to ask you just some questions about value engineering um just in terms of the overall concept do you agree that value engineering is the process of trying to find more cost-effective
01:01:14 of trying to find more cost-effective ways of achieving the same outcome or achieving a better outcome for the same cost
01:01:23 i agree with the first sentence i think you could have lifted that from my statement but the second one yes i'd agree with that too yeah in your experience is value
01:01:34 yeah in your experience is value engineering a common process that occurs on construction projects in the uk
01:01:41 yes prior to the grenfell project had you been involved in value engineering exercises before on other projects yes
01:01:54 on other projects yes can we go at this point to sea um an email that i want to look at sea
01:02:04 407413
01:02:08 if we can just blow that up a little bit more great so this is from alan dawson of apple yards or later artelia dated the 26th of february 2013 and it's
01:02:20 dated the 26th of february 2013 and it's to you
01:02:20 to you and your colleagues at studio e and copying in some others including at the tmo
01:02:28 the tmo and the subject is headed grenfell tower regeneration project value engineering do you see that there
01:02:37 and it says gents as as you are aware there's currently a significant deficit between the approved cost plan budget and the initial figures coming back from ledbetter
01:02:48 ledbetter not least of which on the external facade and general fit out where we are as much as 483 thousand and 1.24 million apart respectively
01:03:01 and 1.24 million apart respectively and then he says clearly we have to reconcile but moreover bridge this gap as a matter of some urgency your urgent assistance in this regard would therefore be appreciated can you come back to us with a radical
01:03:12 can you come back to us with a radical rethink of the scope spec while still meeting the original brief
01:03:16 brief by early part of next week to deliver it within budget and then he says if you have any queries as to what's required please don't hesitate to give any of the team a call and then he asks for your availability
01:03:27 and then he asks for your availability for a meeting do you see that there yes so this was about 11 months approximately before the nbs specification was finalized in january 14.
01:03:38 14. and we can see he's mr dawson is saying that there's a significant deficit between
01:03:44 between the approved cost plan and and the budget and between the initial figures coming back from ledbetter at that stage um now we know from your statement that the cost plan had been based on zinc
01:03:57 cost plan had been based on zinc you've told us that that's at paragraphs 43.5 and 116 to 119 for the transcript um and it would appear from this email
01:04:08 um and it would appear from this email that ledbetter are quoting 000 more for the facade than had been anticipated is that right
01:04:18 i think we see that that's quoted there yes yeah not least of which on the external facade and and general fit out where we are as much as
01:04:25 much as 483k and 1.24 million apart respectively so i think the external facade is said to be
01:04:31 to be the 483 figure do you see that there yes
01:04:37 and you're asked in the second paragraph to undertake a radical rethink of the scope spec do you see that there so this is a significant email to receive would you agree
01:04:48 receive would you agree in terms of your design of the external
01:04:52 wall um i'm sorry um do i think it's significant it because of the word radical we think of
01:05:03 because of the word radical we think of the scope spec i think he's out of line frankly say that again i think he's out of line um
01:05:13 can you explain why you think he's out of line he's not the client
01:05:19 but he's the if it's a radical rethink it's it's not value engineering i see mr dawson so he's apple yards artelia they are um performing the function of employers
01:05:31 um performing the function of employers agent
01:05:32 agent project manager as well as quantity surveyor and well you say project manager but we know that's i know it's disputed but i have seen correspondence supporting it they're they're engaged to carry out the
01:05:45 they're they're engaged to carry out the employer's agent cdm coordinator and quantity surveyor roles
01:05:51 roles so that so they're coming back to you just on your reaction was your reaction at the time you're out of order for telling us this
01:06:02 you're out of order for telling us this no it wasn't i wasn't that strong a response but i i do think to introduce the words radical rethink is completely at odds with value
01:06:13 is completely at odds with value engineering i see okay
01:06:20 now you replied to that email on the same day can we look at that now can we go to that sea four zero seven four one four
01:06:39 so we see on the 26th of february you go back to
01:06:43 back to him and and others and you say allen it is not really possible to undertake a radical rethink without sight of the figures
01:06:51 figures a discussion with the client and the involvement with the services engineer who is not copied into your email is the m
01:06:58 m e not under review as well and then you say what you think the obvious targets for savings are do you see that there yeah and um you say in that second
01:07:10 and um you say in that second subparagraph you've got change zinc cladding material to something cheaper i think planning will need a sweetener to swallow this perhaps copper ceramic terracotta or more glass at low
01:07:23 ceramic terracotta or more glass at low level
01:07:23 level do you see that there yeah and you also say there just to pick it up now you say scale back crown this will also be planning sensitive do you see that in the next sub paragraph
01:07:34 you see that in the next sub paragraph yes
01:07:37 did you have um aluminium also in mind when you wrote this email as in aluminium composite material as a potential
01:07:46 potential cheaper option that you might be able to change
01:07:49 change i was certainly aware of it at that point yes
01:07:55 and would that have been based on your meeting and discussions with cep and iconic um deborah french
01:08:03 yes not not exclusively but yes what else would it have been based on you say not exclusively we did a lot of research in the um early
01:08:14 we did a lot of research in the um early months of the project so
01:08:19 we met with rhinobond but i was very aware of a luca bond yeah and you were aware that that was going to be a cheaper option than the zinc option
01:08:30 zinc option um
01:08:36 i think i think i would have known it would have been cheaper yes yeah
01:08:41 now you say um in your email that you had concerns um that planning were likely to need a sweetener
01:08:49 sweetener to swallow this what did you mean by that
01:08:57 by taking away the the natural finish of a zinc product they may want to have it compensated somehow
01:09:05 somehow in other words that that's
01:09:08 in one way me anticipating a possible conversational dialogue with planning what kind of compensation were you thinking that they might perhaps perhaps some high quality materials at low level i
01:09:20 high quality materials at low level i see yeah
01:09:25 now you you then say in your witness statement that you met with cep to discuss value engineering options on the 4th of march 2013 we can see that if we look at paragraph
01:09:36 we can see that if we look at paragraph 190 of your statement this is sca3014273 at page 85.
01:09:49 this is sca3014273 at page 85. so um you say on the 4th of march 2013 cep came into studio e to discuss the cheaper acm cladding option and various other value engineering options
01:10:00 various other value engineering options do you see that there yeah now
01:10:06 yeah now who first raised the possibility of acm as a subject to to discuss with cep um was it you or or them can you recall
01:10:18 was it you or or them can you recall i'm afraid there's those two lines all i to give it context all i can say is it was march 2013 and we were in a
01:10:26 a hiatus i'm not really working on the project the project had was the negotiations with um ledbetter hadn't really
01:10:39 ledbetter hadn't really come to anything yet
01:10:42 without i can't remember the context okay
01:10:46 okay at that meeting did cep express a preference for acm in terms of final product selection
01:10:54 selection i'm sorry i can't remember you can't remember at this point on just those two lines and i know it's my witness statement i can't recall them no if you can't recall
01:11:05 can't recall them no if you can't recall you can't recall i just wanted to know whether you could recall any anything more about what was discussed at that meeting did you think at this time about getting some um
01:11:16 some um independent advice on whether acm was an appropriate material to use for example from x over
01:11:24 no
01:11:29 did you were you aware that cep might have a preference for a particular product
01:11:35 product and might be keen for you to use those particular products
01:11:45 well they didn't disclose any preference
01:11:49 so you didn't have any concern at the time that by speaking to cep about it you might only be
01:11:56 be being recommended certain products
01:12:04 when we first approached the ep i mean we we looked at some very diverse products
01:12:09 products one of them was a
01:12:13 stone chip product so the fact that they referred us to rhinobond to me wasn't significant i
01:12:24 significant i understood acm was a fairly generic product
01:12:29 okay you then report back to artelia that you're considering a number of options can we just look at that and then and then we can break for lunch um so this is
01:12:41 this is sea407442
01:12:46 so this is an email from you again to mr dawson
01:12:52 and what i want to do is focus on the fourth bullet in the middle of the page
01:12:59 where you say we've had cep come in today to discuss the cheaper acm cladding option and they will be folding samples for possible presentation to planning from our conversation with cep
01:13:12 planning from our conversation with cep we feel there might be scope to switch from zinc but it will require a bit more elaboration than the ledbetters figure allows
01:13:19 allows we note that ledbetter don't appear to have costed the zinc and i put in a budget figure only do you see that there yeah and then in the next bullet you deal
01:13:30 and then in the next bullet you deal with insulated render and you say an insulated render is an option for cladding the tower it's not clear from the schedule whether this is cheaper than acm it is less desirable from a maintenance and lifespan
01:13:40 lifespan point of view do you see that there yes and i think you explained that was that because of the concerns you explained to us earlier yeah and in the next paragraph you also say that you're looking at
01:13:52 say that you're looking at a marley natura as a cladding option as well
01:13:56 well did you see that can you explain what what cladding option that was
01:14:04 marley is a cement board right
01:14:12 mr chairman i think that's a good moment um yes
01:14:16 um yes if we could pause there because then i'm starting us well i'm carrying on but it's a good myth right thank you well we'll have a break now mr sane so everyone can have some lunch
01:14:27 everyone can have some lunch please remember not to talk to anyone at all about your evidence or anything to do with it over the break and we'll resume it to the top please all right thank you give the usher
01:14:49 good two o'clock please thank you
01:15:09 you