Studio E architect Bruce Sounes testifies on design decisions, material specifications including ACM and insulation products, and understanding of fire safety requirements.
00:00:32 good morning everyone welcome to today's hearing
00:00:35 hearing today we're going to continue hearing evidence from mr sands so could you ask mr sims come in please
00:00:55 good morning mr sand good morning are you ready to carry on yes right thank you yes yes good morning um so i just want to start by picking up a few follow-up questions
00:01:06 a few follow-up questions um on some of the topics that we covered yesterday
00:01:09 yesterday um and i want to start by just looking back at the the insulation topic that we discussed
00:01:16 discussed now you suggested yesterday that celetex fr 5000 didn't burn it just charred that was your understanding and you said the whole history of polyurethanes
00:01:27 polyurethanes had been solved and it was safe to use in cavities that was my understanding at the time so that's taken from the transcript yesterday
00:01:36 yesterday and i want to ask you and really the key question is why you didn't include that kind of information in your witness statement because you you mentioned pir at several places in your witness statement for
00:01:48 places in your witness statement for example at 43.9 116.2 and 287 in those paragraphs you don't express a view about the properties of the
00:01:59 view about the properties of the material
00:02:00 material you simply say it been suggested by max fordham
00:02:04 fordham um can i just ask was that in fact this point about the whole history of polyurethanes had been solved by the time and it was safe to use in cavities um is
00:02:17 and it was safe to use in cavities um is that information you've in fact discovered since you gave evidence in march or can you be clear that that was in fact in your mind
00:02:25 your mind when you were looking at the insulation products on the grenfell project it was definitely my knowledge yes prior to
00:02:33 to prior to beginning at studio in 2000. um and and you say that um as we've discussed on the general level
00:02:46 there are very few locations in my witness statement where i have relied on an account that isn't evidenced
00:02:58 an account that isn't evidenced right so wherever possible the statement has been built on the facts yes the documents documents yeah you mean so does that mean that
00:03:09 yeah you mean so does that mean that your statement doesn't deal with things that you can remember about for example verbal conversations that were had
00:03:16 had correct and in particular the the prior knowledge of acm i in retrospect could
00:03:24 could put a lot more in i think the witness statement was an account obviously led by our legal team um
00:03:35 team um telling a story with it with the documents i see okay were you specifically told that you shouldn't include anything about your recollection of state verbal discussions no but that's how it came out
00:03:47 no but that's how it came out in the end how it came out that's
00:03:53 um yes so that's how it came out okay now we see that you've said the whole history of polyurethanes had been solved and it was safe to use in cavities
00:04:04 cavities did that understanding flow from the discussion you said you had with the celetex
00:04:08 celetex representative in 1998-99 about the sun valley fire which you mentioned yesterday
00:04:15 yesterday i i can't obviously recall what fire they were referring to that that's later research on my part but i didn't recall them discussing a
00:04:26 but i didn't recall them discussing a fire where firefighter had been killed okay and i think it's right but can we just clarify that you said you understood that this fire had involved polyurethane
00:04:38 that this fire had involved polyurethane insulation and cavities in the roof which had contributed i believe it might have been that fire i'm not an expert in the subject of of
00:04:49 i'm not an expert in the subject of of the history of fires i believe there were probably more than one fire yes but just to be clear was it your understanding that the fire had involved polyurethane insulation that i can't recall
00:05:02 it was the risk of polyurethane in cavities which had become an issue and which you were aware of
00:05:11 aware of yeah well that's i wasn't aware of it in 1998-99 but were you aware of by the time of the grenfell project
00:05:22 i'm sorry when celetex presented their product to us because at that time before the 2000 it was a relatively novel
00:05:34 2000 it was a relatively novel i don't know novel's the right word but it was it was not as widely used as it is today
00:05:40 is today so so we were given some background to its use and to why it is why it has become acceptable to use it i see but
00:05:52 become acceptable to use it i see but i i'm thinking back to what you said about the sun valley fire and i want to know
00:05:56 know whether you had understood at the time of the grenfell project that that fire had involved polyurethane insulation no were you aware that pir is a type of
00:06:08 were you aware that pir is a type of polyurethane insulation i know it's blown insulation um that's not to say i believe this the substance is the same i'm not sure
00:06:20 the substance is the same i'm not sure yeah i just know it's a blown insulation yes um and is it right that you were aware that both pir and pu are plastic foam insulation you knew that [Music]
00:06:32 [Music] much
00:06:34 much i knew they're not mineral they don't really present you wouldn't use the word plastic to describe them but i knew they weren't mineral
00:06:42 mineral yes okay and um at the time would you have had concerns about
00:06:51 about the use of a polyurethane insulation at the time of the grenfell project would you have had concerns about that we
00:07:00 we wouldn't have looked at it at all because based on prior knowledge because you thought that by this time they were safe to use is that what you're saying
00:07:14 if someone had presented me with a data sheet with polyurethane i would have obviously
00:07:19 obviously challenged it right i didn't go looking for it because yeah i was aware that that was not acceptable or yeah it's not generally used it's fallen out of use i believe i think
00:07:31 it's fallen out of use i believe i think my question is if you would have been concerned about the use of a polyurethane insulation why were you not concerned about the use of a pir insulation given they're both plastic foam insulation products
00:07:46 i'm happy have you not come so full circle i was aware i was of the understanding that the susceptibility of polyurethane to burn
00:07:58 polyurethane to burn so sustained burning had been solved with polyisinary right okay
00:08:06 now just um moving on to what we discussed about the acm material yesterday and and i asked you about the haze galleria meeting that you had do you remember that
00:08:17 that um and i asked you uh whether you i asked you this question did you think about its fire performance and whether it might be sacrificing fire performance in the interest of price
00:08:29 performance in the interest of price and and you said no no i don't and then you carried on and and we just want to be absolutely crystal clear are you talking about insulation all the cladding we're talking about the
00:08:40 cladding we're talking about the cladding now when i asked did you think about its fire performance and whether it might be sacrificing fire performance in the interest of price what i want to be clear on is did you
00:08:51 what i want to be clear on is did you think about that at the time or is your evidence that you just can't recall whether you thought about it
00:09:03 um i do not recall thinking that there was any sacrifice
00:09:11 sacrifice in terms of fire performance yeah um
00:09:17 i did not believe the panels um offered any fire resistance because they're a very lightweight panel okay which which is
00:09:28 panel okay which which is quite a different thing to suggesting that they
00:09:32 that they um offered some kind of hazard okay perfectly different thank you um and then yesterday when we were discussing um why
00:09:43 yesterday when we were discussing um why acm
00:09:44 acm ended up being included in the nbs specification as one of the alternatives you referred to an email from mr madison of the tmo which you said was relevant to this and i want to
00:09:56 to this and i want to see if an email that we found overnight might be the right email so this is
00:10:02 sea408836
00:10:09 and what we see here it's an email from peter madison of the 1st of october 2013 to you copying in david gibson and claire williams at the tmo um and if we just look down
00:10:22 at the tmo um and if we just look down to the email below it's in response to your report back uh of your meeting with harley curtin wall
00:10:30 wall uh friday the 27th of september do you see that there yes i did like check this a big one sorry i did look this up last night and have i if we go back up have i got
00:10:41 and have i if we go back up have i got the right email this is the email that i read great so what we see is peter madison saying hi bruce thanks for this did he give a similar estimate of an aluminium solution
00:10:51 solution peter so he's querying whether there was an estimate for an aluminium solution can you just explain to us with reference to what you said yesterday why this was then relevant to what went
00:11:02 why this was then relevant to what went into the nbs specification
00:11:09 i think it's it's it's the only um there are only a handful of emails from peter that is one that mentions the aluminium and i do know
00:11:20 mentions the aluminium and i do know that this was discussed so this infers an expectation but there were discussions which um guided us to include it as an option i
00:11:31 guided us to include it as an option i see so
00:11:32 see so you're saying that there were discussions in parallel at the same time with these emails on that topic is that correct yes and who did you have those discussions with exactly
00:11:45 i think it would have come up in one of the project meetings
00:11:51 around this time as we were finalizing the tender information we did have project meetings and i i think i can recall it being discussed and what's your recollection as to
00:12:03 and what's your recollection as to what you were being told by the tmo about their position
00:12:08 uh they wanted an option that was that's my understanding sorry i can't i can't recall specific okay but they wanted an option for acm including in the specification and the employers requirements for the project
00:12:20 employers requirements for the project aluminium i wouldn't go so fast to say acm and they were clear that that was to be included in the employer's requirements where they for the project my understanding is it
00:12:31 for the project my understanding is it was included in the ten form of tender so the tendering contractors were given
00:12:41 a box to complete for for that option yeah yeah thank you
00:12:49 okay so um if i can then pick up uh where i got to yesterday on the acm i now want to look at um paragraph 377 of your statement if we can go to sca
00:13:02 of your statement if we can go to sca 3014273 at page 153
00:13:09 and in that paragraph you say that on the 23rd of april 2014 simon lawrence at ryden forwarded me some information received from deborah french of alcoa
00:13:21 french of alcoa and you say you filed the email attachments to a subfolder in studio e's project file and having checked the subfolder appears that the attachments to ryden's email included and then you've set out a
00:13:32 included and then you've set out a number of uh documents there in subparagraphs and if we look at paragraph 377.3 we can see that included within those documents was a british
00:13:43 within those documents was a british board of agreement certificate titled product sheet one rayna bond architecture wall cladding panels dated the 14th of january 2008 referred to as the bba certificate do
00:13:54 referred to as the bba certificate do you see that there yes and then at paragraph three eight one on page one five four you say this you say i would have read the reina bond
00:14:05 say i would have read the reina bond documents between 23rd of april 2014 and 15th may 2014 and then you go on and you say while i do not recall
00:14:16 do not recall specifically what i noted from them at the time i would have been reviewing them from an architectural perspective and would have been particularly interested in the color charts because the focus at the time was getting
00:14:27 the focus at the time was getting planning approval for the materials in an aesthetic sense
00:14:33 do you see that there yeah um now can we take it that you don't actually have a specific recollection of sitting down and reading those bond documents and that you're making an
00:14:45 bond documents and that you're making an assumption that you would have read them in that period thereafter
00:14:52 i think at that point with the exception of the
00:14:57 of the bba certificate we had those in hard copy
00:15:00 copy particularly the color brochures color types of color and and those are the documents which we passed on last year
00:15:15 i think the the bba certificate i i did not
00:15:18 not spend long on it but i think you'll come to a moment where i it's there is evidence i did look at it yeah okay
00:15:26 yeah okay would it have been your normal practice to read a bba certificate for a product that you were intending to use on a project
00:15:36 if you were looking to specify you would yes yeah
00:15:40 yes yeah um it's it's um
00:15:46 it's usually something that is asked for by building control very often yeah very it's something that building control would like to see to to verify that the product is suitable
00:15:59 to verify that the product is suitable for its application so having it in your hand is often only becomes necessary once you make your application for that that item yeah was it your practice to
00:16:13 that item yeah was it your practice to read the whole of a bba certificate for a product
00:16:16 a product you were proposing to use no
00:16:20 what um where we had you know this this was received
00:16:29 received long before we were going to be submitting to to building control okay so what would you approach to that kind of certificate be what would you do with it at that this stage
00:16:40 stage as we have done here we filed it under the relevant section yeah okay now we've seen that you've said there in that paragraph of your statement that you would have reviewed the product from
00:16:52 you would have reviewed the product from an architectural perspective and would have been particularly interested in the color charts because at that point the focus was on planning approval and aesthetic appearance but i think it's right that you also
00:17:04 but i think it's right that you also considered service life and durability of the product at this stage is that right yes now let's look if we go to sca three zeros 109 5 3
00:17:21 this is an email if we can just blow up the top
00:17:25 the top um of the 15th of may 2014 from you to peter blythe of artelia and we can see that in the first sentence you're saying peter rainer
00:17:36 sentence you're saying peter rainer bond's bba certificate includes the following statement regarding service life
00:17:42 life and then you quote the product has an ultimate service life in excess of 30 years can be expected to retain a good appearance for up to 20 years do you see that there yeah so it would
00:17:53 do you see that there yeah so it would appear that you looked carefully at the certificate regarding its surface life and durability is that fair yes now you go on to say in paragraph 381 of
00:18:05 now you go on to say in paragraph 381 of your statement six lines down you say um at this stage neither studio e nor harley we're carrying out detailed design do you see that there
00:18:17 detailed design do you see that there yeah um i just wanted to ask you some questions about that are you suggesting there that the selection of cladding products as opposed to for example how to form
00:18:29 as opposed to for example how to form the joints or the fixings for them was a matter of detailed design
00:18:36 i'm sorry did you repeat that are you suggesting there that the selection of cladding products as opposed to for example how to form the joints or the fixings for those panels was a matter of detailed design
00:18:52 am i saying that the selection of the is a subject of detail design yeah
00:19:00 because you're you're making the point here and i want to ask you what point you're really making you say at this stage neither studio nor harley were carrying out detailed design
00:19:10 design and you say asp can be seen from an email from mark harris to simon lawrence where he says cladding detailing etcetera will have to be dealt with as part of the main scheme design and then you go on about conversations
00:19:22 and then you go on about conversations with daniel anchorator jones but i'm asking a more basic question which is about this just the simple selection of a platt cladding product whether that was part of the detailed design process or
00:19:33 design process or came earlier
00:19:36 okay um
00:19:40 the selection of the products came via ryden
00:19:44 ryden um and i you haven't given the context for this email which i think is quite relevant okay do you want to give me the context for it um we had met with planning
00:19:58 um we had met with planning to present them the alternative clouding products yeah the the aluminium and that had been attended by ryden tmo
00:20:09 ryden tmo and um
00:20:13 and um artelia and artelia had prepared a note for that meeting where they had that note to be circulated i comparing it favorably sorry comparing
00:20:26 comparing it favorably sorry comparing the
00:20:27 the durability of the acm with the zinc has been comparable yes and i didn't believe that was true no yeah so i i was prompted to
00:20:39 no yeah so i i was prompted to dig out the bba and yeah and and make that concept mr mr tunes i i entirely accept your focus at this point was on gaining planning approval um
00:20:50 gaining planning approval um do you agree that before proposing materials to planners you ought to be sure of their suitability in principle for use on the product on the project
00:21:01 product on the project yes did you look at the fire performance of the panels with reference to the bba certificate at this stage i don't recall doing so no and and i i
00:21:14 i don't recall doing so no and and i i think
00:21:15 think at this stage we were not proposing the material
00:21:19 material i think so you're doing a distinction between what ryden were doing and what you were doing i am i think i think that needs to be stated quite clearly at this point the
00:21:30 stated quite clearly at this point the proposal is coming from ryden
00:21:34 you're still retained as architect and lead consultant on the job aren't you at this point
00:21:43 can you explain why you didn't look at the fire performance at this stage
00:21:51 it was not a concern and it
00:21:55 would not be for us to complete the detail design it was not a concern we had seen we've discussed
00:22:03 discussed yesterday that we'd seen many buildings completed in the with the product and again just back to what you mean by detailed design do you mean that questions of fire performance of a product are matters of
00:22:14 performance of a product are matters of detailed design which you would not expect to be involved in
00:22:26 expect to be involved in we very much were involved in matters of detailed design relating to the fire fire issues so i
00:22:37 fire issues so i i'm sorry i'm still struggling to understand the question you seem to be drawing a distinction as to what was occurring at that stage and what you were involved in and he said you weren't completing the detailed design
00:22:49 detailed design which seemed to imply that it wasn't your role to be looking at fire performance and i was just testing that our our position is as outlined in our
00:23:00 our our position is as outlined in our opening statements the detailed design had been
00:23:03 had been taken over by the main contractor and we understood delegated to their specialist subcontractor and this had been our expectation from
00:23:16 and this had been our expectation from the outset so does that mean that you didn't think it was any part of studio e's role from that point forward to look at the fire performance of the panels that were being considered
00:23:32 no i i think it was certainly were we aware of anything we we should have raised it
00:23:43 but as to actually responsibility for the selection and implementation though
00:23:52 what i want to put to you is isn't it illogical to be seeking planning permission for a material that was potentially unsuitable if it didn't have the right fire performance shouldn't that have been something that
00:24:03 shouldn't that have been something that you checked before it's submitted for planning
00:24:18 it's submitted for planning struggling to um to answer your question because
00:24:23 because we we were submitting a product which is a generic composite product and the focus is on
00:24:34 composite product and the focus is on the finish okay obviously since we've learned that it came in different cores but that was not that wouldn't make it had made a
00:24:45 that wouldn't make it had made a difference to the conversation about the appearance at this stage okay can we now look at the bba certificate itself this is a sea 50516
00:24:59 and um if we can zoom in to in the bottom half of that um we see under key factors assessed um that
00:25:11 factors assessed um that it has a section behavior in relation to fire do you see that there for they're heading down and it says their behavior in relation to fire in relation to the building
00:25:22 to fire in relation to the building regulations for reaction to fire the panels may be regarded as having a class naught surface in england and wales and a low-risk material in scotland see section six do you see that there
00:25:33 see section six do you see that there yes do you have any recollection of reading that at the time no
00:25:39 no or at any time on the grenfell project no my my my involvements
00:25:47 reduced after after around this point yeah
00:25:50 yeah so it follows therefore does it that you didn't ever look at section six of the certificate
00:25:57 if we go to the top of page two
00:26:03 um it states um right at the top in the opinion of the bba rainer bond architectural wall clouding panels if used in accordance with the provisions of this certificate will meet or contribute to meeting the relevant
00:26:14 or contribute to meeting the relevant requirements of the following building regulations do you see that there and then in the detail information we get
00:26:22 get two kind of main sections down it says the panels are judged to meet the class naught requirements do you see that there
00:26:27 there yeah um did you have an awareness aside from
00:26:31 from this certificate which you said you didn't look at that the panels had a class naught uh rating under the relevant
00:26:43 england and wales requirements i can't recall
00:26:50 um i mean i would have assumed that they had on the basis of being aluminium but i don't recall okay if we go on to page three of this certificate under the heading
00:27:01 certificate under the heading general uh at the top in the third paragraph
00:27:06 paragraph there's a a paragraph that says it is important for designers planners contractors and or installers to ensure that the installation of the cladding is in accordance with the certificate holder's instructions
00:27:17 certificate holder's instructions and the information giving given in this certificate do you see that yes and again were you aware that it would be important for a designer um to ensure that the installation of
00:27:29 um to ensure that the installation of the the carrying were you aware in general terms in in terms of looking at bba certificates that it was important for designers to ensure that the installation was in accordance with the certificate holders instructions and
00:27:41 the certificate holders instructions and the information given i didn't understand that as being the purpose of this bba certificate no okay i i our practice typically would be
00:27:53 okay i i our practice typically would be to approach a supplier in this instance and discuss with them
00:27:59 with them the requirements of the project and understand how their system could be used for the specific application
00:28:10 application i didn't i didn't see it as
00:28:15 the purpose of the bba to to tell you that
00:28:20 that okay um i think it's right at this time you did understand that there was a difference between a riveted system and a cassette system is that correct yes um at page four
00:28:33 yes um at page four if we can look at paragraph 3.6
00:28:37 it says there
00:28:41 3.6 at the very last part of that general section all design aspects of the installation should be checked by a suitably qualified chartered engineer or other appropriately qualified person
00:28:54 other appropriately qualified person for advice on specific construction details flu penetrations etc the certificate holder should be consulted so just taking that first sentence were you aware that all design aspects of the installation
00:29:06 all design aspects of the installation should be checked by a suitably qualified chartered engineer was that something that had been you've been made aware of by looking at for example other bba certificates for other products
00:29:18 again the the relevance of a bba certificate i i don't think there is relevance for bba certificates yeah where you have a specialist cladding package whether it be a roof or elevation
00:29:29 elevation would involve some engineering yeah to verify it would it be fair to say that you principally saw the purpose of the bba certificate to be something that you could provide to building
00:29:41 that you could provide to building control
00:29:42 control when the time came to satisfy building control
00:29:45 control that the relevant requirements were met is that really how you viewed that bba certificate i don't recall looking at it in those terms for this product
00:29:57 terms for this product but for other products that i've um used on other projects yes it has
00:30:05 it's often something we've had to chase to get our hands on okay let's look then at page five under section
00:30:14 section six
00:30:18 if we could zoom in on that whole section yeah so we have a detailed section here behavior in relation to fire and i so i think you've said you didn't read this at the time of the grenfell project is that right
00:30:29 is that right at any time no
00:30:34 and it's referring um in 6.1 to a standard sample of the product with a gray green duragloss coating being tested and achieving european class
00:30:44 class b now you've already told us that at the time
00:30:48 time you weren't aware of the european classification and testing system um so is it right that you wouldn't have understood what a class b meant even if you'd read it no
00:31:03 when you say no do you mean yes i wouldn't have understood it yeah um but but did you understand i want to ask you about the use of the phrase standard sample there because um what we see in the next sub-paragraph
00:31:16 um what we see in the next sub-paragraph 6.2 is it's drawing a distinction between a standard sample of the product and then a far retardant sample of the product
00:31:24 product were you ever aware that there was this distinction in terms of these rayna bond panels between a standard and a fire retardant sample
00:31:34 i do not record being aware of so that's not something you ever told by orconic or cep
00:31:40 or cep or harley my recollection is the core was never
00:31:45 was never discussed
00:31:49 and then um in 6.4 there's a a warning it says there these performances may not be achieved by other colors of the product
00:32:00 other colors of the product and the designations of a particular color should be confirmed by and then it says in england and wales test or assessment in accordance with approved document b do you see that there
00:32:09 there yes so again i just want to ask you in general where you were aware that there might be um different performances achieved by other colors and that that's something that needed to be confirmed on a specific
00:32:22 needed to be confirmed on a specific product
00:32:26 project
00:32:30 um i wasn't aware of it at the time i i would have thought it a very strange thing to say at the time yeah i would have thought the color would
00:32:42 i would have thought the color would have made negligible difference okay so you weren't aware in general that if you were choosing a different color or finish that that might affect the fire performance and therefore ought to be something
00:32:53 something that you checked as i say the finish is so thin i would have thought there would have
00:33:04 i would have thought there would have been negligible difference in fact why would it be worth even mentioning i couldn't underst i wouldn't have understood that at the time yeah and then at the end of this section
00:33:17 yeah and then at the end of this section behavior in relation to fire at 6.6 it says cavity barriers should be incorporated behind the cladding as required by the national building regulations but should not block essential
00:33:28 but should not block essential ventilation pathways and then we see this sentence particular attention should be paid to preventing the spread of fire from within a building breaching the cladding system through
00:33:39 breaching the cladding system through window and door openings do you see that there
00:33:42 there yes now i appreciate you didn't read this at the time but i want to know whether you were aware of that need for particular attention with these kind of panels
00:33:54 kind of panels for preventing the spread of fire through
00:33:57 through window and door openings well i didn't read this section had i read it i wouldn't have understood that that paragraph you wouldn't have understood it
00:34:08 understood it so you wouldn't have understood that it might be linking back to the provisions in approved document b about cavity barriers around openings no to me this suggests you can't have windows
00:34:21 windows it's my reading of it
00:34:24 isn't it saying just that it's something that needs particular attention to preventing the spread of fire breaching the cladding system through window and door openings that it's something that has to be a particular focus not saying
00:34:35 focus not saying you can't use these where you've got windows but saying you've got to have a tight focus on that topic that's not what it says it says preventing the spread of fire from a
00:34:46 preventing the spread of fire from a building breach in the clouding system through a window so no windows sorry i find it absurd i wouldn't have understood that okay if you hadn't understood it would you have
00:34:57 you hadn't understood it would you have clarified it with you know if you read a bba certificate and you don't understand something
00:35:02 something would you would you routinely had a relationship with the um the suppliers yes i possibly would have but this is all hypothetical because i
00:35:14 didn't um
00:35:21 in in paragraph 386 of your statement you say that you've since the pro since the fire you've
00:35:28 you've now read the bba certificate and you say now with the benefit of hindsight there was nothing on the face of it that alarmed
00:35:35 alarmed warned or concerned you about ryden's proposal to use the acm is it right that even now you wouldn't have thought that the caveat in 6.4 about different colors
00:35:47 about different colors would have been something that would be important to follow up
00:35:55 if i was reviewing this with the supplier
00:36:00 supplier i might ask because it seems a curious point to make that one color could make any difference at all
00:36:10 so your question was do i think now that it would have been important to you yeah you've said in your statement you said i've read it and then even now there'd be nothing that alarmed warned or concerned me about ryden's proposal to
00:36:21 concerned me about ryden's proposal to use acm and what i'm asking is when you read that paragraph 6.4 these performances may not be achieved by other colors did that not strike you as something that you would
00:36:33 strike you as something that you would have been concerned about and would have wanted reassurance on
00:36:39 i might have done how do i reading it yes i might have done but i i repeat that does seem a strange point to make
00:36:47 make okay now
00:36:50 okay now i showed you the email that you sent of the 15th of may 2014 where you forwarded the bba certificate onto peter blythe of artelia and there you refer to the statement on
00:37:01 and there you refer to the statement on the panel's service life and appearance and to establish that you would have had to have gone to section nine of this certificate on the top of page six so that's one page on
00:37:12 page six so that's one page on from the fire section
00:37:17 can we just look at that so page six of this
00:37:23 this yes so there under 9.1 do you see that um that's where it's talking about expected to have ultimate service life in excess of 30
00:37:34 ultimate service life in excess of 30 years do you see that and that was the information you were then relaying on to artelia and you've explained to us hopefully what the context to that was um but
00:37:46 um but it remains your evidence does it that despite looking at that specific section you wouldn't have looked at the fire performance section on the way through reading the certificate
00:37:58 i can't recall but i could well have used the search function is it is it right that you did not ever seek any specific guidance on the
00:38:09 seek any specific guidance on the meaning and effect of the bba certificate from x over no
00:38:15 x over no i didn't and you didn't ever ask for um any discussions about the bba certificate with ryden or harley no
00:38:28 or harley no and you didn't contact the manufacturer
00:38:33 and ask for any further information
00:38:43 [Music] um
00:38:46 um and i think it's right but can you confirm that you never yourself saw any further advice from x over on the fire performance of the cladding panels after this point i didn't
00:39:00 after this point i didn't know studio e didn't do you know whether anyone else at studio he did um i
00:39:09 obviously there's all of neil's evidence and his witness statement yeah which i was aware of at the time but i i that's all i can
00:39:20 that's all i can are you saying you were aware at the time that neil crawford specifically asked xover and mr ashton about the far performance of the acm panels is that your clear recollection
00:39:31 panels is that your clear recollection at the time no no i don't have a recollection of that
00:39:37 now just a few brief questions about the planning process in acm because we know we're kind of within the planning process
00:39:44 process and what we've been looking at some of this morning you've set out your evidence of the planning process in your witness statement i'm not going to go through that in detail but i think there are some matters that
00:39:56 but i think there are some matters that we can agree on and i just want to check that is it right that the planning permission that was granted including a condition that materials to be used on the external faces of the building were to be subject to separate
00:40:08 building were to be subject to separate approval by rbkc is that correct yes and so in effect the planning permission itself did not give approval to any particular kind of planet cladding panel is that right yes
00:40:21 is it correct that the rbkc planning department was generally wary of the change from zinc to acm
00:40:33 um
00:40:36 i think you're asking me to summarize their response which is actually best for them to give but they they it's not an unfair portrayal that they not wary but they
00:40:49 portrayal that they not wary but they had concerns about the overall appearance which is documented yeah that's my next question is it fair to say that the planning office's primary concern was the color and appearance of the panels
00:41:00 and appearance of the panels [Applause] yes yes it was and there was also an issue wasn't there over whether a face fixed or a cassette panel would be more acceptable to the planners
00:41:13 yes and is it right that ultimately the decision to go for cassette fix over face fix was driven by the planning offices
00:41:26 um
00:41:31 driven the planners i think are on record saying they didn't like the visible fixings yeah the visible fixings in the faced fix
00:41:43 fixings in the faced fix yes whether that's fair to say they drove it
00:41:48 drove it yeah not sure just let's look at an email on that this is at um sea 3011373 this is an email of the 28th of july
00:41:59 this is an email of the 28th of july from the planners to david gibson of the tmo
00:42:03 tmo so this is um mark watterson he's in the rbkc planning department isn't he mark no he's he's the planning consultant sorry he's the planning consultant i did sit in the
00:42:15 consultant i did sit in the rbkc planning he commuted from manchester i think yeah thank you um so he's emailing david gibson
00:42:23 gibson and copying in you grenfell feedback um and then you see in the second paragraph i think what you were just describing the email exchange is set up below but in particular
00:42:34 below but in particular the lpa what does lpa stand for local planning authority yeah object to the idea of any exposed fixings on the building
00:42:43 building i pushed them on having exposed fixings higher up the building but their concern which has also been borne out of other site visits is that the rivets will become rust attractors and then stain the cladding they're
00:42:54 and then stain the cladding they're aware of the cost savings but on this occasion they do not outweigh their concerns over quality appearance and longer
00:43:00 longer longevity i advise claire that i do not i do agree with this position and i do not feel it's worth pushing any further however please let you know let me know if you feel any differently
00:43:11 let me know if you feel any differently and then he says we're still looking at the color options so is that a good example of the the mood music you were getting back from the
00:43:19 the planners about their reluctance to use the face
00:43:22 the face fixed and their preference for the cassettes
00:43:26 cassettes yeah i think there are more there's an email from sarah scannell i think yeah after following her site visit which yeah directly communicates their views yeah
00:43:38 directly communicates their views yeah and we can see that this was notwithstanding the awareness and we see that from this email that the cassette fix was more expensive than the face fix
00:43:50 i'm sorry the so they're clearly aware it said in the third line of that paragraph they are aware of the cost savings
00:43:59 savings so they're aware that the face fixed was a lot cheaper than the cassettes wasn't it i i don't know how much they knew okay well
00:44:10 don't know how much they knew okay well they're clearly aware of that in principle from based on this email
00:44:16 um and can i just ask you one final question on the planning did you ever discuss
00:44:20 discuss fire safety of the cladding system with rbkc's planning department no i don't recall and would that be because that was a matter that was actually for rbkc building control
00:44:32 actually for rbkc building control rather than for their planners yes now at this point i want to ask you some questions about resident consultation
00:44:44 questions about resident consultation and i'm doing this now because um what i'm going to be asking you is if you can help us a little bit more about what information was provided to the residents about the cladding panels
00:44:57 the residents about the cladding panels during that consultation process and what i want to look at is something called the grenfell tower regeneration project
00:45:04 project engagement statement if we can bring this up this is at
00:45:16 rbk50236 and so we can see that it's got your label on the top left studio e
00:45:28 studio e um but then other logos around the bottom and it's grenfell tower regeneration project engagement statement planning application october 2012.
00:45:40 application october 2012. um and is it right that this was submitted as part of the planning application yes at that point um who actually put this document together do you know
00:45:52 do you know is it a document you're familiar with i haven't looked at it recently but but was it
00:45:59 was it something studio e put together or was it put together by another party it's very unlikely we put it together okay i think it would have been between um
00:46:10 i think it would have been between um taylor young and rbkc yeah we'll see what it does is it sets out in the introduction what the purpose was
00:46:18 was of the consultation that what the strategy was for consultation and then as we go through it it um contains within it a number of pieces of information for example responses to
00:46:30 information for example responses to questionnaires or newsletters that were sent to residents and feedback through it about what was being said by the community in response to the proposals
00:46:44 now if we can turn to section one the introduction on page three
00:46:56 introduction on page three we can see
00:47:00 picking it up on the in the second sentence of that first paragraph it says the consultation strategy agreed by royal borough of kensington and chelsea in partnership with kensington and chelsea tmo was based on building positive
00:47:12 was based on building positive engagement with local communities and stakeholders through consultation prior to planning submission do you see that there yes and was that your understanding of of
00:47:22 of in very general terms what the consultation strategy was that had been agreed
00:47:29 i wasn't aware that they were following any guidance they were i was aware there was a consultation strategy in place and we participated in it yes yeah
00:47:40 it yes yeah and then paragraph two it says the focus was to continue to provide opportunities for local residents to understand and influence the development development of the design proposals for the grenfell tower regeneration project
00:47:51 the grenfell tower regeneration project before the application was submitted do you see that there yes and again was that your understanding that it was to provide opportunities for residents to influence the development of the design proposals
00:48:04 yes um and then at paragraph three it says in analyzing the responses there is clear evidence of support for the project
00:48:13 project however during the early stages of the consultation there were some concerns over elements of designs whilst we recognize that not everyone will support the proposals many of these concerns have now been addressed
00:48:24 concerns have now been addressed and are reflected in the proposed development do you see that there yes now can you recall um did any of the concerns relate to the external wall and the design
00:48:36 the external wall and the design proposals for that
00:48:39 no it was something that was consulted on but i don't recall any specific concerns
00:48:44 concerns okay can you recall in general what what the types of concerns were i mean we don't need to go into it in detail but can you recall the kind of broad topics that were raised
00:48:55 broad topics that were raised um i
00:48:58 um i before coming i i looked at the which i think you will have the feedback summary yeah the um sort of formal consultation that was
00:49:10 um sort of formal consultation that was done i think in in may 2012 yes and the initial concerns were around security yeah i do remember that
00:49:21 that yeah um raised and the request for cameras
00:49:25 cameras yeah obviously not directly um related to the proposed works okay but i do remember that yeah and then finally we can see it says
00:49:36 yeah and then finally we can see it says there
00:49:37 there in the last paragraph it also meets the guidance set out in the localism act 2011 which sets out a requirement for community engagement in advance of the submission of major planning applications do you see that there
00:49:47 there yes and then if we can go to page four this is the consultation strategy
00:49:55 and what this does is set out the approach to facilitating that's detailed below and we see that in a number of subparagraphs you can see the types of strategies and
00:50:06 you can see the types of strategies and measures
00:50:07 measures that were being said to have been um deployed in order to get the feedback so we've got community briefing session in february 2012 then questionnaires with feedback
00:50:18 then questionnaires with feedback questions
00:50:20 questions as from may weekly evening consultation meetings
00:50:23 meetings or weekly drop-in sessions we don't need to go through them all do you see that so they're set out there
00:50:31 and is it right that you were involved in some of those specific sessions in which feedback was given by residents the the questionnaire i can remember one questionnaire session
00:50:43 i can remember one questionnaire session which
00:50:43 which is i think was the may one um the the evening consultation events myself and possibly one or more from
00:50:54 myself and possibly one or more from studio we attended um i know that the kctimo
00:51:01 were on site often during the day as well right i think yeah in the in the base of the tower in office with drawings on the wall
00:51:08 wall okay yeah and that went on through the summer
00:51:12 summer a number of them
00:51:15 just in general had you had an experience of dealing with issues arising from consultation with residents in a social housing context before doing a building project was that something you had experience of
00:51:26 something you had experience of no when he when you embarked on this process
00:51:31 process and in terms of your involvement what did you
00:51:34 did you think the consultation would involve were you aware that it would involve these kind of measures
00:51:42 we were led by our bkc as to what we were going to do but i understood it would be um a mixture of presentations to to a group
00:51:54 a mixture of presentations to to a group and it's information even and
00:51:58 questionnaires and discussions one-to-one with people in a room
00:52:05 room yeah and who did you discuss the need for consultation with rbkc um
00:52:12 rbkc um [Music]
00:52:16 as i recall it it was mark anderson who who led on that and i say lead i believe he was
00:52:24 quite focused on it yeah but he delegated
00:52:27 delegated that to us some others and he attended them
00:52:31 them as well yep now if we can go to section three of this document on page five
00:52:41 um this talks about the planning brief consultation and i just want to quickly look at the fourth paragraph it says their resident consultation meetings gave assistance to studio e
00:52:52 meetings gave assistance to studio e when developing designs which meet the needs of tma requirements and to residents expectations do you see that there yes and would you agree with that statement that the resident consultation
00:53:03 statement that the resident consultation meetings did give assistance to studio e when developing designs
00:53:12 i would agree to that um
00:53:18 you're going to ask me how i think but yes i would agree to that it was it was a two-way process but it it was also explaining the
00:53:29 but it it was also explaining the proposals
00:53:31 proposals to the residents yeah so they can be asked questions and understand the proposals yeah now at the bottom of that um page under
00:53:42 now at the bottom of that um page under a heading section four newsletters we can see it says and go right to the bottom of that page
00:54:02 um sorry actually it's the first paragraph under newsletters i apologize um it says they're the main purpose of the project newsletters was to provide key information of the project and feedback from residents following
00:54:13 feedback from residents following consultation meetings do you see that yes and then i'm going to show you some examples in a moment where we see the newsletters actually setting out information about some of the cladding proposals
00:54:24 proposals i just want to ask you some questions about that um
00:54:32 did you actually play a part yourself in devising and formulating the questionnaires that contain feedback questions for residents was that a process you were involved
00:54:43 was that a process you were involved with i don't recall doing that no no who do you think devised those questionnaires do you know um again between casey tiemo and taylor young yeah
00:54:55 casey tiemo and taylor young yeah okay now if we go to section six of this engagement statement on page seven this sets out the results of a questionnaire sent to residents in
00:55:06 questionnaire sent to residents in march 2012. so you can see at the top there it says residence views feedback was sought by a kctma roadshow and the issue of a questionnaire to grenfell tower
00:55:17 questionnaire to grenfell tower residents with a deadline return date of the 9th of march 2012 and then it tells us as at the 22nd of march 2012
00:55:25 2012 um how many have been completed and then it actually sets out the results below do you see that and question two is as follows it says do you think
00:55:37 is as follows it says do you think grenfell tower would benefit from thermal insulation cladding this would have the effect of making the building warmer in winter and cooler in summer and would mean homes require less heating it would also improve the external appearance of the
00:55:49 improve the external appearance of the building
00:55:49 building do you see that there yes
00:55:54 were you aware that that question was part of that march 2012 questionnaire i i wasn't no okay can you help us as to whether any information had been given to
00:56:05 any information had been given to residents prior to answering that question
00:56:08 question about the thermal insulation cladding that might be being proposed no i think this is some question it predated our involvement yeah so it
00:56:20 predated our involvement yeah so it wouldn't have been possible to give any details
00:56:22 details at that point of the specific insulation that was being proposed by studio e no no do you recall any discussions with
00:56:33 do you recall any discussions with residents
00:56:34 residents at any later stage about the specific type of insulation to be used in the external wall
00:56:43 i can't recall doing discussing it no no okay um
00:56:51 do you have any recollection of any discussions at any time about fire safety more generally of the materials to be used in the external over cladding
00:57:03 over cladding no no then if we can go on to page 14 this is a table setting out consultation summary you can see the heading section
00:57:15 summary you can see the heading section 7 consultation summary above and it's outlining a number of initiatives that have occurred and what the feedback's been and if we can go on to page 15
00:57:26 can go on to page 15 we can see a line for the 26th of july 2012. do you see it says there evening consultation meeting daytime drop-in sessions and newsletter
00:57:38 drop-in sessions and newsletter and then the topic was um discussion with design proposals and the feedback says this external canopy
00:57:45 canopy residents would like to see a new canopy which offers protection and shelter around the block and then it says external cladding proposal favorable to residents seems to be for profile zinc although we
00:57:58 seems to be for profile zinc although we seem to have some feedback on type of clouding it is still undecided on their preferred color for the cladding do you see that there yes can you help us
00:58:06 us by this stage as to what information about the
00:58:10 about the uh zinc external cladding had been provided to residents in the context of these discussions of hand i can't i can't i
00:58:23 of hand i can't i can't i you have to go back on i'd have to go back on
00:58:27 back on based on the data as to what the board was that we presented that evening yeah so so just to be clear it talks about an evening consultation meeting were you present there
00:58:38 meeting were you present there at that evening consultation meeting i need to check but i probably was yeah and you talked about you just said what board we were presenting can you just
00:58:48 just explain to us what you would do at that evening meeting what you recall doing well there were a number of these meetings
00:58:57 meetings which had slightly different um formats so often there was an address from from mark to an audience of residence and that would
00:59:08 an audience of residence and that would have been followed by a walk around so it was a kind of exhibition we we had our a1 boards on easels so we could stand and talk
00:59:18 and talk people yeah both tmo and studio e staff were present and could talk people
00:59:29 staff were present and could talk people through
00:59:30 through what was presented yeah on the boards yeah
00:59:34 yeah can you recall whether the residents were ever given any information about the nature and composition of the zinc external cladding
00:59:44 as i say i would have to check what was shown on that board but you did pick up a um newsletter yesterday's session yes i'm going to come to that in a moment we'll look at that
00:59:55 a moment we'll look at that where we see some details of the vm zinc i think being provided yes yeah um in your mind what was the purpose of discussing for example the zinc
01:00:06 for example the zinc cladding proposals at that kind of resident meeting what were you seeking to get from it in terms of the design process
01:00:15 the subject of color and appearance in general
01:00:20 general was always
01:00:25 a sensitive one
01:00:29 and we were seeking to to get people on board with what we well we're trying to get a consensus certainly with the residents but also within ourselves as to what we were
01:00:41 within ourselves as to what we were going to present so we were putting proposals forward and seeing what came back
01:00:49 back as to whether there was any strong push one way or the other yeah so i think to summarize is are you saying that what you were seeking to get out of it was primarily about the color and the appearance of
01:01:01 about the color and the appearance of the cladding to help you with your design in that aspect well it was the whole thing we presented three-dimensional views of the building but but obviously the clouding was a key
01:01:12 but but obviously the clouding was a key part of it but so were the windows
01:01:18 now after this what the document we're looking at this engagement statement has a number of appendices which contain relevant information about this engagement that's summarized earlier in the document
01:01:29 the document can we just look at appendix c on page 23
01:01:33 23 these are minutes and notes from the plea pre-planning meeting of the 19th of july and if we go to page 24 which is page one of the minutes
01:01:45 which is page one of the minutes if we can just expand the bottom of that page so this is sorry maybe we should look at the top first just to clarify what this is so it's minutes of a meeting grenfell tower regeneration project it's at the rbkc
01:01:57 regeneration project it's at the rbkc town hall on the 19th of july 2012 and it's lpa pre-application meeting do you see that there yes and you're present we can see that from the list
01:02:08 from the list yes and then if we can go down there's a heading canopy and over cladding that i just want to look at so we can see in the middle of that page it says bs so that must be you bruce soon
01:02:18 soon is that correct explain that an overcloud and rain screen system is being proposed zinc or eternic particle board are being investigated and that says okay with eg but suggested
01:02:31 and that says okay with eg but suggested that color choice should avoid gray can you help us as to what that means okay with eg edward george edward george the planner i think he was the principal planner we
01:02:42 i think he was the principal planner we engaged with throughout and then it says this in the next paragraph considering aluminium windows but still talking to residents about design considering safety etc etc considering ribbon approach to
01:02:53 etc considering ribbon approach to window design but depends on infill panels do you see that there yes do you know whether any details of the window infill panels were ever provided to the residents
01:03:04 to the residents as part of this process
01:03:08 no this was long before we were stay g this was a stage c consultation so we wouldn't have put technical detail forward anyway
01:03:21 have put technical detail forward anyway and just to be clear i think it does follow from your answers earlier but i want you to clarify did any discussions occur about fire safety or fire performance of the external war materials at this meeting
01:03:33 meeting i do not recall being discussed now then if we can go on to page 33 at appendix g and this is newsletters
01:03:45 and this is newsletters so this is the appendix with the newsletters and if we look at page 34 we see the newsletter of the 15th of july 2012. and in in the main part of that page we
01:03:57 and in in the main part of that page we can see a heading feedback from residents do you see that there yes and um just looking for a moment at the the strip on the black strip on the
01:04:09 strip on the black strip on the on the left two paragraphs up from the bottom it says this kctmo is seeking to work with residents and the community to develop the proposals for grenfell tower and has appointed studio e design team and contractor
01:04:22 studio e design team and contractor ledbetter
01:04:23 ledbetter to deliver this project and then it says uh kctmo and rbkc wish to ensure that the regeneration of the tower delivers maximum benefit to the residents and community do you see that
01:04:34 residents and community do you see that there
01:04:34 there yes and then in the middle column at the bottom under the heading what you have said you can see a heading that says you wish
01:04:45 you can see a heading that says you wish to be involved in the development of the proposals for grenfell tower do you see that there yes and was that something you were very aware of at the time of this engagement that the community
01:04:56 of this engagement that the community did want to be involved in the development of the proposals
01:05:03 i have looked at those results of the um may
01:05:09 may questionnaire and i think that was one of the questions yeah supported that yes and then on the right
01:05:17 right um we can see um
01:05:21 four paragraphs down from the top there's uh a sentence that said there is no clear opinion about the color or type of external cladding do you see that there yes
01:05:32 that there yes um and what did you understand type to me
01:05:36 me we've discussed color already and that you were looking for feedback on that uh what would you understand type to be meaning there alternative material yeah
01:05:48 alternative material yeah i think that there was no they weren't giving a preference to any particular type of clouding right and you'd given different options had
01:06:00 and you'd given different options had you as part of your presentations you'd looked at different options i would refer have to refer back to the boards but i think we did okay then look at page 36 this is a
01:06:12 okay then look at page 36 this is a newsletter of the 22nd of july 2012. under feedback from residents on the right-hand side there's a heading external cladding and it says there um but so by this time
01:06:25 and it says there um but so by this time it looks like it says a wide variety of options have been presented and there is a strong preference for metal cladding and it says aluminium one aluminium sheet
01:06:34 sheet two composite metal sheet three profile zinc sheet further work is to be done on this and in particular possible colors do you see that there yeah and then over onto page 37 of this
01:06:45 yeah and then over onto page 37 of this same
01:06:45 same newsletter
01:06:51 right at the bottom of that page it says we look forward to your feedback on and then it's got external cladding as the second bullet do you see that there yes so clearly it would appear that the
01:07:03 yes so clearly it would appear that the consultation's carrying on and a variety of options have been presented and that there's a strong preference emerging for metal cladding was that your understanding
01:07:15 cladding was that your understanding i think i think the the boards were the primary form of presentation i i may have taken samples to these events i can't recall and i
01:07:29 to these events i can't recall and i believe that people would be pointing at images of buildings with clouding on it indicating a preference
01:07:38 so i i'm not sure you would draw draw conclusion that was a strong preference okay
01:07:44 okay one way or the other right can you remember you may not but can you remember when the idea of aluminium sheet was first introduced in the context of those discussions
01:07:57 context of those discussions no as i say i i suspect it relates to an image
01:08:01 image with a caption right saying aluminium sheet but i would i would want to check yeah then if we can go on to page 38 and
01:08:13 yeah then if we can go on to page 38 and look at the newsletter of the 1st of august
01:08:18 in the right hand column 6 paragraphs down
01:08:24 down there's a question where it says our leaseholders concerns being taken into consideration and it says we have engaged with a number of leaseholders on an individual basis and we have additionally offered
01:08:35 basis and we have additionally offered to meet with the leaseholders collectively to explain the proposals that have been developed so far
01:08:41 far do you see that yes do you know why it was that some leaseholders were engaged with on an individual basis
01:08:52 individual basis um
01:08:55 well obviously long leaseholders have um
01:09:01 ownership of their flat yeah and they can
01:09:04 can change it as they wish
01:09:08 and they may have had specific concerns that they had to raise directly with the tmo who
01:09:20 directly with the tmo who who are effectively their landlord
01:09:24 but i i don't recall exactly what those issues were from your point of view were you aware that there had been engagement with a wider group including tenants with shared common
01:09:36 including tenants with shared common interests in the building was that had that happened as well
01:09:41 i think the all the residents engagement was
01:09:46 was open it wasn't exclusive or broken down so are you saying anyone could have come along to like the evening meetings or the drop-in sessions
01:09:58 evening meetings or the drop-in sessions yeah and then if we look at page 40 of this document um we can see some information which appears to have been attached to this first of august 2012 newsletter
01:10:09 first of august 2012 newsletter and if we look at the very bot the bottom half of that page we can see that there is a section zinc cladding systems and its advantages do you see that there
01:10:20 do you see that there yes and then we've got some boxes and diagrams on the right some of these are familiar to us because i actually took you to some of this yesterday when we were looking at the vm zinc composite and we see this is the one where it
01:10:33 and we see this is the one where it had a reference to a high high density mineral rich core combining the qualities of zinc etcetera with rigidity and flatness and then in the little diagram on the
01:10:44 and then in the little diagram on the right at point two it's got polyethylene core
01:10:46 core fr fire retardancy do you see that there yes
01:10:51 yes um now um in the light of that and can you recall on what basis this particular product and and this particular detailed
01:11:03 product and and this particular detailed information on that product was being shared with residents i can't remember the exact
01:11:10 the exact circumstances but i think it it's related to the image above which is of a building cloud in the same product
01:11:19 product which we may have used and that's in in the presentation right so you can't help us as to why this particular product was being singled out to be included within this
01:11:30 singled out to be included within this newsletter at this point
01:11:35 i can't remember exactly and can you remember whether it provoked any discussions we see the reference there to polyethylene core fr fire retardancy did that
01:11:46 that information that went out in that newsletter ever provoke any discussions about the fr fire retardancy of the core of the panel no not to my knowledge
01:12:01 and then finally on on this document um before i ask you some follow-up questions which we might do after the break on consultation i just want to finish going through this document if we look at page 42
01:12:14 document if we look at page 42 and this is the newsletter of the 9th of august 2012 and feedback from residents in the right hand column it says um with reference to the 26th
01:12:25 it says um with reference to the 26th of july 2012 um
01:12:31 actually i think we've looked at this before actually external cladding proposed favorable to residents
01:12:39 residents i think we've considered that already because we've looked at it earlier sorry um mr chairman i think that probably would be a good moment for a break i'm going to carry on with the resident consultation theme and just ask
01:12:50 resident consultation theme and just ask mr scenes about some emails after this yeah
01:12:53 yeah well that's a good point from your point of view yeah it is probably essentially stop there mr sons we're going to have a break at this point um i'm going to ask you to go with the usher in just a moment
01:13:04 usher in just a moment and remember please not to talk to anyone about your evidence while you're out of the room all right and we'll come back at course to 12 please okay right thank you very much
01:13:26 thank you
01:30:28 right would you ask mr sands to come
01:30:32 back
01:30:38 and this grange before we continue i understand that a number of people have been suffering problems with the receipt of the live transcript um mine wasn't working but it may be
01:30:50 um mine wasn't working but it may be working now but i understand for some people receiving it elsewhere there have been difficulties i'm sorry about that the technical people are doing their best to resolve
01:31:01 people are doing their best to resolve the problems and i hope that they'll succeed in doing that before very long right are you ready to carry on mr sims yes yes yes thank you yes so continuing with the theme of
01:31:12 yes so continuing with the theme of resident consultation what i now want to do is just take you to a number of emails that are relevant to that topic and ask you some some related questions can you uh can we look at a document rbk50474
01:31:33 so these are minutes of a meeting that you attended at rbkc on the 30th of august 2012 housing digest meeting do you see that
01:31:44 housing digest meeting do you see that there yes
01:31:46 there yes now um can you confirm that at this meeting with councillor coleridge you told him and others that 80
01:31:53 80 of the residents were happy with the proposals
01:31:56 proposals as recorded in the minutes can we just have a look in the minutes this is a question that's come in
01:32:04 come in quite recently so we can just look down to the next page
01:32:14 sorry page three thank you
01:32:21 yes there we go um so under heading five it says bruce of studio e attended and gave a presentation do you see that there yeah and then at the bottom after the
01:32:32 yeah and then at the bottom after the bullets it says 80 of the residents were happy with the proposals do you see that there immediately after the bullet points um so can you confirm first of all that
01:32:45 um so can you confirm first of all that that's what you said at the meeting
01:32:50 i can't recall saying that um i might recall attending the meeting a meeting
01:32:59 i mean this was not a normal meeting for me to attend yeah can you recall the substance of the point can you recall being aware that as far as you were concerned 80 of
01:33:10 that as far as you were concerned 80 of the residents were happy with the proposals
01:33:13 proposals this is quite detailed the discussions about
01:33:18 about the um the proposals i'm struggling to remember that okay so i would also struggle to remember the eighty percent of residence item so
01:33:30 eighty percent of residence item so can can you help us as to where that 80 figure might have come from and how how that was arrived at no no okay um can we now look at an
01:33:41 no no okay um can we now look at an email that we looked at yesterday uh which came up in the chronology of the acm story um this is sca40396
01:33:56 and if we can look at the bottom of page one this was the email that you sent to mr blades
01:34:01 mr blades on tuesday the 10th of april in anticipation of what appeared to be a meeting at site yes and do you remember there's that that sentence sorry that paragraph there about it's important to be discreet while we're
01:34:13 important to be discreet while we're there
01:34:14 there this is at the end of the page as the political context for the development and the development of the adjoining site is very sensitive and then you say this i would refrain from discussing with residents or staff who you might meet
01:34:26 or staff who you might meet or discussing drawings where anyone can see them
01:34:29 see them there is enough misinformation about on the estate and we don't want to add to it unwittingly do you see that there yes now in the light of all the resident engagement work that we've just been discussing and the
01:34:40 the stated intention of that engagement work the question is can you explain here how your comments are compatible with the aim to be having positive engagement with the community and
01:34:51 engagement with the community and stakeholders at this time
01:34:57 i don't see them as incompatible at all we were employed by rbkc to assist in the design of the refurbishment
01:35:08 in the design of the refurbishment and this is i think a week or two into or a month into the project and i have been
01:35:17 been warned of speaking even to tmo staff about the proposals i hope you can pull up mark's email i've
01:35:28 i hope you can pull up mark's email i've got i've got that i can take you to that in a moment which i as far as i recall is the source of my
01:35:37 comments here i see yes you referred to this yesterday and i think we've found it overnight can we go to sca403591
01:35:48 it overnight can we go to sca403591 and if we look at page two at the bottom of the page
01:35:55 this is an email from mark anderson to you a month earlier of the fifth of march 2012 where he says good morning bruce and then um in the second line of the email you are not
01:36:06 you are not under any circumstances to make contact with robert regan or the other estate inspectors requests for information are to be directed to myself copied to alastair and
01:36:16 and siobhan please let me know what floor plans you require is is that the email you were referring to yes and we i think i would have spoken to mark after that correspondence
01:36:27 after that correspondence and and what did you discuss with him after this no i i can't remember what i mean as we would have discussed this item the sensitivity around
01:36:38 around what tmo wanted to be known in other words how they how they went about engaging with the community wasn't something they wanted to leave
01:36:52 something they wanted to leave a chance encounter on site i see and what messages did you get from those discussions what what did you come away thinking in the light of those discussions um
01:37:07 discussions um just to be careful i didn't entirely understand the role of the state inspectors on site i didn't understand the sensitivity they specifically had
01:37:18 specifically had did you ever think to yourself during the project well that that's not very consistent with what i'm also being told about community engagement and engaging with stakeholders
01:37:34 and engaging with stakeholders no i don't i don't think that's fair i think
01:37:39 there was ample opportunity to engage all parties and what i didn't was obviously wary about is somebody who
01:37:50 was obviously wary about is somebody who i didn't know okay you might say something which could be misinterpreted right on site and
01:37:58 and there were a lot of there was a strong possibility he would be noticed on site yeah if we just look at the top of this
01:38:05 of this email string at the top of page one there's another email from mr anderson on the 5th of march 2012 um to you
01:38:15 um to you uh and he he gives a bit more explanation he says robert is a tmo employee and i wish to ensure that we manage the dissemination and sources of information do you see that there and so um did you
01:38:27 do you see that there and so um did you feel at the time that the tmo was taking a close interest in managing the dissemination of information about the project
01:38:38 that's that's certainly reflected in that
01:38:42 that i i wasn't entirely clear of the reasons and did that actually affect you in terms of what studio e were able to do in terms of community engagement did that have a knock-on effect in terms of
01:38:53 that have a knock-on effect in terms of what you were then doing i don't believe it had any impact on our
01:38:58 on our formal or informal engagements no okay can i just look i've just got a number of emails to share can we look at another email this this is forward in time to the 5th of
01:39:09 this is forward in time to the 5th of july 2012. if i can go to ibi 6048
01:39:23 so this is an email from mark watterson the
01:39:27 the planning consultant is that right yes to you
01:39:31 you studio e architects um and he says it's further to your earlier conversation about the progression of the refurbishment and then i want to pick up on
01:39:43 and then i want to pick up on what he says in paragraph two he says i will seek a meeting with the planning officer aiming for thursday 19th july we will have been informed by the first rounds of consultation at this stage so we will have to have
01:39:54 stage so we will have to have so we will have a clear idea of the resident's views i would suggest that a series of these meetings will be needed to agree the design
01:40:03 design prior to the submission of the application and then he says this in paragraph three i would recommend that it would be beneficial investing time now to ensure that residents are on side as much as possible
01:40:14 possible prior to the submission of the application this will help reduce to reduce the risk of judicial review and is of
01:40:21 and is of course best practice i would suggest that at this stage this consideration should be as much of a driver on the application submission program
01:40:30 program as the projected start on site date do you see all of that yes did you understand in that third paragraph what he meant by
01:40:41 paragraph what he meant by um reducing the risk of judicial review did you understand what that meant yes why did you think that or why do you think
01:40:52 think the risk of judicial review was a a factor on this project is that something you thought was a legitimate concern
01:41:01 it's a factor on all projects to be honest that meets any kind of local opposition it is a factor yeah
01:41:12 it is a factor yeah what did you understand him to mean by um
01:41:16 um he talks about it being beneficial in that first line of paragraph three beneficial investing time now to ensure that residents are on side as much as possible what did you understand that onside to mean
01:41:29 um to win support from the residents for the proposals
01:41:36 did you ever feel during the process that the aim of the consultation was merely to
01:41:41 merely to persuade residents round to the tmos ideas
01:41:45 ideas of what it wished to achieve rather than to provide an opportunity to respond genuinely to what the residents wanted did you ever feel that during the process
01:41:57 i think that's putting it a bit simplistically
01:42:01 the focus of the investment was on the infrastructure and the tmo were taking serious taking seriously the the
01:42:13 taking serious taking seriously the the input of their residence that's how i took it there was i felt at the time considerable effort put into
01:42:22 put into to gathering input on various items yeah now um if we can go forward in time again on the 20th of august 2012
01:42:35 again on the 20th of august 2012 if we can look at an email tmo one two zeros three seven five on page two
01:42:50 there's an email at the bottom there from peter martindale can you explain what his role was on the project
01:42:59 it's an email to you
01:43:03 i don't recall his role in fact i knew him as peter martin sorry martindale's unusual to see it like that he was a studio employee yes
01:43:16 he was a studio employee yes i can't remember what his role was
01:43:21 so he was a studio employee that was your recollection no i'm not sure what the um email's been redacted yes let's look over the page
01:43:32 over the page if there's anything at the bottom of the email
01:43:36 no that doesn't help if we look at um i want to look at uh paragraph four sub paragraph four
01:43:50 i'm looking for a paragraph i'm not sure that's the reference um
01:43:57 no i can't see that there we'll come let's come back to this email another time if we need to um can i ask you then finally on this
01:44:08 um can i ask you then finally on this topic
01:44:09 topic um can we look at an email chain
01:44:18 sea406493
01:44:24 this is an email if we zoom in at the top of the page now this is an email from neil crawford to ben rogerson of x over on the 5th of
01:44:35 rogerson of x over on the 5th of november
01:44:35 november 2012. so forward in time again and cc your cc'd into it bruce soon do you see that there yes and this was explored in mr crawford's
01:44:49 and this was explored in mr crawford's evidence but i want to ex just explore it briefly with you since you were copied in he states can you help with the query below from colin charles at ledbetter i understand colin has been challenged
01:45:01 i understand colin has been challenged by one of the residents that the current redesign of the landscape surrounding grenfell tower compromises the fire access to grenfell tower
01:45:09 tower and then it says the individual concerned is a known troublemaker do you see that there yes now did you have any concerns um when you were copied into this email
01:45:20 um when you were copied into this email about the reference there to a known troublemaker did that um come to your attention do you remember noticing that i appreciate i was copied on and it did
01:45:33 i appreciate i was copied on and it did overlap with grenfell
01:45:37 but i don't recall um do you ever remember
01:45:41 remember sorry i don't recall the email at the time okay
01:45:45 time okay do you ever remember discussing this topic
01:45:48 topic with mr crawford the fact that there'd been concerns expressed by one of the residents about the landscape surrounding and the fire access being compromised or the
01:45:59 fire access being compromised or the individual being a known troublemaker do you ever recall any discussions with mr crawford about that
01:46:07 i think i think the issue of the access around the tower came up time and again
01:46:14 that's reflected in correspondence
01:46:19 but i can't recall that in the context of any troublemakers here no
01:46:26 here no right yeah do you agree looking at this email now
01:46:31 email now that the topic that appears to have been raised was a wholly legitimate one to be concerned about given the importance of firefighting access to a building like grenfell tower
01:46:43 i think it was raised from the outset yes i agree and it's a legitimate topic to be concerned about isn't it yes do you think that emailing in these terms and really it's
01:46:55 emailing in these terms and really it's a reference to the individual concerned as a known troublemaker do you think that's compatible with a positive attitude towards resident engagement and consultation
01:47:07 um it's it's copied to consultants um
01:47:15 neil wasn't involved in the consultation i don't think it's relevant well i'm wondering if that's a matter for mr sons anyway and he didn't write this i agree i'm i'm not going to pursue any further thank you
01:47:27 pursue any further thank you so mr sands i now want to turn to the topic of
01:47:31 topic of cavity barriers and ask you some questions about the design of the cavity barriers in the facade now um turning first to the requirement of the building regulations
01:47:44 of the building regulations um were you aware at the time of this project
01:47:48 project of the b34 requirement the building should be designed and constructed so that the unseen spread of fire and smoke within concealed spaces in its structure and fabric is inhibited
01:48:00 fabric is inhibited was that something you were aware of the principle i was aware of yes and can we have a look at section 9 of approved document b so if if we go this is clg 50173
01:48:15 so if if we go this is clg 50173 this is the 2006 edition of adb with 2010 amendments so this is what would have been available in 2012 and i want to look at section 9 on page 82
01:48:30 and 9.1 it states that concealed spaces or cavities in the construction of a building provide a ready route for smoke and flame spread this is particularly so in the case of
01:48:42 this is particularly so in the case of voids in above and below the construction of a building eg walls floors ceilings and roofs as any spread is concealed it presents a greater danger than would be more obvious
01:48:53 danger than would be more obvious weakness in the fabric of the building do you see that there yes were you aware of that guidance in approved document b on concealed spaces and cavities when you
01:49:04 concealed spaces and cavities when you were designing the grenfell project yes i was did you appreciate that the construction of the new facade would create a number of additional
01:49:15 would create a number of additional cavities
01:49:17 cavities yes and did you appreciate that there was a risk of fire spread within those cavities
01:49:22 cavities yes now approved document b also gives some guidance on the location of cavity barriers
01:49:28 barriers if we can look at 9.2 on that same page guidance there is to provide cavity barriers and i'm just paraphrasing here to subdivide the
01:49:39 paraphrasing here to subdivide the cavity
01:49:41 cavity where there would otherwise be a pathway around the fire separating element i.e compartment walls and floors
01:49:51 this is illustrated in in diagram 33. which appears on this page below if we can have that diagram up on the page
01:50:03 [Applause] do you recall ever looking at this diagram
01:50:09 diagram during the time you worked on the grenfell project
01:50:13 i think you asked me on my second day whether i'd read part b in the context of this project and i
01:50:21 and i i said no but i didn't going to explain why
01:50:25 why okay party is guidance yes and an experience i've gained in 20 years i've generally found it very
01:50:36 20 years i've generally found it very difficult
01:50:38 difficult to to form any definitive interpretation from the guidance i think so i may have looked at this during the course of the project but i wouldn't have looked at it as the
01:50:50 wouldn't have looked at it as the as the person considering the design i might have looked at with it with either adrian or thomas as they were reviewing
01:51:01 adrian or thomas as they were reviewing these details i see so even though this was a kind of project you've never done before a high-rise over cladding project it didn't occur to you that it might be a good idea to go back and look at key
01:51:12 a good idea to go back and look at key provisions of adb including this one well i i believe thomas did he if not directly certainly in connection with
01:51:24 directly certainly in connection with his um
01:51:25 his um conversations with suppliers as to whether the products were how they should be used but i'm asking about you yourself personally i wasn't working in that
01:51:39 that way on the project i was sitting down preparing drawings and specifications okay now we can see from um diagram 33 it's in
01:51:50 in little um gray shading with the label at the bottom cavity barrier that it's suggesting cavity barriers at the top of the cavity do you see that they're closed top of cavity yes and it's suggesting them
01:52:03 yes and it's suggesting them within the cavity at compartment floor line do you see that there there's a little gray shading yes and it's also
01:52:11 it's also showing cavity barriers around the windows can you see that yes and it's got a specific diagram closed around openings do you see that there
01:52:19 there yes yes and then it's also got some guidance about fire stopping in the in the green um can we move on to look at the next page of adb at page 83
01:52:31 look at the next page of adb at page 83 at paragraph 9.3 the guidance states that cavity barriers should be provided to close the edges of cavity
01:52:39 cavity cavities including around openings so would you agree with me that this guidance is very clear about the need for cavity barriers around openings
01:52:51 for cavity barriers around openings not in the context of a range screen facade no i wouldn't agree okay what was it about these provisions of adb that we've just looked at that would suggest to you that in a rain
01:53:03 would suggest to you that in a rain screen
01:53:04 screen cladding system you wouldn't have to provide cavity barriers around openings well they proved documents silent on on rain screen it doesn't discuss it
01:53:15 rain screen it doesn't discuss it but i i believe
01:53:19 the the diagram 33 refers to a very conventional form of construction and not a rain screen which is which is
01:53:31 a rain screen which is which is essentially outside the cavity is outside it's vented pressure equalized if you like it's it doesn't offer any resistance to flame from the outside or flames coming around
01:53:42 coming around the window opening i see so i wouldn't have
01:53:46 have i would have read that as unclear okay does that mean that it was your understanding that you thought that you didn't need to provide cavity barriers around openings in this kind of rain screen clouding
01:53:59 in this kind of rain screen clouding system
01:54:00 system i would have done what i believe thomas did and that he would have consulted
01:54:06 consulted who i'm not sure who he consulted but i know that he was speaking both to to exervis siderise and harley
01:54:16 harley i'm obviously not clear on what is who he spoke to and i and maybe we'll not know but i i know he was he did spend time trying to arrive at a solution
01:54:29 trying to arrive at a solution can i just focus on your own knowledge at this my own knowledge was him summarizing it to me no was your understanding your own understanding that you didn't have to
01:54:40 understanding that you didn't have to provide cavity barriers around window openings
01:54:45 i had never seen one around an opening cavity barrier around a rain screen facade no i regarded as regarded it as outside those drawings that we
01:54:57 it as outside those drawings that we forwarded last year included a clutch from
01:55:03 cgl i think ryan zinc and kme and there are no cavity barriers around openings did you ever consult any guidance uh
01:55:14 did you ever consult any guidance uh to inform you about your own knowledge on this topic or ask anybody else any other outside parties about whether thomas was dealing
01:55:25 parties about whether thomas was dealing with it
01:55:25 with it and he consulted so does it amount to this that you basically left it to thomas
01:55:30 thomas to work out what the cavity barrier arrangement was he he came back to me with his conclusion and i agreed it and when he
01:55:42 conclusion and i agreed it and when he came back to you with his conclusion did he say to you i'm only going to put the cavity barriers at compartment floor i'm not going to put them around the windows i think this is acceptable
01:55:53 windows i think this is acceptable because did you have that discussion with him
01:55:56 with him i repeat i haven't seen a cavity on a detail around the window i don't recall it being discussed so i think you just i think you've just
01:56:08 so i think you just i think you've just answered
01:56:08 answered you don't recall that being discussed is that correct correct so when you said thomas came back to me with it and i agreed what did he come back to you about and what did you agree the location of
01:56:19 and what did you agree the location of the cavity berries on the typical day drawing i see so you looked at his drawings on that
01:56:28 that and you didn't have a problem with where he put cavity barriers
01:56:34 i thought they were consistent with the my
01:56:37 my understanding of part b in terms of protecting this concealed spread of fire
01:56:50 mr crawford said in his evidence this was day nine uh page 163 lines four to eight that's just for the transcript um he was asked did mr soon tell you
01:57:01 um he was asked did mr soon tell you that in the cavity barrier scheme there was not to be a cavity around the windows and he said my understanding from the discussion with him was that there wasn't a requirement for a cavity barrier around the windows
01:57:13 the windows do you recall having those discussions with mr crawford
01:57:19 no i don't so you don't recall saying to him
01:57:23 him that there wasn't a requirement for cavity barriers around the windows i don't recall that specific topic no do you recall having any discussions
01:57:34 do you recall having any discussions with mr crawford about the cavity barrier arrangement yes i know that that came up in the conversation the email exchanges with x over
01:57:46 the email exchanges with x over september 14 and march 15. i was aware of them at the time
01:57:54 time but not not they were referring to the cavity barriers at the compartment lines
01:58:03 the stage d report prepared by studio e which is dated august 2013 doesn't address cavity barriers anywhere in it that's right isn't it yes in your experience is it common for
01:58:14 in your experience is it common for details such as cavity barriers to be addressed in the design at a later stage yes that's fair do you remember
01:58:26 yes that's fair do you remember at the stage d stage ever addressing your mind
01:58:29 your mind at the time as to whether or not to carry out some initial design work on cavity barriers
01:58:38 stage d yeah
01:58:43 and had you actually done you or to your awareness anyone else at studio e actually done any initial work on cavity barriers at that stage i believe we had but this is um
01:58:55 i believe we had but this is um based on documents in our in our system your belief at the time was based on on what at the time i wasn't
01:59:06 what at the time i wasn't necessarily aware of it but i believe looking back at the documents on our system that we were looking at the cavity barrier issue
01:59:14 issue and who was doing that that would have been adrian chess but that was not something you were involved in
01:59:22 stage d obviously encompassed a period of of hiatus a stand down from roughly december 12 to i think june
01:59:34 to i think june 13 during which time i believe adrian did do some work on that
01:59:43 okay let's move forward to the tender stage
01:59:47 stage and that the preparation of the tender documentation between august 2013 and january 2014 can we look at what you say in your witness statement about this this is sea three zeroes one four two seven three
02:00:00 three zeroes one four two seven three at page 112.
02:00:05 and this is paragraph um 267 it starts right at the bottom of that page and you say there i have no recollection of how the judgment as to the placement of cavity barriers
02:00:17 as to the placement of cavity barriers on the typical bay drawing was arrived at
02:00:21 at and then you say i note that cavity barriers
02:00:24 barriers are not shown on the typical the draft typical bay drawing date of the 24th of september 2013 which states provision of cavity by
02:00:32 cavity by fire barrier tbc do you see that there yes so
02:00:35 yes so i want to focus on that very first sentence that you say you've got no recollection about how the decision about where to install cavity barriers was arrived at now is it right that at that tender
02:00:47 now is it right that at that tender stage you were still taking the lead on the design within studio e
02:00:53 um i was still leading on the project yes yes does it remain your evidence that you uh are unaware as to how
02:01:04 that you uh are unaware as to how the cavity barrier arrangement was arrived at tender stage
02:01:12 i am unaware i was unaware of the conversations that led to those positions indicated i see can we just look at a drawing this is
02:01:24 sca402499 and we'll need the offline
02:01:34 version
02:01:44 thank you i should clarify i was i cannot recall who was spoke where the discussion came from thomas may have mentioned it but i
02:01:56 thomas may have mentioned it but i cannot recall so you're saying he might have mentioned to you who he had been consulting yes but you can't recall any discussion with him about that specifically who
02:02:07 him about that specifically who he spoke to i cannot recall okay um this drawing uh in the bottom right hand corner it's dated the 24th of september 2013 and it
02:02:19 dated the 24th of september 2013 and it was a drawing that was included as part of the employer's requirements package it's number 127906110 and i want to look at the right-hand
02:02:30 and i want to look at the right-hand side of the drawing right at the top that proposed section typical bay we can zone in on that as much as possible
02:02:40 and at the top of that if we look at the fourth
02:02:43 fourth tag down there's some writing that says ensure horizontal and vertical cavity barriers
02:02:49 barriers meet tightly do you see that there yes and um at the bottom of that one tag up we see also cavity
02:03:01 one tag up we see also cavity fire barrier in line with compartment floor structure do you see that there yeah again under p10 both under p10435 so this is showing an arrangement where
02:03:13 so this is showing an arrangement where we've got cavity barriers along the line of compartment floors is that correct yes and it does not show any cavities around
02:03:22 around the windows does it certainly not at the sill level correct
02:03:34 and did you notice that at the time these drawings were being prepared no and can you help us as to precisely why the arrangement is as it
02:03:46 precisely why the arrangement is as it is on this drawing with nothing at sil level
02:03:53 i repeat i understood the purpose of the cavity prayers was to limit the spread of
02:04:00 fire within the cavity was outside so i i did not think that there was any
02:04:13 i i did not think that there was any any reason to well i know i'm putting words i'm inventing it i do not recall
02:04:21 recall seeing there to be a need for a cavity barrier under the window
02:04:27 at the time do you know if it was intended that that cavity barrier at the compartment floor line at the head of the window should also act as a barrier to inhibit the passage of fire
02:04:38 the passage of fire into the cavity of the external wall in the first place do you know whether that was the intention
02:04:45 my understanding which is reflected on this drawing is that the cavity was outside
02:04:54 outside so the barrier
02:04:58 only happens to offer protection any flame exiting the window would find its way into the cavity so you weren't aware of
02:05:07 aware of of guidance at the time of the importance of preventing the cat the flame from entering the cavity around the sides of the windows getting into that cavity in the first
02:05:18 getting into that cavity in the first place i don't think that's clear in section nine you don't think that's clear in section nine okay no that diagram reflects the conventional cavity construction
02:05:29 conventional cavity construction whether it be timber frame or masonry so where section 9 refers to cavity barriers around openings what wasn't clear about that that cavity
02:05:40 what wasn't clear about that that cavity i interpret as an internal space which therefore
02:05:44 therefore has some degree of protection or concealment of flame whereas you know green screen the facade is external
02:05:57 did you ever check your interpretation of that with x over no not me no
02:06:05 can we go to your statement again at paragraph 267 this is sca 3014273 at page
02:06:14 113.
02:06:20 at the end of that paragraph at the top of the page
02:06:27 and you say this in the final lines you you're talking about um you say given the level of detail on the latter drawing um such as the reference to the 25
02:06:41 um such as the reference to the 25 millimeter gap on the horizontal barrier being consistent with the siderise cavity barriers that i believe were installed
02:06:47 installed i believe that the location of the cavity barriers must have been determined with specialist input
02:06:55 do you see that yes now do you mean that in your
02:06:58 in your your view there's a high level of detail on the drawing
02:07:05 clarity there's there's some clarity on the proposal yes i wouldn't say a high level of detail but there's clarity and when you say there it must have been determined with specialist input do you know who provided that specialist input
02:07:18 provided that specialist input the siderise lamitham i think was the name that we had were specified but is i'm talking about whether they
02:07:29 but is i'm talking about whether they were actually consulted and asked about this
02:07:32 this do you know that cider eyes were consulted
02:07:35 consulted at the tender stage about this arrangement or are you just assuming from the fact that you've specified in the nbs siderise cavity barriers that they were i recall discussing or i was called
02:07:47 i recall discussing or i was called thomas
02:07:49 thomas discussing this with me and have him having consulted others i repeat i couldn't remember exactly whom he had discussed this with or whether more than
02:08:00 discussed this with or whether more than one
02:08:02 one my
02:08:05 understanding now is that he would have consulted with saddaras but that's based on um but it's right isn't it that we haven't found i don't think you found any emails
02:08:17 found i don't think you found any emails or
02:08:17 or written record of such a consultation occurring
02:08:22 occurring no and i can't i can't obviously confirm what thomas did i don't believe i was in the office
02:08:32 i'm going to put it to you that because the guidance in approved document b about providing cavity barriers around openings is clear that specialist input should not really have been necessary at that
02:08:44 really have been necessary at that tender stage it should have been obvious that cavity barriers should be put round the windows
02:08:54 i obviously have given this a lot of thought
02:08:58 thought and i did watch professor luke bisbee's testimony so i i tend to agree to to achieve what the i agree with him
02:09:09 to to achieve what the i agree with him that
02:09:09 that i can't see how you achieve what's required where you have to provide a half hour
02:09:13 half hour in both directions when you're supporting the window with aluminium so i don't think
02:09:23 with hindsight i don't think i agree that it was clear on the rain screen what the intention was in the document okay
02:09:30 okay can we go back to the drawing that we were just looking at sca402499
02:09:38 and i want to look instead at the um the elevation of the facade that we see on the top
02:09:44 the top left now it's right isn't it that that's not marked up to show where cavity berries should be located is it
02:09:53 the elevation yeah no no and i want to show you some drawings in mr hyatt's report on this topic can we go to uh phyr603
02:10:07 on this topic can we go to uh phyr603 at page 44 and look at figure 3.16
02:10:16 and if we can blow that up this is the first in a series of drawings in which he shows elevations of the facade
02:10:25 facade and what the scheme of cavity barriers uh
02:10:29 uh in his view should have been and he's done that for a series of elevations we can see that for example if we go on at page 45 and 46 within this
02:10:40 at page 45 and 46 within this let's look at at different
02:10:44 conditions he calls them conditions different parts of the facade which had different configurations and he's showing
02:10:50 showing in a in an elevation where the cavity barriers should be can you just explain it's a general question why you didn't produce similar drawings at tender stage
02:11:02 drawings at tender stage clearly showing the elevations of the tower and where the cavity barriers were
02:11:08 required we didn't think that would be necessary for the tender do you agree that that would have been a relatively straightforward exercise to do
02:11:22 um
02:11:28 i think it would have stepped into the um
02:11:33 the stage f stage of the reaper plan of work where you are dictating
02:11:44 plan of work where you are dictating what you want the contractor to do in other words you're taking a traditional line on information and design traditional line as in the architect instructs
02:11:56 instructs and the contractor constructs i see and when you're saying f stage you mean
02:12:04 mean f after tender because remember we were looking at a drawing the drawing i showed you was part of the employer's requirements so it would be after the technical design stage stage e
02:12:16 design stage stage e no f is technical design so this level of commitment to a scheme to me would fall more obviously
02:12:27 a scheme to me would fall more obviously into a stage f
02:12:30 i see at the time you were working on the tender or overseeing what was being done on the tender did you personally look at any information on the siderise website
02:12:43 any information on the siderise website about where cavity barriers should be installed in a rain screen cladding system
02:12:48 system no i don't did you know that they have a video available which very clearly shows this
02:12:55 this no do you know if anyone else that studio e consulted the siderise product brochure
02:13:01 brochure to see where they advise cavity barriers should be located we have just the one side rise document on file
02:13:11 on file which is discusses the horizontal and vertical products but not detail on their location though okay now i want to turn to what the mbs
02:13:25 okay now i want to turn to what the mbs specification said about cavity barriers can we go to sea one six
02:13:32 at page 246.
02:13:42 and if we can look at item 435
02:13:49 is that on that page
02:13:56 is that all that's shown on that page
02:14:03 yeah that might be a wrong reference um at item four three five studio e specified lamitham horizon do you want do you want to get that up
02:14:13 that up um i can i'll just get the reference um well otherwise it's a bit hard yeah i understand there it is
02:14:24 yeah i understand there it is thank you 246. yep okay so this is item 435 ventilated cavity barriers and we can see that the product
02:14:36 and we can see that the product reference a few lines down is said to be lambeth horizontal and lamithim
02:14:42 lamithim vertical do you see that there yes
02:14:49 and those were ciderized products is that correct yes this is the data sheet we have on our record which i believe is was saved earlier in the year and that's why i believe
02:15:02 and that's why i believe agent jess may have done some research yeah
02:15:05 yeah and then if you look a few bullets from the bottom it's got a heading fire resistance rating and it says 30 30. do you see that there
02:15:16 30 30. do you see that there now we know the minimum performance standard in approved document b was 30 minutes insulation and 15 minutes integrity
02:15:24 integrity does the 30 30 here refer to insulation and integrity that's that would be my reading yeah so is it right that the cavity barriers
02:15:35 is it right that the cavity barriers actually exceed the minimum performance standard
02:15:39 standard if looking at the guidance in approved document b
02:15:46 um yes were you aware of that at the time no no and the specification also says installation requirements
02:15:59 installation requirements uh two items down from that so just one up from the bottom installation requirements it says continuous with minimum joints do you see that there yes was it meant
02:16:12 do you see that there yes was it meant by that that there should be no breaks in the horizontal cavity barriers yes did you give any consideration at this stage to how cavity barriers would interface with any cladding rails
02:16:24 interface with any cladding rails that were used
02:16:30 at this stage i think we were looking at a
02:16:37 sort of helping hand bracket they called it a t bracket which would not normally conflicts with that they're spaced out so they wouldn't
02:16:49 that they're spaced out so they wouldn't normally conflict with with barriers i see so was it something you were generally aware of that there was a need to make sure that the bracketry for the cladding panels didn't
02:17:01 bracketry for the cladding panels didn't uh interfere with the continuous nature of the cavity barriers you appreciate the design that thomas prepared with the drawing that thomas prepared is not based on a
02:17:13 prepared is not based on a on what was built it's based on a simpler system with with brackets that i believe could have avoided any conflict
02:17:25 believe could have avoided any conflict or clash
02:17:26 or clash with the cavity barriers okay
02:17:31 do you know whether um any research was done at this stage about any test certification that supported the use of these barriers in a rain screen system no
02:17:44 in a rain screen system no did you or anyone else to your knowledge at studio e discuss the suitability of these cavity barriers with in a rain screen system with the manufacturer with siderest
02:17:56 with the manufacturer with siderest i'm not sure i did not have those conversations so i'm not aware of them but i believe they must have happened but i don't know did it ever occur to you that in the event of a fire the acm
02:18:07 you that in the event of a fire the acm might buckle and provide a route for fire to spread within the cavity notwithstanding the presence of cavity barriers
02:18:20 that doesn't quite make sense if the cladding has buckled it's created void which which would be yes
02:18:31 created void which which would be yes and there's no hard surface for the cavity barrier the intumescent to expand and seal is there it's outside yes yeah and that
02:18:44 my understanding is that's the degree of protection that the barrier offers it's only until fighting and fails
02:18:55 can we move forward in time to a query that was raised by harley uh later much later on in the project in march 2015 can we go to sca three zeros one two nine zero six
02:19:14 if we can blow up the top of that what we can see is that on the 6th of march 2015
02:19:20 2015 there's an email from neil crawford to kevin lam and simon lawrence kevin lam was doing work at a time for harley
02:19:28 harley and simon lance for ryden copying you in and others and he says hi kevin as per telephone conversation i've asked the question of x over on the
02:19:40 i've asked the question of x over on the fire break but not had anything back to me the fire breaks would have to follow the ratings of the party wars which is shown on the fire plan attached you can see some of the low-level apartments are separated by
02:19:51 low-level apartments are separated by 120 minutes and others by 60 minutes do you see that yes and attached to that is a far strategy drawing
02:20:02 strategy drawing and do you remember looking at the drawings that were attached to this email at the time no no so you didn't
02:20:13 no no so you didn't i was copied in as as um being notionally still the project lead but neil was fronting it so does that mean that you wouldn't have
02:20:24 so does that mean that you wouldn't have looked at those drawings and noticed that there were no cavity barriers at the head
02:20:28 the head jam or sill of the windows in those drawings
02:20:32 drawings no i wouldn't have scrutinized the email which was
02:20:35 which was copied to me for information
02:20:39 okay um
02:20:46 can we go back to sea three zeroes one two
02:20:49 two nine o six
02:21:01 so um mr crawford is saying there that he's asked the question of x over on the fire break but not had anything back um now just to put this in context in
02:21:13 um now just to put this in context in terms of time again the nbs specification was dated january 2014 can you explain why it wasn't in march 2015 the question of the fire resistance
02:21:24 2015 the question of the fire resistance of the cavity barriers was still outstanding
02:21:30 i think this pertains to neil's evidence as to the rfi that hardly raised in the conversations that
02:21:41 hardly raised in the conversations that ensued
02:21:41 ensued yeah but did this not alert you to the fact that xover's advice was unfinished or incomplete on the external wall
02:21:52 wall the fact that this query was being raised
02:21:58 at the time that no i i understood that there was a discussion going on that's all i it's all i recall did you know at the time that the question had been asked of x
02:22:09 question had been asked of x over and but they hadn't had anything back yet
02:22:14 no
02:22:17 and this didn't prompt you to ask x over for a comprehensive strategy or advice on the specific cladding proposals at that time
02:22:27 no
02:22:31 and i want to ask you just a few questions about cavity barriers in the crown if we can go to drawing
02:22:39 sca402551 and we'll need the offline version of that
02:22:47 this is dated it's a drawing you can take it from me i'm peter it's small it's dated the 26th of september 2013 and it also formed part of the
02:22:56 of the employer's requirements and it's a drawing of the facade where it meets the the top of the building the crown of the tower
02:23:04 tower if we look at the very top right hand side
02:23:08 side so i want to look at that section on the right
02:23:12 right if we can go into that
02:23:16 do you see at the very first label at the top it says design of the crown detail tbc by architect do you see that there
02:23:24 there yes so is it right that at that stage um that part of the design was outstanding it hadn't been worked out yet
02:23:37 it hadn't been worked out yet correct yes and does it also follow that not much thought would have gone at that stage into where cavity barriers should be located at the crown i'm correct
02:23:51 at the crown i'm correct now we can see a horizontal cavity barrier uh appears to be there at the root at the
02:24:02 appears to be there at the root at the um
02:24:03 um at the head of the window on the top floor can you see there's a smaller hatched little rectangle there do you see that sorry at the head of the window yeah yes
02:24:16 but there's no other detailing about cavity barriers at the top of the building is there no and no indication of how the horizontal cavity barriers at the top would meet with the vertical
02:24:27 top would meet with the vertical cavity barriers
02:24:31 well it's a section rather than a detail at the corner but there are dotted lines i see beyond which as they appear on the section on the
02:24:42 as they appear on the section on the left i would interpret as being the barriers behind the cladding we don't get an elevation of that do we
02:24:54 no we haven't been able to find one so was it the intention that studio e would be carrying out further detailed design work of the crown at a later stage
02:25:05 um the work is sorry the design is outstanding because of the ongoing planning negotiations and i i believe it was
02:25:16 negotiations and i i believe it was clarified as part of the actually i think it was part of the material submission can i show you another drawing um from
02:25:27 can i show you another drawing um from mr hyatt's report this is phyr603 at page 50 and it's figure 3.21
02:25:42 and this is mr hyatt's um elevation where he's shown how in his opinion cavity barriers should have been arranged
02:25:53 should have been arranged around the crown at the head of the building do you see that
02:25:59 yes can you explain why studio e never produced a similar drawing to this on the grenfell project in an elevation which looked at the
02:26:10 in an elevation which looked at the cavity barrier detailing at the top of the building i think this comes back to
02:26:23 i think this comes back to the same position as we did not expect to be
02:26:27 to be detailed designing every aspect of the envelope
02:26:30 envelope okay so that was something you left to harley and ryden to to work out was it correct
02:26:44 um staying with the crown for a moment um can we go to sea 40663
02:27:03 um can we go to sea 40663 this is an email um to you from you sorry to paul duncan on the 16th of november 2012. do you see that there yes and these seem to be notes
02:27:17 yes and these seem to be notes from your um from the architecture appraisal panel aap meeting on the 15th of november 2012 is that right correct and at the fourth bullet from
02:27:28 correct and at the fourth bullet from the bottom it records um it says white lump at top opportunity to do something with the top of the building amenity space question
02:27:40 of the building amenity space question mark conservatory question mark do you see that there yes and you've said in your statement that in response to this studio e increased the height and elaborated the design of the crown
02:27:51 design of the crown that's at paragraph um 154.3 of your statement is that correct that's correct
02:27:59 now is it right then that some changes to the crown were then suggested as part of the value engineering process
02:28:08 let's look at a document can we go to sea sca407672
02:28:18 this is an email dated the 22nd of may 2013 from robert powell of apple yards later artelia to philip boo the vartelia copping you in do you see that
02:28:31 yes and i want to look at the second paragraph we can see there he says um the perception is that if we
02:28:43 he says um the perception is that if we retain the planned external envelope treatment
02:28:46 treatment alloy windows and only reduce the scale of the crown then we are not departing too wildly from the existing planning application and then he talks about what the biggest question remains over the access to the
02:28:57 question remains over the access to the walkway and the lift do you see that there
02:28:59 there yes and is it right that any reduction in the scale of the crown would have been subject to the approval of the planning offices
02:29:11 at this point i'm sorry you've you've jumped over quite a big um event which was that architect's appraisal panel yeah and the feedback we received yeah
02:29:22 yeah and the feedback we received yeah um and what happened thereafter right um
02:29:26 right um [Music]
02:29:28 [Music] you wanted me to comment on
02:29:32 the question i asked you is it right that this would all be subject to the approval of the planning offices because and that their judgment would be based on appearance rather than considerations of fire safety
02:29:43 considerations of fire safety correct yes
02:29:46 now um i think we've seen that no detailed design work uh had been done um for the crown at the tender stage we
02:29:57 for the crown at the tender stage we just looked at that can we just look at something in the very first draft of the mbs specification dated the 21st of november 2013.
02:30:07 2013. can we go to that sca 50152
02:30:19 can we go to that sca 50152 so um this draft we we know it we believe it was dated the 21st of november 2013 and it was a draft before the one on the 29th of
02:30:30 draft before the one on the 29th of november 2013 which was issued to tenderers
02:30:33 tenderers yeah sorry this was january this was 29th of uh sorry 21st of november 2013. so this is what we think is the first
02:30:44 so this is what we think is the first draft of the nbs specification that we can find there seems to be another one on the 29th of november 2013 and then there's the one from january 2014
02:30:54 2014 which was the final version um can you recall who was sent this first draft of the nbs specification no
02:31:05 i did i i i believe if it was a first draft it
02:31:09 draft it possibly wasn't a should for tender no no i don't think it was issued for tender we think it might have been sent to the tmo but we can't see it being sent to anybody else might that be right
02:31:21 i can't recall okay can we look at page 81 within this draft this first draft and i look at clause 130
02:31:36 so this earlier version has some detail included for the crown which was not included in the later
02:31:48 which was not included in the later versions
02:31:50 and it states under material do you see it says there is the second bullet point there and it says material panel made up of two sheets of zinc that
02:32:01 panel made up of two sheets of zinc that are 0.5 millimeter thick and thermo glued on either side of a mineral-rich polyethylene core do you see that yes and i want to ask you about that that
02:32:14 and i want to ask you about that that those words mineral-rich polyethylene core did you appreciate at the time that the reference to that mineral-rich polyethylene core was likely referring to an fr fire
02:32:26 was likely referring to an fr fire retardant core no
02:32:31 so no i and i didn't prepare this in the first instance do you know i'm sure that would have who within studio sorry unfinished i'm not sure who did it and prepare this although
02:32:44 i'm injured i keep bringing up work that was done almost a year before this but i i
02:32:49 i think a good portion of this specification had been completed by adrian jess okay and he he would have he may well have put this in
02:33:00 put this in but there was never any intention to have a different to the crown as to the rest of the building
02:33:09 um i want to ask whether or not you were aware though at the time that there had been a desire to provide a superior fire rating
02:33:20 a superior fire rating for the crown over and above the fire rating for panels on the rest of the building lower down no so you can't explain to us why this
02:33:32 no so you can't explain to us why this is talking about a mineral-rich polyethylene core i think it's because the specification goes back to anywhere from december 12 to
02:33:45 anywhere from december 12 to february 13 when we were considering as incomposite
02:33:52 and this is a secondary clause to to h92 non-standard item being the crown so i think the first draft possibly for this h92
02:34:05 possibly for this h92 made reference to vm's inc that's my my i see yeah understanding but you see why we're asking you about this you can understand why the reference to a mineral which polyethylene core
02:34:17 mineral which polyethylene core something that i think that's copy pasted from manufacturer's information i see but you don't think it would have been understood within studio e that that was a superior panel
02:34:30 e that that was a superior panel to the one that finally appeared for the more general sections of the tower in the later version of the mbs spec
02:34:40 or at least for my side definitely not a mineral which is ambiguous i see when i say superior i mean superior to the rayna bond acm panel that was one of the alternatives
02:34:55 the core you meant you're talking about superior core or superior finish superior fire performance no
02:35:06 now can we just look at another drawing we'll almost finish this topic sea sea402596 this is another one of the employers
02:35:17 this is another one of the employers requirement drawings
02:35:29 and if we see at the top of the building this is it right that this drawing is showing
02:35:33 showing um what some people have described i think on the project as a radiator effect design for the top of the building which is what was ultimately installed wasn't it yes so so channels of uh acm
02:35:46 yes so so channels of uh acm c-shaped tunnels that were interconnecting the the um you could the white lump that um we'll also prefer to in his um feedback
02:35:57 we'll also prefer to in his um feedback on
02:35:58 on at the aap is the plant room at the top the tank rooms the left motor room
02:36:04 room yeah and the the other for instance the the exhaust for the bathrooms and the yeah lobbies they're all contained
02:36:15 the yeah lobbies they're all contained within that concrete box which is set back from the edge yeah the smoke extract that top and the existing building included
02:36:25 included perforated precast panels which you might see on you will see on earlier photographs which provided a kind of crown
02:36:36 which provided a kind of crown yeah existing crown and this was our solution to concealing that existing um precast element yeah to unify the
02:36:48 um precast element yeah to unify the appearance
02:36:52 did you ever consider the fire safety of the crown
02:36:57 the crown at any point during the design process
02:37:07 we were not aware of the combustible risk of acm otherwise of course we would that charm
02:37:18 otherwise of course we would that charm to my thinking at the time was was just metal outside and therefore presented no hazard or risk see so um
02:37:29 or risk see so um does it follow that that were there ever any discussions forget acm for a moment about
02:37:36 about the crown and fire in relation to the crown
02:37:40 crown and the need to consider whether or not the crown might be a vehicle for fire spread in the event of an external fire
02:37:50 i i watch professor terrera's
02:37:59 evidence because i certainly didn't understand the risk that it posed no so is the answer to my question no it was never discussed
02:38:12 sorry i can't i my transcript's still not working can you just be clear was it ever discussed no it was never discussed
02:38:26 in terms of the design of the windows now
02:38:29 now um sorry there's one more topic on cavity barriers which i just want to cover um did you ever discuss the cavity
02:38:42 um did you ever discuss the cavity barrier strategy with mr crawford when he gave his evidence he said that you were adamant that the cavity barrier strategy was correct
02:38:53 correct and what he seemed to mean by that was i not around the windows but just along compartment lines he said that day 10 page 190 lines 13 to 15. do you recall being adamant in
02:39:05 do you recall being adamant in discussions with mr crawford about this cavity barrier strategy being correct i can't remember being adamant about the cavity barrier strategy being correct but i was
02:39:15 but i was confident that thomas had checked it with
02:39:19 with someone and that it was um it was viable viable it was um we could expect it to be accepted
02:39:30 i i had confidence in what thomas had presented to me would you agree that a reasonably competent architect would prepare an
02:39:42 competent architect would prepare an indicative design of amongst other things the cavity berry arrangement four stages riba stages d and e no does it follow that
02:39:56 no does it follow that you don't agree therefore that this work should start with a review of statutory standards and relevant guidance um
02:40:11 the principles were understood so i i'm not sure i understand the question
02:40:19 did studio e to your knowledge ever do a review of statutory standards and relevant guidance for the cavity barrier arrangement at grenfell tower
02:40:32 i think i want to repeat what i said earlier these statutory requirements as contained in the brief document are guidance and requires a high degree of interpretation
02:40:48 requires a high degree of interpretation so it's not it's not possible to go down the list and take off items
02:40:57 i think the question was whether studio e had undertaken in an investigation into that wasn't that your question absolutely on our own um
02:41:09 i think i think that's i can only refer to what's borne out in thomas's and neil's evidence as evidence that we did take steps to to check
02:41:22 can we just look at a couple of um examples from mr hyatt's report before we we break if we can go to phyr 603 at page 64.
02:41:45 603 at page 64. so here and in a series of um drawings what mr hyatt has done is he's indicated
02:41:52 indicated where the position of the cavity barriers was as indicated in the harley drawings and then where the cavity barrier position he says should have been at the window jam so it's the difference between the solid
02:42:03 it's the difference between the solid red line and the dotted red line do you see that there yes and there are a number of these um drawings let's look at another one for example at the sill if we look at page 65
02:42:17 he's outlined in a dotted line where at the sill
02:42:20 the sill level a cavity barrier ought to have been whereas no cavity barrier was shown in the harley drawings and then he at the window head on the next page 65
02:42:32 he's indicated that the cavity barrier should have been immediately immediately at the window head in the dotted line rather than remote from it in the solid red line do you see that there
02:42:44 yes did you think it was studio e's responsibility to address this kind of detailing in its designs
02:42:56 no can you explain why why not this level of detail is special stage f um fabrication or detail design
02:43:09 um fabrication or detail design [Music]
02:43:11 [Music] so i don't believe that fell to us to direct highly on as to how they
02:43:22 direct highly on as to how they proposed to to satisfy the requirements of the
02:43:25 of the employer's requirements
02:43:30 that was my next question did you think it was studio e's responsibility to make sure harley addressed this kind of detail in
02:43:36 detail in its designs
02:43:41 under what's under what authority well under the ride and deed of appointment for example seek to ensure that designs met the
02:43:52 seek to ensure that designs met the statutory standards that was one one provision within that deed of appointment but forget the detail of that deed for a moment i just want to know whether you understood at the time that it was
02:44:03 understood at the time that it was studio e's responsibility to make sure harley addressed that kind of detailing in its designs
02:44:12 i don't believe it it was at all i think that would have that would have created um duties which we did not expect to have that would place
02:44:26 designers fuller's design responsibility on studio e so i think i think we it was a very clear line and that and that is very typical of design and build as a
02:44:40 design and build as a as a method of procurement so does it follow then that you wouldn't have expected mr crawford to pick up on those kind of design issues for example nothing at the sill and
02:44:54 you wouldn't have expected mr crawford to be questioning that when he was being shown the drawings i think
02:45:01 think you have to look at each detail in in on its own but if you take this option here sorry this detail in front of me where the location of the barrier above the
02:45:12 the location of the barrier above the window
02:45:15 window needing to be literally at the window head
02:45:21 to me introduces all sorts of um
02:45:26 practical problems for the installer
02:45:32 and i'd also not clear why that would have been
02:45:37 have been a requirement under any reading of the proof document so i think the the
02:45:45 onus on neil to flag it is false i don't think he did have that bonus
02:45:52 bonus just one final question if i may were you ever
02:45:55 you ever personally involved in considering harley's design drawings after studio he was novated to ryden or did you leave that task to mr crawford
02:46:09 as far as i can recall that i left that entirely to to neil i certainly remember seeing drawings coming in and but i didn't i didn't seek to study
02:46:21 and but i didn't i didn't seek to study them
02:46:22 them okay
02:46:30 there's been a bit of a problem with the transcript well my live channel yours has no no mine hasn't been running and nor's the one up there well we'll have to investigate what's happened over the lunch break but that is an appropriate moment if that's okay
02:46:42 appropriate moment if that's okay yes we'll we'll have a break now for lunch mr sins we'll come back at two o'clock please and uh
02:46:49 and uh you go to the usher don't talk to anyone about your evidence please um
02:46:56 please um mr strange will i'm sure that those who are dealing with the transcript know there's a problem i can only apologize to you and everyone else is trying to make this and we'll hope this back in action at two
02:47:07 we'll hope this back in action at two o'clock
02:47:08 o'clock exactly right thank you
02:47:34 you