Neil Crawford of Studio E on Exova's role as fire engineer and specification of Celotex RS5000 insulation
00:01:17 Good morning everyone. Welcome to today's hearing. We're going to continue hearing evidence from Mr. Crawford in just a moment, I think. So, could we have Mr. Crawford in please?
00:01:42 Good morning, Mr. Crawford. Morning.
00:01:44 Morning. I hope you're ready to carry on. Yes.
00:01:46 Yes. Good. Thank you. Yes, just a minute. Mr. Chairman, Mr. Crawford, good morning.
00:01:50 morning. Morning.
00:01:50 Morning. Um, I want to uh turn next to Exover and your dealings with them. Your you worked with Exova on the Calk project, didn't you?
00:02:01 you? That's correct. Uh was it you who recommended Exova that they work on the Grenfell Tower project? Um no.
00:02:08 Um no. Uh do you know who did? No.
00:02:10 No. Do you know anything about how Exova came to be involved on the cult project at all? Um
00:02:17 I believe there's um
00:02:24 I believe there's a uh an indication early on that there was a certain convenience in transferring the same consultant team across. I think we heard that from the earlier. Yeah. But on the calc project I meant
00:02:36 Yeah. But on the calc project I meant who who got inv exo involved Oh, sorry. Originally on the calc project. Oh. Um gosh. Um
00:02:44 gosh. Um I I don't recall. Okay.
00:02:47 Okay. Um what was your overall impression of the quality of cal of Exover's work on the calc project?
00:02:56 Um the the project was complicated by the fact that um there was um a requirement for there is well there's discussion of
00:03:07 for there is well there's discussion of various strategies in terms of escape that involved um sprinklers or not using sprinklers and then there was complications in relation to um the
00:03:19 complications in relation to um the engineering strategy to accommodate that. So it wasn't straightforward. There's a number of revisions done to the strategy to um get that resolved.
00:03:30 um get that resolved. Can we please go to SEA 000000453
00:03:36 please?
00:03:41 Now, this is an email um dated the 24th of April, 2012.
00:03:51 And uh you are copied in on it if you see the list of copy E. Yes.
00:03:57 Yes. And it's sent to Terry Ashton of Exover. And in the second paragraph, you can see the attachments and the subject matter. its calc and Grenfield Tower upgrade.
00:04:08 its calc and Grenfield Tower upgrade. So, it's at a time when both are being considered. And in the second paragraph, you see that um Bruce Zones says to Terry Ashton, "We've thus far had no
00:04:19 Terry Ashton, "We've thus far had no commitment in writing from you to a fire strategy on either the Cal Measure Center Academy residential development or the Granfell Tower upgrade. We've had no concrete input by way of drawing markups or draft reports to support the
00:04:31 markups or draft reports to support the developing designs. This is becoming critical for us with three weeks to go before we submit the stage D report for Cal with much of the work undertaken so far by the whole team relying on the
00:04:44 far by the whole team relying on the fire safety advice we've received at the meetings at meetings we fear that the designs have not had adequate scrutiny and that we are at considerable risk at this late stage of late changes abortive
00:04:55 this late stage of late changes abortive work and possible cost implications to the project. And then in the third paragraph Mr. Stone says, "If you are unable to reassure us that you are committed to the two projects by the end
00:05:07 committed to the two projects by the end of this week, both agreeing contract terms and providing detailed advice, we will regard this as a renunciation of the commission and be forced to look elsewhere for fire safety." Uh, my first
00:05:19 elsewhere for fire safety." Uh, my first question, Mr. Crawford, is when you were copied in on that email, did you read it?
00:05:26 That's eight years ago. I mean, probably. Do you have a do you remember reading it do you think? I don't I mean I have to say Andre and Bruce were more involved with setting up the projects in terms of managing
00:05:37 the projects in terms of managing consultants and bringing them in. Um I would I would have been copied it. I would have I would have I probably would have read it. Yes. Right now it was Mr. S's evidence that he was passing on a concern uh to Mr.
00:05:50 he was passing on a concern uh to Mr. Ashton from the calc team. Um, was that your concern that that Exova had not provided adequate scrutiny of the drawings for calc? I can't recall.
00:06:01 I can't recall. Was it your concern that Exover had um put in no concrete input on calc at that stage?
00:06:08 stage? I don't recall. Did you have any discussions yourself with Mr. Ashton or anyone else at Exover at that time regarding regarding resourcing issues? Not that I'm aware of.
00:06:20 Not that I'm aware of. Did you discuss the contents of this email with Mr. S at all? I can't recall. Okay. Uh I mean against the background of what is said in this email to be
00:06:31 of what is said in this email to be studio ease at least dissatisfaction with Exova's work on the project in the way they set out there. Do you know why you recommended them for the Granfell Tower project?
00:06:42 Tower project? I I didn't personally recommend. You didn't. Do you know why you were content with them to be the fire engineer on the Grenfell Tower project? I I'd have said the job they did ultimately in Cal was pretty good. Did X
00:06:55 ultimately in Cal was pretty good. Did X overdo anything in response to this email to uh LA your or Mr. S's concerns as expressed there in that email? Um I couldn't recall. Could we please
00:07:08 Um I couldn't recall. Could we please turn to LBI uh and 000000 so five zeros please 620 and go to the bottom email in the chain
00:07:20 and go to the bottom email in the chain which is at the bottom of page two.
00:07:26 Uh now this is an email of the 10th of October
00:07:31 October 2012 from Colin Charles of Leadbit Bitter to Andre Kushelle. Now, you weren't copied in on that email, but you um you were you were copied in on the email above it, but I'll just show you
00:07:43 email above it, but I'll just show you this one to start with. Um Andre, I have still, and this is from Colin Childles, I have still to receive a satisfactory response from the design team with reference to the concerns raised by the
00:07:54 reference to the concerns raised by the Gag, the Granville Action Group. Our client requires us to deal with this, and I'm not willing to commence the works until I receive demonstration that the fire safety of the estate has been considered with on the design. This is a
00:08:05 considered with on the design. This is a clear requirement of the of the CDM regulations. The response received from Exovia is in my opinion casual. Uh should I issue this to GAG, it would further exacerbate an already high
00:08:16 further exacerbate an already high project risk. I must have a proper response regarding consultation with BC and LFB by return regards Colin C. And then if you look above it,
00:08:28 then if you look above it, uh Mr. Kushelle replies and you were copied in at that point. If you go to the uh top uh you can see just running right from the very top of the page, Colin Charles
00:08:40 the very top of the page, Colin Charles uh sends the email string uh below it uh to uh uh you uh and then below that um you um you can see uh that uh or two
00:08:55 you um you can see uh that uh or two below that Andre Kosell responds to him and then above that is your response to Andre Kosell and Colin Charles just to set the context and what Mr. Cashelle says.
00:09:06 Um, yeah, if you just if the operator can move down to that one, Colin, that's right. We look at that. The safety of the estate has been considered. Then if you look six lines down, you you can see
00:09:17 you look six lines down, you you can see uh that Andre Kushell says, "As you know, the separate Granville Tower Commission is running behind Cal with designs currently sitting at stage C and BC LFB consultations still to occur. As
00:09:29 BC LFB consultations still to occur. As far as we are aware with the proviso on the granful landscape, the proposed uh academy
00:09:36 academy uh and leisure developments are not impacting on the fire safety of the estate. I've asked Neil to get back to you on the details of the calc BC stroke LFB consultations held to date.
00:09:47 LFB consultations held to date. uh and you then uh write to Andre Kashell and Colin Charles on the same day 10th of October.
00:09:58 on the same day 10th of October. Uh and you say Colin, our contacts at RBKC have been John Allen and Dave Gammon. And you explain that and then you say in the next paragraph following an initial meeting with building control on the 28th of October 2011, I did ask
00:10:11 on the 28th of October 2011, I did ask the question in relation to fire access to and around the tower C attached. However, this was not formally responded to, although we were led to believe all access is from Grrenfell Road. And then Colin Charles response to that above
00:10:22 Colin Charles response to that above that on the page as you can see there. Thanks, Neil. I'm afraid we need a formal response from RBKC. Please chase this. Now, I've shown you the whole email string. Um, do you remember
00:10:33 email string. Um, do you remember reading Mr. Child's email uh and when you received Mr. Kushell's reply from eight years ago? No. No. Um, do you accept that Mr. Charles's
00:10:44 No. Um, do you accept that Mr. Charles's concerns about Exov's performance, which are set out at the bottom of page two, which I read you, um, should have put you on notice as to Exovover's, um, perhaps somewhat less than thorough
00:10:56 perhaps somewhat less than thorough approach at that stage. Well, certainly they might not have been as mobilized to to the extent that they might have been at that point,
00:11:07 might have been at that point, right? Um going forward in time just under two years to the summer of 2014 when you took on the Granfell Tower project. Yeah. Do you remember whether during your dis
00:11:18 Do you remember whether during your dis handover discussion with Mr. Stones uh you had a conversation with him about the involvement of Exover in the Grenfell Tower project?
00:11:29 Possibly. I was aware of the fire report.
00:11:38 Do you um was it your understanding at that stage that Exover had been instructed to assess fire safety issues as they pertained specifically to the overcladding of Grenville Tower?
00:11:51 overcladding of Grenville Tower? I understood that they they produced the um high level fire strategy report.
00:12:03 Uh is that something that Mr. Sains told you?
00:12:07 you? Um this pretty much mandatory in any project project of that um nature and complexity. Was it your understanding that Exova would would be well let me start try a
00:12:19 would would be well let me start try a different question. Uh when you came into the project say we're looking at July August 2014 did you ask Mr. zones to see the reports,
00:12:30 to see the reports, the fire strategy reports that Exoba had produced so far on Grenfield Tower. I'm not sure if I asked him, but I would have read them at some point. Right. Do you remember when you read them?
00:12:41 them? Specifically, no. Was it your understanding that Exova would in future be producing advice on the application of regulation B4 of the
00:12:52 the application of regulation B4 of the building regulations 2010, external fire spread?
00:12:58 Is that your understanding at the time?
00:13:05 Um, I'm not sure. You're not You're not sure as in you can't remember or you can remember not being sure. Um,
00:13:17 Um, well, my my understanding is they would have had the fire strategy report and I would have read that fair fairly early on,
00:13:23 on, right? because it's obvious a priority to understand I mean specifically B1 and B5 issues I mean they're very primary to any scheme particularly where there's any complexity so you would look at
00:13:35 any complexity so you would look at those and understand those and get your head around them as part of coming into the project if you like so you'd understand this in terms of specifics to the facade
00:13:46 the facade um
00:13:51 where it was where it was relevant You'd also expect um um commentary on that. Yes.
00:13:59 Yes. Yeah.
00:14:00 Yeah. Yes. And again I'm just just focusing on the moment you came into the Granful Tower project July August 2014. Uh did you think or expect uh that
00:14:12 Uh did you think or expect uh that Exova's work would cover the entire uh of the Granfell entirety of the Granfell Tower project or just a part of it?
00:14:25 I would expect you to cover um where it was relevant. Where it was relevant. Yeah.
00:14:32 Yeah. So all of it where it was relevant. Yes.
00:14:35 Yes. I see. Thank you. Now, uh, when you came into the project summer of 2014, did you know that Exova had at that point so far produced five fire
00:14:49 that point so far produced five fire safety strategy reports? And I'll just list them for you. There's a report on the existing fire strategy for Granfell Tower of August 2012 and then a design
00:15:00 Tower of August 2012 and then a design note in September 2012 and then um issue one of the outline fire safety strategy for the refurbishment um 31st of October 2012, issue two of
00:15:13 um 31st of October 2012, issue two of the outline fire safety strategy for the refurbishment of 24th of October 2013 and then issue three of the same strategy dated 7th of November 2013. And I should also
00:15:25 7th of November 2013. And I should also just be clear the initial design note was also for the refurbishment. Now there are five of those. Do do you remember that um at that stage when you
00:15:36 remember that um at that stage when you came in there were five such reports which Exavver had done. What what I'd do when I come into any project is look at the most recent fire report to understand the status of the
00:15:47 report to understand the status of the project relative to the fire strategy at that time. would have gone back and read the historical ones. Not necessarily. I see. Well, we'll come back to that in
00:15:58 I see. Well, we'll come back to that in in a moment. If you can go please to paragraph 71 of your witness statement, which is SEAL triple014275 at page 28.
00:16:09 at page 28. Paragraph 71.
00:16:17 Uh, and you uh you say uh you discuss an email exchange in September 2014 between uh Harley Ryden and Studio E in relation uh to a request
00:16:31 and Studio E in relation uh to a request for information an RFI regarding horizontal fire brakes um in relation to cavity barriers and we'll come back to that later in your evidence. Can I ask you to be shown page 29 within the same
00:16:45 you to be shown page 29 within the same paragraph? uh where you say uh third line down uh in short I contacted Exover which was the fire engineer on the project on the
00:16:56 the fire engineer on the project on the project
00:16:58 project uh and produced the fire strategy reports. You see that? Yes.
00:17:01 Yes. I would have contacted Exover as it is an authority on all things fire related. Yes. Now my question is was it your understanding at that time that prior to noation prior to your DOE's noation
00:17:15 noation prior to your DOE's noation Exova was the quotes authority on all things fire related your words in respect of the refurbishment at Grenfell?
00:17:23 Grenfell? Yes.
00:17:23 Yes. Yes. Did you have any reason to to believe at that time that Exova's role had changed postnovation? No.
00:17:32 No. So when you refer here to the fire strategy reports, can you just be clear what you're referring to?
00:17:47 Um, all the reports that they had created.
00:17:51 created. All the reports. Thank you. And I think you say you had read those as part of the is this right? As part of your coming into the project. is is part of coming into any project
00:18:02 coming into any project personally that's what I always do I go straight to the fire strategy to understand fire strategy of the project at the current time right
00:18:09 right I would have seen normally the way we file things we'd have had a consulting folder and it would have been labeled Harley or whoever it was and you
00:18:21 Harley or whoever it was and you navigate to there and look at the dates and read them whether you'd go back and read them all from the start as in vision one, revision two, vision three, possibly not. You'd certainly look for
00:18:32 possibly not. You'd certainly look for the latest. I may also have read it as part of the um
00:18:39 um stage employers requirements tender set that Bruce had as a physical set on his desk.
00:18:44 desk. Yes. Yes. I see. Now um let me take you then to the latest that you say you would have read and in fact I think you said on Thursday afternoon last week that you had in fact read it. Uh, that's
00:18:56 that you had in fact read it. Uh, that's just for the for our own record. That's day nine, page 136 at lines 13 to 20. If I can ask you to look at it, it's EXO 416.
00:19:15 Uh, and you can see there it's dated the 7th of November 2013. It's issue number 03 and it's a report to studio E. Do you
00:19:26 03 and it's a report to studio E. Do you see that?
00:19:27 see that? Yes.
00:19:28 Yes. Um, when you first read that as part of your handover with M from Mr. SS, did you do you remember dis you remember discussing its contents with Mr. S? Remember? No.
00:19:41 Remember? No. Do do you remember uh discussing anything with Mr. S about Exov's input at that stage?
00:19:52 Um
00:19:55 I can't recall but it doesn't mean that I didn't or
00:20:01 can I ask you please to go to page four under the introduction. Uh
00:20:08 Uh but it says there you see it says the refurbishment comprises and just look with me if you would at it there are five bullet points. Bullet point one is ground story level. Bullet point two is metzanine level. And then bullet three,
00:20:21 metzanine level. And then bullet three, walkway level. Bullet four, walkway level, walkway plus one level and the creation of four new residential apartments. And bullet five, generally
00:20:32 apartments. And bullet five, generally improvements to the building services. And then it says, "This report details the applicable statutory controls in respect of fire safety and contains an outlined fire safety strategy for compliance with these statutory
00:20:44 compliance with these statutory controls.
00:20:45 controls. The report is based on discussions held with the design team, the Royal Burough of Kensington and Chelsea and on fire access and fire strategy drawings produced by Studio ELLLP.
00:20:56 produced by Studio ELLLP. You see that? Yes.
00:20:57 Yes. Um it it we can see, can't we, that the introduction section doesn't make any reference at all to the overcladding of the exterior of the building, does it?
00:21:08 the exterior of the building, does it? No, but the last section does. The last section does. That's the whole report. Ah, okay. But but when you're looking at the summary of what the refurbishment comprises
00:21:19 comprises and we could read it together, we can see that it doesn't make any reference to the overcladding. My question is did you note the scope of the summary of of
00:21:31 you note the scope of the summary of of Exova's report uh when you read it? I believe it was within their terms of appointment that they were to look at the um
00:21:42 cladding or the external facade
00:21:47 in in indeed. Um did you look at the terms of appointment when you read this report? Did you put the two side by side?
00:21:56 side? I don't recall putting the two side by side, but Bruce may have mentioned terms of appointment. Bruce S mentioned to you the he may have mentioned
00:22:07 he may have mentioned right let let me just be clear when you had a conversation with Mr. Sains at the handover
00:22:13 handover um are are you can do do you remember having a conversation I don't Mr. S about
00:22:17 about as I mentioned earlier I don't specifically remember anything specifically in relation to the report that's not because
00:22:27 because it didn't happen it's because it's eight years ago and I don't have that level of recollection. Okay, I understand. Let me see if I can get at it this way. When you, as you say, you did read this report and you
00:22:40 say, you did read this report and you looked at introduction, do you remember what your thoughts were about the scope of the work Exova had been asked to do? I don't know. To me, it just reads like a fairly standard sort of generic
00:22:53 a fairly standard sort of generic introduction description of a project. Right.
00:22:56 Right. You knew I I'm and I'm I'm suggesting this because I think it's common ground between us, M. Mr. Crawford, that when you came into the project, one of the significant elements of the project was
00:23:07 significant elements of the project was the overcladding of Granfell Tower. Yes. Who's one of the elements? Yes. Yeah. So, when you read this report and saw the introduction and the description by Exov of what the refurbishment
00:23:19 Exov of what the refurbishment comprises, did it strike you as complete?
00:23:25 Or did it strike you as incomplete?
00:23:31 I I don't recall. I mean, I just read the report. I mean, I read the report from start to finish. And I I wouldn't I wouldn't I don't think I wouldn't analyze it in that way. I wouldn't be
00:23:42 analyze it in that way. I wouldn't be marking it or saying, you know, I'd just be because this is the third revision. This is where it was. I just read it, assume it, look at fire strategy drawings, look at the project.
00:23:53 drawings, look at the project. Um, I don't think I'd look at it in the terms you're sort of indicating. So, so can we take it that you didn't think to yourself when you read this report, oh, they've missed out the overcladding in their description of the
00:24:05 overcladding in their description of the refurbishment, but they didn't because it was later on. Well,
00:24:11 Well, but but in the introduction, it's not there, but the many things that potentially not in so is the answer to my question is my is the answer to my question no.
00:24:25 the answer to my question no. So, what was the question? Yes, of course. Uh, can we take it that you didn't think to yourself when we read this report they've missed out the overcladding in their description of the refurbishment?
00:24:42 Well, I guess not because I read it at the end,
00:24:44 the end, right? Did you maybe you don't remember, but did you have a discussion with Mr. S about the precise scope of what Exov were asked to do?
00:24:55 were asked to do? I don't recall. What about a conversation with Mr. Ashton? Did you have a discussion with him about the precise scope of what Exov were asked to do? Um, I don't recall.
00:25:08 Um, I don't recall. Do you
00:25:11 remember discussing with either of those two gentlemen where Exovover had got to in Exov's assessment of the issues pertaining to external fire spread at
00:25:23 pertaining to external fire spread at the time of your handover? I I would have understood it as per the line at the end of the end of report. We'll come back to the end of the report in a in a moment because I know you keep
00:25:36 in a in a moment because I know you keep referring to it and we will look at it. I suppose what I'm trying to say is at this point when I took over the project I'd have had an introduction. I'd have been concerned with certain things. The things I'd been concerned with were
00:25:48 things I'd been concerned with were essentially M1 and M5 issues because for example I knew some changes were happening in the lower levels. the lower levels from a fire strategy perspective were much more complex uh in my view and
00:26:02 were much more complex uh in my view and and I would have been aware of those and focusing on those um then I'd have read the whole report I'd have read the whole report in the context that it was the third version of the report and that's
00:26:13 third version of the report and that's where it was in the point in time I wouldn't be going back and analyzing it from the perspective of completeness of brief as you would at the start of a
00:26:24 brief as you would at the start of a object
00:26:25 object right could you mentioned M1 and M5 what are they
00:26:29 are they sorry B1 and B5 B1 and B5 I see now um do do you remember ever discussing with Mr. S or indeed Mr. Ashton uh where it
00:26:40 Mr. S or indeed Mr. Ashton uh where it had got to in its in its assessment of issues pertaining to external fire spread
00:26:47 I'm sorry to say this but again my understanding was what it said in the document which was at the end of the document
00:26:54 document this statement there. All right. Well, we we will look at that. Uh if you could turn the page to to uh the next page, please. Paragraph 2.1D.
00:27:05 2.1D. It's on the screen now. Uh the uh section two is headed statutory considerations and 21 the building regulations 2010. And then you can see
00:27:17 regulations 2010. And then you can see that the five requirements of schedule one are set out. There's B1 at the top and B5 at the bottom. And between them we've got B2 internal fire spread linings, B3 internal fire spread
00:27:28 linings, B3 internal fire spread structure and B4 external fire spread. Now, um it it it's clear or well was it clear to you from reading that uh that
00:27:40 clear to you from reading that uh that the report was going to deal with um each of those uh regulations or each of those requirements within schedule one so far as the refurbishment of the tower
00:27:51 so far as the refurbishment of the tower was concerned.
00:28:17 Yeah. My understanding would be that the report would deal with them in the terms in which they were applicable. Yeah. Can we look at page nine, please? And this should be paragraph 3.1.4.
00:28:30 And this should be paragraph 3.1.4. compliance with B4, external fire spread. Do you do you see that? Yes.
00:28:34 Yes. And it says it is considered that the proposed changes will have no adverse effect on the building in relation to external fire spread, but this will be confirmed by an analysis in a future
00:28:45 confirmed by an analysis in a future issue of this report. When you when you read this report, did you notice that paragraph?
00:28:58 Um,
00:29:01 I would have noticed it. I mean, if I read the report, I'd have noticed it. Yeah. And uh, did you consider or do you remember considering Exova's progress in
00:29:13 remember considering Exova's progress in relation to its advice on compliance with uh, B4 external fire spread? Did you consider how it would progress? What it says there?
00:29:24 What it says there? I'm not sure. I may have discussed with Bruce in the handover what his understanding was or what where he saw the level of compliance
00:29:35 compliance at that point. Um
00:29:39 do do you remember having a discussion with Mr. S on uh when studio expected to receive the um future issue of this
00:29:51 receive the um future issue of this report? I don't recall having a specific comment.
00:29:55 comment. Did Mr. S tell you to progress the uh next issue of this uh outlined fire safety strategy with Exova once the
00:30:06 safety strategy with Exova once the cladding subcontractor had been engaged and further detailed design had commenced? I don't recall. Did you ask Mr. zones what documents Exover had in order that they could
00:30:18 Exover had in order that they could complete the analysis they indicated would be provided. I don't recall. Did you yourself conduct any checks to see whether Exov had the documentation
00:30:30 see whether Exov had the documentation it needed to complete the analysis they said would be provided? I don't recall.
00:30:39 Did Did you Did you ask Mr. Ashton whether there was anything exo needed so that they could complete the analysis that they'd indicated would be provided in a future issue of that report.
00:30:55 Were you not in some way concerned that by August 2014, which was some 10 months or so after issue three, perhaps nine months after
00:31:06 issue three, perhaps nine months after issue three of this report, that an analysis of the compliance of the overcladding scheme with regulation B4 of the building regulations had not at that stage been completed.
00:31:17 that stage been completed. [Music]
00:31:18 [Music] My understanding was that the the the cladding is is detailed in the employer's requirements and um stage and the tender set was compliant and the the
00:31:30 the tender set was compliant and the the options were also compliant. Um
00:31:37 where was that understanding from? Um I guess that would have been from conversations with Bruce and also um I would have expected any schema tender
00:31:50 would have expected any schema tender stage to be compliant relative to that stage.
00:31:54 stage. Uh
00:31:56 Uh so let's just try and be clear here. Are you saying that Mr. S told you
00:32:07 Mr. S told you that the
00:32:10 that the uh cladding as detailed in the employer's requirements and the stage E tender was compliant with the building regulations. My understanding was that his
00:32:21 My understanding was that his understanding was that it was compliant.
00:32:26 If that was so, Mr. Crawford. Do you know why or do do you remember asking yourself why it was that as at November 2013 Exov were saying
00:32:39 November 2013 Exov were saying uh that they would confirm by an analysis in a future issue of this report whether the proposed changes would have any adverse effect on the building so far as external fire spread
00:32:51 building so far as external fire spread is concerned. Um it's possible because there's a number of options and final decisions hadn't been made particularly in relation to planning um uh what decisions came out
00:33:04 planning um uh what decisions came out of planning that that they wouldn't have done that final issue till let's say maybe they had um
00:33:14 more more detail I don't know possibly are you telling us that Mr. S had told you that even though Exovover had said in their 7th of November 2013 report
00:33:28 in their 7th of November 2013 report that whether the proposed changes would have an adverse effect on the building in relation to external fire spread would need to be confirmed by an analysis in the in a future issue of the report. Uh nonetheless there was no
00:33:40 report. Uh nonetheless there was no reason any longer to pursue such an analysis with Exova. I don't recall
00:33:55 If Mr. Sains had told you that you need needn't worry anymore about compliance with B4 as isue as indicated in this report because he had already had the
00:34:07 report because he had already had the confirmation needed. You you would remember that, wouldn't you?
00:34:14 Possibly. But you don't. No,
00:34:24 on the assumption and bear with me on this that Exov had not as at the summer July August 2014 given any confirmation
00:34:36 given any confirmation by an analysis whether in a report or otherwise that the proposed changes would have no adverse effect on on the building. so far as external fire spread was
00:34:48 far as external fire spread was concerned. On that assumption, it's right, isn't it, that Exova still had significant work to do as at that date in respect of assessing the compliance of the overcladding
00:34:59 the compliance of the overcladding scheme with the building regulations? Not necessarily. I mean my understanding was that they had been kept a breast of the development of the project and the
00:35:10 the development of the project and the scheme and therefore they knew exactly what was going on with the scheme and what the proposals were. So the fact that they
00:35:19 that they I mean they might leave that statement in the report but it it it didn't mean it doesn't necessarily mean that um what was proposed was in their view
00:35:30 um what was proposed was in their view not compliant or compliant. You say that that was your understanding. Yes. Was that an understanding which you had from being told that by somebody or was it an assumption that you made?
00:35:42 assumption that you made? Um I think that's understanding I had from Bruce. I mean I think Bruce was pretty clear that um that that
00:35:53 was pretty clear that um that that Exov knew what was going on and what was being proposed and that's did
00:35:59 did understanding I had. I'm so sorry. You want to finish your answer? I don't mean to interrupt you. That's it. Okay. Did are you just be very clear about this, Mr. Crawford, are you saying that Mr. S told you
00:36:12 that Mr. S told you that Exov knew what was going on and and just just be clear about this and were satisfied
00:36:18 satisfied that the proposed changes to Granfell Tower were compliant with the building regulations, specifically B4 external fire spread.
00:36:35 Can you phrase that again? Sorry. I will. Um, are you saying that Mr. S told you that ex were satisfied that the proposed changes to Grrenfeld Tower
00:36:47 proposed changes to Grrenfeld Tower would have no adverse effect on the building so far as external fire spread was concerned? I think that was his belief. Whether how he communicated that to me, I can't specifically recall, but I do believe
00:36:58 specifically recall, but I do believe that was his belief. Did you ever see a document
00:37:01 document that confirmed what you understood to be his belief? No.
00:37:09 Uh, did you ever ask him to get a document like that from Exover? I don't recall.
00:37:20 Given its importance, can you explain why you didn't ask Mr. stones to get a document like that from Exov or indeed seek one yourself.
00:37:31 Exov or indeed seek one yourself. [Applause]
00:37:39 Perhaps it's a feeling that um well I'm not entirely sure but I think as I stated earlier my impression was that Bruce understood what had been
00:37:50 that Bruce understood what had been proposed up to then in his eyes and in Exov's eyes was compliant. Do you agree that Exova's work at the tender stage so uh late 2013 Mr.
00:38:06 tender stage so uh late 2013 Mr. Crawford had not been brought to a state of completion so as to form a satisfactory basis on which to proceed with further design and uh and specification of products. Um I couldn't
00:38:18 specification of products. Um I couldn't comment on that because not involved in that period of works. I think that's comment a question for Bruce. A question for Bruce. All right. Uh
00:38:32 A question for Bruce. All right. Uh but would you agree that unless you knew whether or not for sure the cladding design was compliant with B4, then you couldn't really make any progress yourself?
00:38:43 yourself? Well, as I stated, my understanding was from Bruce that he believed that it was compliant. Right.
00:38:53 Right. But you never really interrogated Mr. Sains. That's a harsh word. You never scrutinized with Mr. says what the basis of his belief was. Well, you just not in the way you are
00:39:04 Well, you just not in the way you are now. No,
00:39:05 now. No, no. But in any other way, I I don't recall. I mean, we generally when you have these conversations, they're fairly informal and you look at reports, you look at the drawings, and you satisfy yourself that
00:39:18 you satisfy yourself that that of what the issues are and where the project is at.
00:39:27 Um, can I ask you to look at SEA? All right, before we do that, can I just ask a question on the one that's on the screen at the moment? You can see, Mr. Crawford in paragraph 314
00:39:38 Crawford in paragraph 314 that X overwrite, it's considered that the proposed changes will have no adverse effect. Do you recall what you understood the proposed changes to refer to?
00:39:50 to? I I would understand that is the the general proposition to overclad and with all the options that we've provided to date
00:39:59 date even though as far as we can see there is no reference in this report to overcladding at all.
00:40:07 [Music]
00:40:14 Yes. because um my belief was that uh Bruce has kept them a breast of where the project was. I mean there regular design team meetings.
00:40:25 design team meetings. This is a fairly formal document, isn't it?
00:40:28 it? Um yeah. Yes. Um if Exova had the overcladding in mind, would you not expect them to have a made a reference to it somewhere?
00:40:41 Well, it does mention B well B4 is external fire spread. So that is external
00:40:50 materials or climbing. Thank you.
00:41:05 Can I ask you to go to SEA 000011473
00:41:11 please Mr. Crawford
00:41:16 now uh correct uh me if I'm wrong but I think these are your handwritten notes of a design team meeting of the 3rd 13th I'm sorry of August 2014. Yes.
00:41:29 I'm sorry of August 2014. Yes. At 10:00 a.m. Uh, and you can see who was uh present. SL, that's Simon Lawrence, isn't it? Yes.
00:41:38 Yes. Of Ryden's. And then, uh, there's something else below it. S and looks like PM Ryden's Harley's. Uh, that was probably Simon Corner.
00:41:49 Uh, that was probably Simon Corner. Okay.
00:41:50 Okay. Okay. Uh, and uh, a little bit um, below that after KL and um, something and then stroke NC. No, it's like BS. Stroke NC.
00:42:01 No, it's like BS. Stroke NC. Okay. And BS would be Bruce Zones, I imagine.
00:42:04 imagine. I'm guessing. Yeah. Yeah. And then you see underneath that a line and then it says cassette fix and then underneath that fire strategy not approved.
00:42:12 approved. Um, do you remember what that meant? Fire strategy not approved. Um
00:42:23 um possibly with building control. Uh you say possibly building control. Um well the reason the reason I'm saying that is there was sever several
00:42:34 that is there was sever several iterations of the fire strategy um plans that were commented on by building control and that went backwards and forwards a few times. In fact it went backwards and forwards right to the end
00:42:45 backwards and forwards right to the end of the project. Are you just so we clear are are you saying that the Exova issue three 7th November 2013 of the of the outline fire
00:42:56 November 2013 of the of the outline fire safety strategy had gone to building control and they'd not approved it. I think in the context of what's written there it meant the fire strategy
00:43:07 there it meant the fire strategy drawings as I mentioned earlier comments being made on them that were going backwards and forwards. Yeah. I mean, the fire strategy drawings are pretty much inextricably linked with the document itself and
00:43:19 the document itself and and we'll see perhaps later uh what did go to to building control. Um but can we be clear that it's not the fire strategy set out in the Exover report which we've just looked at from November 13.
00:43:32 just looked at from November 13. Reading that now I don't think right I don't think it is. Could you while we're on it, do you know who had uh not approved the fire strategy?
00:43:41 strategy? Who which individual? Um well Paul Hansen was looking at means of escape with B1 and B5 issues. So his he was commenting
00:43:52 he was commenting generally on the fire strategy drawings in that respect. Okay. And whose responsibility did you think at the time it was to get the fire strategy approved?
00:44:06 postation riding although we were doing it on their behalf or or we doing part of it in their behalf.
00:44:18 Right. Uh was there any discussion that you had with Ryden about how how the fire strategy as referred to there would be approved? Well, they were fully aware of it
00:44:29 Well, they were fully aware of it because they were sitting in all the meetings. You notice Simon Lawrence at the top there. So for example um Simon's very much aware of um let's
00:44:41 um Simon's very much aware of um let's say the issues in relation to smoke vans and so on. Were you told at this design meeting or design team meeting whether the work on the fire strategy had been completed by
00:44:52 the fire strategy had been completed by Exov subject to approval? No.
00:44:56 No. No. Were you told whether Xova was expected to produce an updated or final outline fire safety strategy? Not that recall.
00:45:04 recall. Can I go back to your witness statement at SEA
00:45:08 at SEA 000014275
00:45:10 000014275 at page 61?
00:45:14 Uh, and this is paragraph 188.
00:45:29 And you Mhm. You say there is under the heading X over you say in the second uh well I'll take it from
00:45:40 in the second uh well I'll take it from the top as as above X over the KCTMO's fire engineer continued to provide advice on fire safety and fire engineering issues throughout the project. I did know that Exova was not appointed by Ryden as at 19th of
00:45:52 appointed by Ryden as at 19th of September 2014. It was possible that Exova remained appointed by KCTMO due to the nature of some of the contemporaneous correspondence and Exova's lack of objection to assisting
00:46:04 Exova's lack of objection to assisting which I have summarized below. You see that?
00:46:07 that? Yes.
00:46:08 Yes. So, is it right that you knew that Exova had not been appointed by Ryden? Yes, that referenced that email. Um, Simon Lawrence brought it to my attention that they hadn't appointed them yet.
00:46:19 them yet. Yes. And we'll come we may come to that if we need to shortly. Um, and is it right that you didn't know for sure as of September 2014 whether whether exa had been retained by the TMO?
00:46:32 had been retained by the TMO? I knew that we'd recommended repeatedly that fire consultants used at the start of project and also believe Bruce recommended that they used in the postnovation stage. I didn't know categorically whether they were employed
00:46:44 categorically whether they were employed by KCTMO, although the fact that they responded to all my queries to me suggested they're being employed by somebody. Um, in some sense it was none of my business
00:46:56 in some sense it was none of my business who is paying them so long as they were responding to my questions. Was it not your job to find out who who Exava had been retained by so so that you knew who was responsible for them?
00:47:09 you knew who was responsible for them? I would have only queried that if if they had brought it to my attention. For example, if they weren't being paid or they weren't employed, do you normally expect the consultant to say, "Well, actually, I haven't been appointed for this phase of work, so I need to get
00:47:21 this phase of work, so I need to get back to you." Then that send an alarm bell perhaps that well, well, actually, in the context of of Simon Lawrence's email, you can if you pull that up, you can see that he asked me to go back to
00:47:33 can see that he asked me to go back to him if if if they aren't responding, but they were responding. So I had no reason to believe that they weren't employed by K KTC CMO or another entity.
00:47:45 another entity. So does it come to this that you knew they weren't appointed by Ryden so you assumed they'd been appointed by TMO? Yeah,
00:47:51 Yeah, I see.
00:47:53 I see. Did you think to explore with the TMO or uh what the terms of their appointment were?
00:48:01 were? Um
00:48:02 Um frankly that wouldn't have dawned on me. I mean I'd have expect I mean the reports the port the continuation of their work is the continuation of their work. If I was to make a query and they
00:48:13 work. If I was to make a query and they to suddenly say well actually we're not pointed to um or comment on this aspect of work then then that flag something up to me.
00:48:23 to me. So so I think we can agree at least this that you realize that ex weren't um contracted subcontracted to studio E. It knew that. Yeah. knew that. So
00:48:34 It knew that. Yeah. knew that. So although they were, as you put it, the authority on all things fire related uh in respect of the Granfield Tower project, that would depend on what they were asked to do, wouldn't it?
00:48:45 were asked to do, wouldn't it? Yes.
00:48:46 Yes. And you had no control over that because you studio hadn't appointed them. We hadn't appointed them, but we could ask any question of them that we wanted. Well, you say that it it it's right,
00:48:58 Well, you say that it it it's right, isn't it, that if in fact you had a query about anything specific. Um, they were only as accessible to you, Studio E, is their relationship with the TMO permitted. Correct. Except I never remember being
00:49:12 Correct. Except I never remember being told
00:49:14 told when quering anything that they couldn't respond to. I see. So, Exovover essentially remained available to StudioeE really regardless of what questions you
00:49:25 really regardless of what questions you had for them in relation to the project and in the capacity that um I would have expected
00:49:31 expected and they would help. Is this right? You understood that they were really available to Studioe as a resource that you could use on an as and when basis. Yes.
00:49:40 Yes. I see. Did you ever raise any concerns regarding the nature of Exover's appointment uh during the construction phase either with Mr. SS or with Ryden?
00:49:51 phase either with Mr. SS or with Ryden? I don't see that some something for me to be concerned with
00:50:00 unless I had a an indication that something wasn't right which is heard already. Okay.
00:50:09 Okay. Um, can I ask you to look at your statement, paragraph 197, this is on page 63.
00:50:18 Thank you. Uh, and you say at the start of that paragraph, and I should just point out this is under the heading revision B drawings, on 19th September 2014, Simon Lawrence Ryden emailed me
00:50:29 2014, Simon Lawrence Ryden emailed me and said regarding Exova, I know that they provided information in the tender for KCTMO, but I don't know if they are still working for them, I know that we
00:50:40 still working for them, I know that we haven't employed them. So, if you are getting some free advice, then great. Otherwise, we will need to look at this. And then you say, I replied on the 22nd of September saying, thanks for the
00:50:52 of September saying, thanks for the heads up and again flagged the importance of getting building control to agree the fire approach to which Simon Lawrence said we would chat about after the design team meeting on 23rd of
00:51:04 after the design team meeting on 23rd of September 2014. Now I show you all of that. I have just one or two questions about about that there. Did you do you remember did you impress upon Mr. Lawrence at that time or or at the
00:51:16 Lawrence at that time or or at the design team meeting you referred to 23rd of September that Exova at that stage had not provided any analysis of the compliance of the proposed overcladding scheme with the building
00:51:28 overcladding scheme with the building regulations as they had promised to do or indicated they would do some 10 months earlier.
00:51:37 I I don't recall doing that but but the line in the report does state that the current proposal will have no adverse effects.
00:51:50 Subject to compliance, subject to confirmation uh by way of an analysis in a future issue of the report is what it it's what it says, doesn't it? Yes.
00:52:01 Yes. Yeah. So did my question again. Did you impress upon Mr. Lawrence uh uh that Exover hadn't provided at that stage the promised analysis.
00:52:12 promised analysis. I don't recall. No. Right.
00:52:14 Right. Did you impress upon him that significant further work needed to be done in respect of the fire safety issues as they pertain to the proposed overclatting?
00:52:25 I don't recall. No. as you told the chairman that you understood that even though the scope of the work identified by Exova in the introduction did not include overclouding your understanding
00:52:36 include overclouding your understanding o of their work is that it would do by reference to um the paragraph we looked at and the reference to B4. Yeah. Um, so my question is, did did you
00:52:47 Yeah. Um, so my question is, did did you not tell Ryden, uh, look, we need to push X over to produce the promised analysis on external fire spread?
00:52:58 No, I bet I sent them details later.
00:53:06 Did you ever tell anybody or seek to speak to anybody at the TMO of the um of the heads up that you had received from, as you put
00:53:19 that you had received from, as you put it, from Simon Lawrence?
00:53:26 I'm not sure I had any contact at the TMO,
00:53:30 TMO, direct contact at the TMO. No, no. Uh, in general terms, is that is that true postnovation that you had no contact with the TMO? Um,
00:53:42 Um, with the exception of CLA, um, I'm not aware of any. Right. So, can we take it that you didn't take any steps yourself to tell the TMO that Exova uh had not uh
00:53:55 the TMO that Exova uh had not uh provided a detailed fire strategy uh in respect of the proposed overcladding? No.
00:54:10 Given your understanding that Exova were in your words the authority on all on all things fire related, did you not seek to get to the bottom of
00:54:21 did you not seek to get to the bottom of what Exova's role actually was in respect of well at least in respect of providing the analysis which would confirm their
00:54:32 the analysis which would confirm their view that the proposed changes would not uh affect the risk of external fire spread.
00:54:46 Sorry, can you ask the question? Yeah. Given your understanding that Exova was the authority in respect of all things fire related, why didn't you seek to get to the bottom
00:54:57 why didn't you seek to get to the bottom of what their role actually was given that they'd not produce the promised analysis that they said they would do? Well, I I I saw the consultation with Exova as ongoing. So, for example, as um
00:55:12 Exova as ongoing. So, for example, as um the details of the claring became more apparent, um I said to them, Yeah. And and and did you not at some point at least think it appropriate to
00:55:23 point at least think it appropriate to tell Ryden or advise Ryden in in pretty strong terms that a fire consultant, a specialist fire consultant should be engaged, if not by Ryden, then by
00:55:35 engaged, if not by Ryden, then by Studioe in order to get to the bottom of the external fire spread questions given that Exova hadn't produced any. But I understood um
00:55:48 understood um that were engaged by someone else.
00:55:54 You understood that they were engaged by someone else and therefore it was someone else's problem. Is that is that it?
00:56:01 it? No, no, no, no, no. Um it's only a problem to me so far if they didn't answer for example any queries that we had. If they if if they were to,
00:56:13 that we had. If they if if they were to, for example, turn around and say, "Oh, we can't we can't respond to your question or your queries because we're not appointed to do this work." Then then I would have said, "Well, okay, there's something wrong."
00:56:26 I mean, at this point really, you're you're getting uh as Simon Lawrence has told you, free advice, weren't you, from Exover?
00:56:40 No. He says, "I know that we haven't employed them," meaning Ryden. Yeah. And so if you, Studioe, are getting some free advice, then great. Otherwise, we'll need to look at this.
00:56:51 Otherwise, we'll need to look at this. So, let me put a question to you. Did you think at that stage September 2014, that studioe when it was when it asked Exov for advice on an as and when basis would get
00:57:02 advice on an as and when basis would get it for free? No. If you look at what he said, he actually says, "I don't know if they're still working for KCTMO." My assumption was that they were still working for the KCTMO.
00:57:12 KCTMO. Yeah.
00:57:14 Yeah. So, it's not free advice, right?
00:57:18 right? But it's advice that you weren't paying for, wasn't it? But why would we?
00:57:27 I mean there if you look at the diagrams at the start of my witness statement section 10 there are a number of specialists and consultants that were um contracted direct to or or were client
00:57:41 contracted direct to or or were client side and by that I mean K KTMO side as opposed to riding something. You see the uh advice that you were getting
00:57:53 uh advice that you were getting or could get from Exov would come to you.
00:57:55 you. Yes. But if you didn't actually know who they were employed by, would it follow that you wouldn't know the basis on which you were entitled to ask for that advice?
00:58:06 advice? Well, let me phrase it another way. If I was seeking advice um and
00:58:15 it was never there was never any um let's say
00:58:19 let's say if I asked for advice and it was given then I had every reason to believe that I was getting all the vice that are required. Therefore, why would I question the scope of the advice they're being asked to give? It was satisfying
00:58:30 being asked to give? It was satisfying everything that I was asking for. H how would you know whether TMO had let me try this one again? How would you know
00:58:41 know whether TMO themselves knew that a future analysis uh had been promised by Exover in
00:58:52 uh had been promised by Exover in November 2013 and not as at September 14 yet delivered? Well, all of that was pre my involvement in the project. Well, except that it wasn't, was it? Because in September 2014, the advice
00:59:05 Because in September 2014, the advice hadn't been delivered. My question again, how would you know whether TMO knew that? Well, I'm not mind treasure. I wouldn't. Would you not think to check with Ryden
00:59:18 Would you not think to check with Ryden that TMO had known that fact so that TMO could give the the right instructions to X over
00:59:28 in a certain sense? I didn't consider any of my business who was employing who. I came into the project, I knew I had to get certain advice. I sought that advice. I got that advice,
00:59:41 right? I mean, that that's that's my position. Mr. Chairman, um we're going to move to a different topic and it's 11:00. I wonder whether now maybe um a convenient
00:59:53 wonder whether now maybe um a convenient moment for a break. Would you like a break now, Mr. Crawford?
00:59:55 Crawford? Uh yes, please. Yes. Right. Well, we'll stop now for 10 minutes or so. Um, please don't talk to anyone about your evidence or anything related to it while you're out of the
01:00:06 related to it while you're out of the room. We'll return at 10 11, please. All right. Thank you very much. We like to go with the usher.
01:00:20 Turn past 11, please.
01:11:57 hot room.
01:12:01 Would you ask Mr. Crawford to come back, please?
01:12:19 All right, Mr. Crawford. Yes.
01:12:21 Yes. Yes. U Mr. Crawford, I'm now going to ask you some questions uh about the envelope insulation, if I may. That is the insulation applied within the new cavity that was formed by the rainscreen cladding system. All right.
01:12:33 cladding system. All right. Mhm.
01:12:33 Mhm. Now, I think we can agree that there were two insulating products ultimately used as envelope insulation material on Granfeld tower. RS5000 Celletex um
01:12:44 Granfeld tower. RS5000 Celletex um Kingspan cool therm K15. Yes. Um we weren't aware of the um Kingpan product being used till after. We'll we'll come to that late late later
01:12:56 We'll we'll come to that late late later on but I think we can agree that they were used
01:12:59 were used ultimately. Yes. Yeah. Now, as we've uh already discussed between us, when you came into the refurbishment project, Celotex FR5000 had been specified in the NBS spec as
01:13:11 had been specified in the NBS spec as the thermal insulation to be used in the cladding system. Yes.
01:13:15 Yes. If you nod, it won't go on the track. Oh, sorry. Yes. Yes.
01:13:17 Yes. So, can we just now then go back briefly to approve document B, which is CLG 000000
01:13:25 000000 uh 224, and go to page 96, please. And I just want to remind you of paragraph 12.7 of approved document B. We looked at it last week. Uh it says
01:13:38 We looked at it last week. Uh it says under the heading insulation material stroke products in a in a in in a building with a story 18 meters or more above ground level. Any insulation product filler material not including gaskets, sealants and similar etc. used
01:13:49 gaskets, sealants and similar etc. used in the external wall construction should be of limited combustibility C appendix A. This restriction does not apply to masonry cavity wall construction which complies with diagram 34 in section 9.
01:14:00 complies with diagram 34 in section 9. Uh now it's right isn't it that Cletex FR 5000 is a rigid polyurethane foam board or PIR product.
01:14:11 board or PIR product. Yes.
01:14:12 Yes. Yes. And PIR products are not generally regarded as materials of limited combustibility.
01:14:24 It can be
01:14:28 uh and uh uh if you go to the um uh BCA, you say can be
01:14:37 can be they can be regarded as as materials of limited combustibility. Is that your experience? I I believe they can be. Yes. Right. Let me be clear because I may have mis misled you by my question. I said polyurethane. In fact, P is poly is
01:14:50 said polyurethane. In fact, P is poly is cyanate. So your answer is still the same, isn't it? Or is it? Uh is still the same. Okay. You say they can be. Um what are the circumstances in your experience as at July August 14 in which a poly
01:15:04 at July August 14 in which a poly isocanurate product could be a material of limited combustibility?
01:15:14 Well, it's a plastic foam essentially and it's um impregnated with a fire retardant to um
01:15:26 potentially to make it comp compliant in that manner. So you are you saying that as at the summer of 2014, you had come across PIR
01:15:38 summer of 2014, you had come across PIR foam products for use as insulation that had uh that were of limited combustibility. Was that your experience?
01:15:57 I don't recall precisely. I mean, understand the definitions in table A7, for example. Well, let's just look at those so we're clear. It's page 132 of the same uh same
01:16:10 clear. It's page 132 of the same uh same document on the screen, please. Were you
01:16:17 uh here is table A7, use definitions of materials of limited combustibility. And take a moment, if you would please, Mr. Crawford, just to look at that.
01:16:30 Um just to help you with it because it's a a a document in a number of parts. The left hand column is references in ADB guidance to situations where such materials should be used and there are
01:16:42 materials should be used and there are nine instances of that and then the definitions on the right hand side of for example would apply in the definitions on the left. Yes. And did you know at the time that
01:16:54 Yes. And did you know at the time that in order to be a definition of u as a material of limited combustibility, it either had to be uh classed in the European class under A or B
01:17:06 European class under A or B national class. Yeah. Uh or the or any of the national classes set out in A, B, uh or C or or D.
01:17:15 or or D. And D compares with C because it's about um it's about uh density. Yes. So, were you familiar at the time with table A7? I was aware of the table. I'm reluctant
01:17:28 I was aware of the table. I'm reluctant to use specific words like familiar. It kind of implies that you know everything specifically that's in it. Right.
01:17:36 Do you recall uh when Celletex RS5000 as opposed to FR5000 was specified for the Grenfell project in place of
01:17:48 the Grenfell project in place of Celletex FR5000? Do I recall the period when it was specified? Um yes it was forwarded to me by um I think Ray Harley
01:18:00 by um I think Ray Harley um 17th 18th September there about I think
01:18:07 think 2014
01:18:08 2014 and what makes you recall that specifically because we were having
01:18:14 we're having conversation I think they'd raised their RFI one. Yes.
01:18:19 Yes. In relation to um cavity buyer strategy. Yes. And um as with much many things in architecture, they're all interlin.
01:18:31 architecture, they're all interlin. So
01:18:33 So for example, how you may go about um cavity barrier strategy, you have to consider the whole build up of the wall, let's say. Um and Ry folded that
01:18:46 let's say. Um and Ry folded that information. Um I think in the belief that I can't remember whether I asked for it or not since I'm
01:18:57 since I'm I see. All right. So we well we we'll come back to look at that that chain of email correspondence in detail very soon. Um so you say it was Harley who specified RS5000 in place of FR5000. Do
01:19:09 specified RS5000 in place of FR5000. Do you know the circumstances in which that substitution took place? Meaning the reason for it? Yes. Well, the reasons and and the reasons surrounding it.
01:19:20 reasons surrounding it. No.
01:19:20 No. No. Did was it not your business to know that?
01:19:25 that? Um
01:19:28 Um well, I suppose as um specialist subcontractor proposing a product that on the face of it looked very similar to specified
01:19:41 it looked very similar to specified product.
01:19:43 product. On the face of what? description. I see. All right. Did
01:19:50 Did I mean uh it's worth sorry just interject. It's worth being in mind products are changing all the time. They're changing their names, their brands, their their labeling. Um so for
01:20:01 brands, their their labeling. Um so for example,
01:20:03 example, RS
01:20:05 RS could have been the same as FR for example.
01:20:08 example. Okay. Did you ever or did you at that time have a discussion with Ray Bailey or anybody else at Harley about why FR 5000 was being replaced by RS5000?
01:20:21 FR 5000 was being replaced by RS5000? I don't recall except that that's what they're proposing and yeah um so
01:20:27 so and the nature of design and build gives them that entitlement to some extent. So, do we take it from that answer, and I don't want to put words in your mouth, correct me if this is wrong, but you simply took on trust from Harley that if
01:20:40 simply took on trust from Harley that if they thought RS5000 was compliant, that was fine by you, I guess. Yeah. Yes. Really? Okay. Uh well, let's just go back a question or two then um to uh
01:20:53 go back a question or two then um to uh table A7.
01:20:56 Were you aware or did you have any thoughts at the time about whether Celotex RS5000
01:21:06 RS5000 uh was a material of limited combustibility having regard to the matters in table A7 which you say you were familiar with?
01:21:24 Well, the the information for example on the um
01:21:29 the um the technical sheet that Harley forwarded
01:21:32 forwarded um on RS
01:21:35 um on RS um 5,000 product um makes reference for example to BS476
01:21:44 which cross references with limited combustibility testing. Thank uh I I I note your answer. You say it cross references with limited
01:21:56 cross references with limited combustibility testing.
01:21:59 testing. Where do you see that on table A7? Um for example D. Yes. And that's to be clear 4761.
01:22:10 Yes. And that's to be clear 4761. Yes.
01:22:12 Yes. Yeah. Does state 11 11.
01:22:16 11. Do you know what testing to BS47611 involved?
01:22:23 involved? I understand the basic principles of BS 476 testing, but I wouldn't presume to assume that I knew anything specifically technical as that. Therefore, I would
01:22:35 technical as that. Therefore, I would refer it to fire specialist, which I did. Did you know that there was a difference between testing to BS47611 on the one hand and BS 4766 and 7 on the
01:22:49 on the one hand and BS 4766 and 7 on the other? I'd always refer to um fire specialist interpretation particularly of this kind of information because technically um
01:23:01 technically um the use of the words thermal couples is in my in my opinion in many ways is beyond that of a an architect. Um additionally I'd state I'd point out I
01:23:13 additionally I'd state I'd point out I mean there's over a 100 BS references within part ADB2 alone. And the idea that you'd somehow have complete knowledge of all of them is is absurd in
01:23:24 knowledge of all of them is is absurd in my view.
01:23:25 my view. There's only one BS 476 reference under the national class for materials of limited combustibility though, isn't there?
01:23:34 there? Um,
01:23:36 Um, yes, but what well unless you did BN13501
01:23:41 BN13501 under European class? I was talking about national class. National class. If I'm seeing yes, so one wouldn't have to worry about all the other BS's only that one when one
01:23:53 the other BS's only that one when one was looking to see whether a material was or was not a material of limited combustibility. Do you agree with that? Well, I I would agree that you need to have a sufficient
01:24:05 agree that you need to have a sufficient knowledge of tech technical interpretation to be able to um interpret
01:24:11 interpret the complexities that are implied in that.
01:24:18 Did you know or give consideration at the time to whether RS5000 was the same product or a different product from FR5000?
01:24:27 FR5000? Um
01:24:27 Um I don't recall. Don't recall. It's right, isn't it? I think we can we can agree with each other that Celtex RS5000 was also a PIR product.
01:24:38 RS5000 was also a PIR product. Poly sayurate. Yes. Yes.
01:24:41 Yes. Yes.
01:24:42 Yes. Yeah.
01:24:44 Yeah. Do do you happen to know what FR in FR 5000 stands for? No.
01:24:51 No. Would it be surprising if I said flat roof?
01:24:57 Um, it would be. Yes. Right.
01:25:10 Now,
01:25:14 did you know that RS5000, like FR5000, did not meet the requirements for limited combustibility as set out in approved document B, table
01:25:27 as set out in approved document B, table A7 that we've got on the screen. I didn't know that categorically. No, you didn't know it categorically. Did you know it a bit? No. As I as I think I've stated and in
01:25:39 No. As I as I think I've stated and in my witness statement, um I referred to the fire specialist to check its compliance. So just to be clear, would it follow from your answer
01:25:50 clear, would it follow from your answer that you didn't know that FR5000 should not have been used as an insulation product on Grenfell tower
01:26:01 insulation product on Grenfell tower unless
01:26:02 unless either it was tested under a large scale test under BS8414 to the B135 criteria or there was a desktop report or a
01:26:14 or there was a desktop report or a holistic fire engineered approach had being taken. My understanding of the FR product was that it had been proposed by um Max
01:26:25 that it had been proposed by um Max Forom originally and from the conversations I had with Bruce, his understanding of it was that it was compliant and then when I received the information from Exover, I sought to um
01:26:39 information from Exover, I sought to um confirm to myself that it from from Harley, I sought to confirm to myself that it was compliant by checking it with the um what I consider to be the higher fire authority which was um exova
01:26:52 higher fire authority which was um exova right well we'll come back to that in in due course
01:26:58 uh if we could look at your witness statement please at page 62 that's sea 000014275
01:27:05 000014275 at page 62 and you look at paragraph 192 uh you refer to an email uh uh and this is in the middle of an
01:27:17 uh uh and this is in the middle of an email string and you say in response to the comment, Daniel Ankle Jones, design manager at Harley stated, "The insulation is class N. Therefore, after reading the correspondence below, I I
01:27:29 reading the correspondence below, I I believe the fire barrier in these locations will not be necessary. Can you confirm this is acceptable?" And then you say this again, I forwarded the comment to Exover together with the data sheet for Celtex RS5000 dated August
01:27:43 sheet for Celtex RS5000 dated August 2014 that Daniel had attached to his email.
01:27:47 email. Now if we can look at that it's sea 000011724
01:27:53 000011724 as you've referred to it there paragraph 192
01:27:58 192 and let's look at the second email in the chain. This is the email from Daniel Anker Jones to you Mr. Crawford on the 18th of September 2014 at603 or 403 copied to uh
01:28:13 September 2014 at603 or 403 copied to uh various people including Simon Lawrence at Ryden. Neil, thank you for your response. He says the insulation is class n etc. as you've quoted in your uh
01:28:24 class n etc. as you've quoted in your uh in your statement. Uh now uh there's there's no uh reference in that email to the data sheet, is there?
01:28:36 email to the data sheet, is there? Uh, not that casino. No. Well, we'll come back to that precise issue shortly. Can I look Can we look at the data sheet itself, which you didn't refer to, but which
01:28:47 which you didn't refer to, but which your statement says you forwarded? It's CEL
01:28:51 CEL 000000411,
01:28:55 please.
01:29:04 Um, is this the document that you were referring to in your statement? Yes.
01:29:09 Yes. Did you read it at the time of the email correspondence? Did you read it all?
01:29:19 I read enough to be convinced that I thought it was appropriate to use. Right now, if you look at um the first page, which is the page in front of us,
01:29:31 which is the page in front of us, uh and we'll come back to the email chain later. Let's just look at the documents. It says a third paragraph down with Celletex RS5000, you are specifying an insulation board.
01:29:44 you are specifying an insulation board. And then in the uh second bullet point it says is the first PIR insulation board to successfully test to BS8414 meet the criteria set out in BR135 and
01:29:56 meet the criteria set out in BR135 and is therefore acceptable for use in buildings above 18 m in height and then it says has class N fire performance throughout the entire product in accordance with BS476.
01:30:10 product in accordance with BS476. Now we know that Mr. Ankle Jones had said in his email that it was class not. My question is what did class not mean to you at the time?
01:30:25 Um understood class not in relation to diagram 40 and where it should be applied in relation to diagram 40. I think they've um linked class not um to
01:30:38 think they've um linked class not um to BS 476. You can see that in the third dot down.
01:30:44 dot down. Um
01:30:45 Um and obviously I mean the the way this information is presented repeated use of it um applicable for use for buildings over 18
01:30:57 applicable for use for buildings over 18 meters. I mean everything in this document to me suggests that the product is appropriate in rainfree use. That's it opening line in buildings for more than 18 meters in height.
01:31:10 more than 18 meters in height. Um, I had no reason to suspect that it wasn't based on the information that I read and I folded it to Exova for confirmation.
01:31:23 So to answer my question, you say that you understood class N in relation to diagram 40 and that should be it should be applied in relation to diagram 40 but it also cross references BS476 there
01:31:37 but it also cross references BS476 there which is also referenced in limited combustibility testing. I see.
01:31:44 I see. Um it doesn't say which 476 though does it? Well, as I said, um I don't consider myself
01:31:52 myself um a specialist in that level of testing. I mean, if it says BS476, then that's what I understood by it. You refer to diagram 40. Did it did this
01:32:05 You refer to diagram 40. Did it did this thought go through your mind at the time? What had diagram 40 got to do with the use of insulation? Well, it talks about class, zero, surfaces. Yeah,
01:32:17 surfaces. Yeah, we mentioned before the internal surfaces,
01:32:20 surfaces, right?
01:32:22 right? What would class N in in the context of an insulation product to be used within a rain screen uh mean?
01:32:32 uh mean? Well, it's surface flame sprite classification. Yes. And how would that be relevant to an insulation product that you knew was
01:32:43 an insulation product that you knew was being applied within the rain screen and not as part of not as the external surface?
01:32:47 surface? They used deliberately well in my view talk about class O through the whole product which I think is misleading. Can
01:32:58 product which I think is misleading. Can actually see that here but it was in the first line. It does say it. Where does it say it? Third bullet point down has class not fire.
01:33:05 fire. Oh yes through the entire product. Yes. Sorry. Yeah. What does that mean to you? It suggests to me that
01:33:16 this
01:33:19 and reduced flame spread throughout the product.
01:33:25 Is that right? I mean you to be blunt about it we've obviously seen the recent emails in terms of the internal correspondence within cellot text and clearly they
01:33:38 within cellot text and clearly they sought to deceive um and they calculatedly sought to deceive based on that the understanding that an average architect would have with the way they've worded this document and to me
01:33:51 they've worded this document and to me that's that's answer that's apparent by that reference to BS47 76 and the way it cross references with limited combustibility is deliberately misleading is
01:34:07 is masquerading um horsemeat as a beef lasagna and people bought it. Well, m Mr. Crawford, I'm interested in your recollections as they happened at
01:34:19 your recollections as they happened at the time and not in what you now say about the behavior of other people. Okay. So, what I want to know is what
01:34:30 Okay. So, what I want to know is what you thought on reading this document at the time. Do you understand? Yeah. What I want to know is when you read as you say you did this data sheet,
01:34:41 read as you say you did this data sheet, what I want to know is what you took from the third bullet point down has class N fire performance throughout the entire product in accordance with BS476. Do you understand my question at the
01:34:52 Do you understand my question at the time? What did that mean to you? All I can say is the totality of what was written there and made me understand that this product was
01:35:04 made me understand that this product was compliant in that use. And for me to verify that knowing the technicalities that are involved
01:35:14 in limited combustibility testing was to confirm that with Exova which I did. This data sheet is not is it presenting
01:35:25 This data sheet is not is it presenting this product as a product of limited combustibility in accordance with uh section 12 is presenting it is a um product
01:35:36 is presenting it is a um product suitable for buildings raincreen in buildings above 18 m.
01:35:44 Certainly that is what it says at the very top. No, it says it repeatedly. All right, but can you identify? Well, take it from me because it's not in there. That nowhere in this document
01:35:56 there. That nowhere in this document does it say that that RS5000 is a product of limited combustibility. You're telling me that, so I'm taking your word on that. And nowhere in this document does it say
01:36:08 And nowhere in this document does it say that it is a product of limited combustibility in accordance with section 12.7 and table A7 of the of approved document B. If you're telling me that. Yes. Well, did did you do you recall ever
01:36:19 Well, did did you do you recall ever reading it in there? Well, I've told you how I read it. I told you I understood the document and how I checked the document. So, just so I've got your evidence clear
01:36:31 So, just so I've got your evidence clear on this
01:36:33 on this is it it's the class N fire performance throughout the entire product which to you meant that it was safe to use on buildings above 80 m as an insulation
01:36:44 buildings above 80 m as an insulation product. It was the it's the entire presentation material. I then sought to um to to to check that interpretation with Exova
01:36:56 check that interpretation with Exova which I did in which I understood from what what were fairly emphatic confirmation from Exova that it was applicable and then and that it
01:37:08 was applicable and then and that it could be used. Their understanding of how how it was and how it could be used may have been different from mine. They may may have had
01:37:19 may may have had they work in hundreds of buildings. They may have had knowledge of BR135 testing for example that led them to believe that it was applicable in this particular buildup.
01:37:32 applicable in this particular buildup. But you don't know that, do you? No. But what I know is from the conversations I had with Exova that they were emphatic, fairly emphatic about the fact that it was appropriate to use and
01:37:44 fact that it was appropriate to use and that's that's what they suggest to me. I mean that's my understanding from the conversations I had with them. I asked them to put it in writing. They put it in writing the context with the cavity
01:37:55 in writing the context with the cavity barriers on reflection is a tacit approval in writing but from the conversations I had with them I understood that it was appropriate to use. Right now looking at the data sheet
01:38:07 use. Right now looking at the data sheet page one just above the bullet points it says with Celotex RS5000 you are specifying an insulation board that and then the second bullet point says is the first PI insulation board to
01:38:18 first PI insulation board to successfully test to BS8414 meet the criteria set out in BR135 and therefore is acceptable for use in buildings above 18 meters in height.
01:38:30 buildings above 18 meters in height. Now, do you remember seeing that? Yes.
01:38:35 Yes. Um, did it not occur to you at the time when you saw that that the reason why this material was acceptable for use in buildings above 18 m in height was because it had, as it said, passed a
01:38:49 because it had, as it said, passed a BS8414 test and met the BR135 criteria? Well, I think I've explained this several times now that there's multiple ways in which
01:39:00 ways in which the product can be compliant through various tests. The BS 476, the BS um EN13501,
01:39:12 um EN13501, the BS 8414. I understand there's different routes to which effectively prove that compliance. I don't think an architect has the
01:39:23 I don't think an architect has the technical
01:39:25 technical ability to analyze all that and it's a highly specialist and technical set of information also doesn't help when it's misrepresented. So my first protocol was to send it to
01:39:37 So my first protocol was to send it to what I considered a higher fire authority i.e. the fire specialist and ask them to evaluate it. You say it's misrepresented. Can we just be clear? What do you say was
01:39:49 be clear? What do you say was misrepresented?
01:39:53 To me, the suggestion is that that this product is appropriate for use in buildings over 18 mters. And
01:40:03 And everything about it suggests to me that it's that it can be used potentially under BR135 or as limited
01:40:14 under BR135 or as limited combustibility. You say or is limited combustibility. You you you does that tell us that you knew there was a difference?
01:40:28 I think the class O performance throughout the entire product when it worded in those terms it's ambiguous and when it relates it to BS476 in those
01:40:39 when it relates it to BS476 in those terms it's ambiguous. Well, let's read on then. Um, if you go to page two of this document, uh, in the middle of the page, it says physical properties,
01:40:51 uh, and underneath that it says, uh, fire propagation. This is the last but one. BS476 par 6 pass surface spread of flame BS476 part 7 class one. Do you
01:41:04 flame BS476 part 7 class one. Do you remember looking at that detail when you saw this data sheet in September 2014? I don't. specifically.
01:41:15 Had you done, you would have noticed, no doubt, that it did not say that it had passed a test under BS 47611, which you told us earlier was the uh test for limited combustibility under table A7.
01:41:28 limited combustibility under table A7. Yeah, I think I'd go back to my original point, which is that I'd always forward this to fire to fire specialists. I have authority to to get their understanding in the context of the whole buildup.
01:41:42 And then if we go to page three at the very top certification our Celtex RS5000 is a premium performance solution and is the first PI board to successfully meet the
01:41:53 board to successfully meet the performance criteria set out in BR135 for rainscreen cladding systems and then it sets out what the test was. Did you read that at the time do you think? I don't recall.
01:42:06 I don't recall. Did you notice what the system tested was?
01:42:09 was? I don't recall. Did you notice the wording at the bottom? The fire performance and classification report issued only relates to the components detailed above. Any changes to the components
01:42:20 above. Any changes to the components listed will need to be considered by the building designer. Did you read that at the time?
01:42:24 the time? I don't recall reading that. Did you understand from this document that the only basis for Celex's claim that RS5000 was suitable for use on buildings over
01:42:35 was suitable for use on buildings over 18 meters in height was that uh it had as Celtex said satisfied the BR135 criteria by way of a fullscale BS8414 test.
01:42:47 test. No, I don't think I understood I don't think I understood the product as being um
01:42:54 um as compliant only under um necessarily compliant only under BR135 test. I understood that it could be compliant and um in order to check that
01:43:07 and um in order to check that compliance, I forwarded it to the um fire consultant.
01:43:16 So do we take it from that that the actual basis of Celotex RS5000 as suitable for use above 18 m as set out there uh namely in accordance
01:43:29 as set out there uh namely in accordance with the test identified was not something that you thought needed to be considered by the building designer because you didn't check it yourself.
01:43:40 Like I said before, I think the interpretation specifically of parts of um proof document B are extremely difficult and I would
01:43:51 are extremely difficult and I would forward them to a fire specialist or at least seek fire specialist advice, which I did.
01:43:59 I did. Uh just just taking it in stages to see how far we get. Do you accept that the configuration and the materials that were were used in the BSA4144 test as set out in this data sheet as we
01:44:10 test as set out in this data sheet as we can see on page three was not the same as that proposed and in fact used at Grenfell Tower. Was it?
01:44:23 No, it doesn't necessarily mean they would behave the same way, but no, they're not the same. a and and and therefore uh it was a change to the components which would need to be considered by the building designer. Did
01:44:35 considered by the building designer. Did that occur to you at the time that because the system was different? If if you're assuming a B135 test in relation to that um and again as what
01:44:48 in relation to that um and again as what pointed out we exova have um our authority and fire and have massive number of um desktop studies and um
01:45:00 number of um desktop studies and um tests which they can call upon and I suspect that's what they used to inform fact that they believed it was compliant. When you read this document, did you
01:45:12 When you read this document, did you think to yourself, uh, it it is compliant and I can use it above 18 meters in height, or did you think to yourself, I'm not sure. I better ask over.
01:45:22 over. I wouldn't assume anything in part B in many ways. Um, I think from what I saw in the literature on the front of the
01:45:34 in the literature on the front of the product, I I did pretty much assume that it was appropriate for use, but I sort check that with the fire specialist.
01:45:45 check that with the fire specialist. And the basis of your what you call pretty much assume your assumption just so that I'm clear is what the reference to class N. Is that it? It's as set out in my witness statement.
01:45:57 It's as set out in my witness statement. It's all those statements combined. I see.
01:46:05 Can I ask you to be shown a document which you may not have seen and if you haven't we'll we'll think again. Look at CL 612,
01:46:17 CL 612, please.
01:46:28 Now, this is something called a rainscreen cladding compliance guide when specifying Celotex RS5000 in buildings above 18 mters. And it's dated, although I don't think you can see it on the screen, it's dated August
01:46:41 see it on the screen, it's dated August 2014. Um at your at the time of your coming into the project or indeed at any time did you see this document? No.
01:46:49 No. Right.
01:46:55 Now in September 2014 on the 2nd of September you I think attended a design team meeting design team meeting number two. You remember that?
01:47:06 two. You remember that? Yes.
01:47:06 Yes. Okay. I'll show you a document. If you can go please to SEA00000011581.
01:47:16 These are the minutes of the meeting. Uh and uh you can see uh that uh it was held on site at 10:00 a.m. on that day, 2nd of September, 2014. Mr. Lawrence was
01:47:29 2nd of September, 2014. Mr. Lawrence was there, Mr. Okconor was there from Ryden, and you were there as as the project architect studio E. You see that? Yes. Uh and Mr. Ankatil Jones and Kevin Lamb were there from Harley as well.
01:47:40 Lamb were there from Harley as well. Um now can I ask you please to go to item u 3.62 on page four.
01:47:53 Um it's under the under the heading uh against 3.60 cladding brackets insulation fixings panels etc. And 3.62 62 uh discusses U
01:48:05 panels etc. And 3.62 62 uh discusses U values. You see that? Yes.
01:48:08 Yes. Uh and it says U values were discussed with SL
01:48:11 with SL asking how the figures in the spec were arrived at and whether they needed to be rechecked from an M and insulation point of view. Is the insulation thickness show on architect drawings correct? Shown on architect drawings correct. DAJ
01:48:23 Shown on architect drawings correct. DAJ confirmed that he had checked them, but with the assumption that that RML were fitting further insulation internally. SL didn't believe this was part of the spec. All parties agreed to check their documents. See that?
01:48:34 documents. See that? Yes.
01:48:35 Yes. And then
01:48:36 And then uh there's a PMN which I think is a post meeting note uh which says Max Forom tender u value document was shared to team via email. External wall construction was checked against all
01:48:48 construction was checked against all tender information and all information shared.
01:48:52 shared. Um,
01:48:54 Um, do you know or do you remember what figures in the spec exactly were checked?
01:49:01 checked? No.
01:49:02 No. Do you know why Mr. Lawrence wanted to recheck the EU values? I don't recall. Do you know what had changed perhaps that had made him do that?
01:49:13 that had made him do that? Don't recall. Did you review the studio e tender information in respect of the insulation at the time?
01:49:29 I can't recall I can't recall whether this went back to Max forum as a discussion or not just without seeing the associated correspondence. Did you do you remember have any
01:49:40 Did you do you remember have any discussion with Mr. S about how the U value was decided upon? Um, I knew I knew it'd been um it'd been derived uh from the original um in the original
01:49:52 from the original um in the original match forum report. It been derived from that. Did you have a discussion about it? Um I knew there a value target
01:50:03 Um I knew there a value target and you know a proposal to achieve that U value target. Um I I don't recall any specific detail if that's what you're asking. Do you remember whether you checked the U values with Mr. McQuat or
01:50:15 checked the U values with Mr. McQuat or anybody else at Max Forom? I I can't recall this particular instant to be honest. Do you did you look back through the
01:50:26 Do you did you look back through the records you had like emails to understand how the target you value had been decided? I may have done. I just
01:50:37 Do you remember any discussion historically in the project before you came on the scene of the use of mineral wool as an insulation product? No.
01:50:47 No. So you can't help us as to why it was that mineral wool had been discounted for use as insulation. Um I I understood that um the techies were impractical
01:50:59 were impractical um to achieve that you value be the bracketry would who did you understand that from um I think Bruce I see now can I take you um
01:51:14 I see now can I take you um on a little to sea 000000
01:51:19 000000 five 9561 this is an mail the 1st of November 2013. I'll give it again. It's sea 409561
01:51:32 and it's an email from Tom Ashton at Curtins to Artilia and to Bruce Zones. Uh, and I don't think it came to you, but it says um, "Dear all, please find
01:51:45 but it says um, "Dear all, please find our structural specifications attached." And I suspect one of the reasons it didn't come to you is that you weren't involved in the Grenfield project at that time. Now I'm assuming, Mr.
01:51:56 that time. Now I'm assuming, Mr. Crawford, unless you told me otherwise, that you didn't see this email at the time.
01:52:00 time. No, this a year and a half before ex Exactly. But let's look and see what the structural specifications were. Um, it's one of the attachments to the email and it's a TMO
01:52:13 12249.
01:52:17 And in the email, it's the one that's entitled L1212 spec 001. It's the last attachment referred to.
01:52:30 And there it is. It's uh Curtain's spec of the 1st of March 2013 for the um design, supply, and application of overcladding systems to Grenfell Tower.
01:52:58 Um, if you look at this, um, do you remember ever reading this document once you've taken over from Bruce Zones? I don't recall seeing this document. You don't recall? You don't recall ever
01:53:09 You don't recall? You don't recall ever seeing it? Is that right? I don't recall seeing it. No. Okay.
01:53:18 Did you know uh and I'll ask the question in a general way that um this specification had at least recommended
01:53:29 specification had at least recommended that the cladding system should comply fully with the recommendations of um BR uh the the BR document fire performance of external thermal insulation for walls
01:53:41 of external thermal insulation for walls of multi-story buildings dated 2003. I don't recall seeing the documents. So I wouldn't recall. You wouldn't know. Did you ever have a discussion with Mr. S about whether the system as specified in the MBS
01:53:52 system as specified in the MBS specification was compliant with BR 135?
01:53:59 135? Specifically with 135? No. Yes.
01:54:04 No. Uh
01:54:07 Uh would you agree with me and this may be a hypothesis because you didn't read the document. So putting it in that context, Mr. Crawford, that if under this structural specification
01:54:18 structural specification uh that Harley were working to, if they were required to work to it, if that's the case and the cladding system was to was to comply fully with the recommendations of BR135 of 2003, then
01:54:31 recommendations of BR135 of 2003, then the recommendations were part of the performance criteria for the system.
01:54:38 This I can't answer as a hypothetical question. Okay, you won't answer. All right, can't answer. Um, just generally then before I leave that,
01:54:50 just generally then before I leave that, did you take any steps yourself to ensure at any time that Harley's drawings were compliant with the recommendations under BRE 135 2003 or
01:55:01 recommendations under BRE 135 2003 or indeed 2013 which was the third edition? Not that recall. Okay. Um, I'm now going to turn to a different topic. Um, Mr. Chairman, we're a bit early for the next break,
01:55:13 a bit early for the next break, but the the next topic is quite long, so I'm entirely in your hands. I'm very happy to start it. When you say quite long, what you talking?
01:55:21 talking? Uh, it'll it's likely to take us up to the lunch break and possibly. Well, perhaps you'd rather have a break while you've got the chance, Mr. Crawford.
01:55:29 Crawford. Yes,
01:55:29 Yes, I think that would be sensible. All right, we'll rise for 10 minutes. So, if you go to the usher, please, we'll come back at 5 12. Thank you. Right.
01:55:44 5 12 please.
02:06:37 Yes. Would you like to ask Mr. Crawford to come back, please?
02:06:54 Right, Mr. Crawford. Yes.
02:06:55 Yes. Good. Thank you, Mr. Millet. Yes, m Mr. Chairman. Mr. Crawford, I'm going to ask you some questions now about the exchange of emails on the 17th and 18th of September, 2014 following
02:07:06 and 18th of September, 2014 following the request for information from Harley to Ryen. If we can start please with SEA000017,
02:07:15 sorry, 11730 and go to page four.
02:07:22 And there you have an email uh from Daniel Ankerl Jones to Simon Lawrence uh and Simon O' Conor of Ryden copied to you and Mr. S. Well actually
02:07:35 copied to you and Mr. S. Well actually to both of you and copied to Kevin Lamb and the subject is Granfell Tower cavity fire barriers. Simon please find attached RFI 01
02:07:46 01 which relates to the requirement of fire brakes. This may be something that has already been decided or may need confirmation from the local fire officer as the opinion tends to vary. You see that?
02:07:55 that? Yes.
02:07:57 Yes. Uh and then the request itself is at which is attached is at H0000003616
02:08:05 please.
02:08:09 And uh you can see it there request for information form the date on the right hand side 17th September 2014. It's from Daniel Ankerl Jones of Harley to Simon Lawrence at Rydens. Date answer required
02:08:21 Lawrence at Rydens. Date answer required 26th of September 2014. Query, please may you confirm the required extent of the horizontal fire brakes within the cladding areas. And then the suggested solution, we believe that they will be
02:08:33 solution, we believe that they will be required at every floor level on the vertical columns but not in the area of cladding between windows. This is because there is no chimney effect here and therefore the cladding will not add to the spread of fire.
02:08:44 to the spread of fire. Now um first why because we've seen that you received this document. My question is why did you think at the time that Harley was sending you this request as
02:08:58 Harley was sending you this request as well as Ryden given your postnovation role as you saw it?
02:09:08 Um,
02:09:15 well, if you look at the the original email, if you bring that back up on the screen,
02:09:20 screen, uh, yes, it's SEA00001730,
02:09:25 [Music] page 4. where they mention may need confirmation from the local fire officer as the opinions as as the opinion tends to vary
02:09:37 to vary meaning um building control. So I saw this as assisting in the um coordinating building control.
02:09:52 Why did that occur to you as something for Studio E as opposed to Ryden alone?
02:10:01 Well, we we obviously had a um cavity barrier strategy at stage E within the employers requirements and what you suggesting is contradictory to that.
02:10:13 suggesting is contradictory to that. Well,
02:10:16 Well, so the question then is was and I want your your recollection of how you saw this at the time, Mr. Crawford. Was the RFI
02:10:26 RFI that was the question a question which fell within the scope of what you saw as commenting on design intent?
02:10:47 or other manifests issues. Yes. Uh or rather manifests issues. I don't I I don't I'm not sure I'm understanding that qualification.
02:10:59 that qualification. Um
02:11:03 okay. The way I saw this is we had a fire strategy, a cavity buyer strategy at stage E in employer requirements. They were proposing a different strategy. So it was perfectly logical
02:11:14 strategy. So it was perfectly logical for them to quantify that against our strategy particularly when it related to um
02:11:22 um um coordination of building control submission for which is part of our responsibility which is what's inferred by confirmation from local fire officer.
02:11:33 by confirmation from local fire officer. So ju just to be clear about this this question am I right in saying ex it fell outside the scope of what you saw as commentary on design intent.
02:11:46 commentary on design intent. I know where you're coming from and well never mind about where I'm coming from. Did you did you or did you not see it as falling within the scope? Well, it's not architectural intent. Um is it architectural intent?
02:12:00 is it architectural intent? Borderline. borderline
02:12:05 and and given in fact they've well look I think I've said it already they came to us for specific information in an RFI in relation to the clarification against our original
02:12:18 clarification against our original scheme
02:12:20 scheme unreasonable not to answer it at least attempt to answer it well Harley were already on board at this point weren't they? Yes.
02:12:31 this point weren't they? Yes. As the specialist subcontracting designer for the cladding. Yes.
02:12:36 Yes. So why didn't you go back as a recipient of this email to uh Daniel Ankerl Jones and say this is a matter for you uh and to work out with Ryden and not a matter
02:12:48 to work out with Ryden and not a matter for us because it does not fall within the scope of architectural intent or design intent. Yeah. But is an issue of coordinating building control and ultimately seeking to get building control sign off.
02:13:01 to get building control sign off. So, and well, yeah, that's that's what I would say, I guess.
02:13:08 guess. Okay. Well, we see uh your uh response uh or rather your next move, which is if you go up up the page,
02:13:19 you go up up the page, page four, we can see that under cover of an email on the 18th of September
02:13:28 at 11:08. Uh I'm so sorry, we've gone too far. That's it. you uh send the email that you've received on to Terry Ashton at
02:13:39 you've received on to Terry Ashton at Exover with the RFI. Yes. Yes.
02:13:43 Yes. And you copy in Simon Lawrence and Simon O' Connor. And you say, "I'm working on the Granville Tower regeneration project from the Studio E. The following RFI has
02:13:54 from the Studio E. The following RFI has come in relating to horizontal fire brakes within the cladding areas. Can you comment on the RFI attached and whether you believe this interpretation in relation to stack effect is correct?
02:14:05 in relation to stack effect is correct? Now that that's that just the first point is that's not is it the coordination of answers with building control. You're essentially passing him on the question you've been asked by uh
02:14:17 on the question you've been asked by uh Daniel Ankerl Jones.
02:14:21 Yes. But ultimately his original question related to um I mean he raised the point that different building controls have different in or he didn't
02:14:33 controls have different in or he didn't use the word building control I can't remember what he used but that's what he was referring to building control have fire officers have different interpretations of the requirements of cavity barriers.
02:14:44 cavity barriers. Therefore, it was related to building control ultimately.
02:14:53 Um, you then move up the page, if we can, please, to page three of that email chain. I'm sorry to do this in reverse order, but that's how these things are. And Mr. Ashton replies at 11:33 that
02:15:05 And Mr. Ashton replies at 11:33 that morning, 18th September, 2014, and he says, "Neil, I've never seen details of what you're doing to the external walls. Do you have any cross-sections or elevations?
02:15:17 elevations? Now, let's just take this slowly. At this stage, Mr. Crawford, you had read issue three of Exov's um outline fire safety strategy as you've told us before.
02:15:27 before. Yes.
02:15:29 Yes. And you had read in that document in relation to B4 that there were no adverse effects, but the that that would be confirmed in a future analysis. Yes.
02:15:40 Yes. Mr. Ashton's response that he had never seen details of what Studio E had designed in respect. No, that's not what he said. He says I've not seen details. Doesn't mean he hadn't he didn't know what was happening
02:15:51 hadn't he didn't know what was happening in the external walls. You cut across my my question. Sorry.
02:15:57 Sorry. Let me try it again. Mr. Ashton responds and he says that I've never seen details of what you're doing to the external walls. Did that come as something of a
02:16:08 walls. Did that come as something of a surprise to you at the time?
02:16:15 Well, my understanding from discussions with Bruce is that Exov were fully aware of how the scheme had developed, including the external wall buildup.
02:16:27 including the external wall buildup. Well, let's just go back a little bit to the evidence that you told you gave us this morning, Mr. Crawford about uh that paragraph which deals with requirement B4 in the building regulations within
02:16:39 B4 in the building regulations within the Exover fire safety strategy. Uh and you told us that you thought that Mr. S had believed uh that they'd been told by he'd been told by Exov that the strategy
02:16:51 he'd been told by Exov that the strategy was compliant that the design was compliant. Now when Mr. Ashton tells you in September 2014 that he has never seen details of what you're doing to the external walls. Did
02:17:02 you're doing to the external walls. Did you not stop and think and ask yourself how it could be that Mr. S had previously thought if that is correct uh that he had been told by Exova
02:17:13 that he had been told by Exova uh uh that uh the external wall construction was compliant? No, because he says I've never seen details. Um Harley were doing the details. They were doing
02:17:25 were doing the details. They were doing the one to five details. We done one to five details in for example the employers requirement set. So they understood the concept. They understood it in broad brush stroke let's say um
02:17:38 it in broad brush stroke let's say um sense of what was being um installed. But what he's saying is I've never seen details. I understand details mean specific details as in the specialist subcontractor's details.
02:17:52 subcontractor's details. Yes. So, did Mr. Ashton's response not undermine entirely what you had read in the outline fire safety strategy from uh from 2013? No, because that's an outline fire
02:18:04 No, because that's an outline fire strategy. It's not a detail strategy.
02:18:07 strategy. Did it not undermine the belief that you had that Mr. S had been told by Exov uh that the designs at that stage were compliant?
02:18:18 compliant? No.
02:18:21 No.
02:18:24 Did it give you cause to consider that Exova had not in fact at that stage considered at all the impact of the overcladding scheme
02:18:36 overcladding scheme and its compliance with requirement B4?
02:18:42 Sorry. Sorry. Can you rephrase that or repeat that? Yes. Did Mr. Ashton's response to your question not give you cause to consider that Exova had not in fact
02:18:54 consider that Exova had not in fact considered at all the impact of the overcladding scheme and its compliance with requirement B4 of the building regulations
02:19:04 I don't think it necessarily did no well if if Mr. Ashton had not seen the details of what you were doing to the external walls. How could he he possibly
02:19:15 external walls. How could he he possibly give any reliable advice about whether the overcladding scheme did or didn't comply with requirement B4 of the building regulations? But just to explain that um he was taken
02:19:27 But just to explain that um he was taken through the scheme as the scheme developed um my understanding was the scheme was developed up to tender stage. He had he did understand the concept of what was going to the wall. What he's
02:19:39 what was going to the wall. What he's saying here is I've never seen details. The key word is details. Did you take up Mr. Ashton's response with Mr. S?
02:19:54 I don't recall possibly.
02:19:59 Would would you not have expected studio E on yourself as project architect? And I know you don't like the the term, but as lead consultant and as lead designer to have sent the details
02:20:10 to have sent the details that we see there referred to by Mr. Ashton to X over at an earlier stage so that they could advise on whether the various elements of the cladding design
02:20:21 various elements of the cladding design and the system did comply with approved document B. Well, I I think I've already explained to you what my understanding was and the information that was, for
02:20:33 and the information that was, for example, worked up to and in the stage report
02:20:38 report um wouldn't have included and didn't include that level of detail. It didn't include one to five details, for example.
02:20:47 example. Did you did you did it not occur to you at the time to go back to Mr. and and ask him a question such as, "Well, hold on a moment. I need to understand what details you have seen and what details
02:20:58 details you have seen and what details you haven't seen in relation to the external walls." Well, with that occur to you, with all due respect, I don't know exactly what he had and hadn't seen or had and hadn't discussed with Bruce, but my understanding was
02:21:10 with Bruce, but my understanding was that Exova, whether Terry individually or as a totality, had an understanding of where the project was at that point in time. Now when he's made this
02:21:21 in time. Now when he's made this comment, I then send him the details
02:21:28 which had quite recently just become available from Harley.
02:21:37 Well, all right. Let's look on let's look at that. Um, if you go on to page three up the page, you can see your answer.
02:21:49 answer. Neil Crawford to Terry Ashton, 18th September, 1218. Hi, Terry. Do you see that? Please see attached are sections and the initial drawing set we've had from Harley's. The initial drawings from
02:22:00 from Harley's. The initial drawings from Harley's are fairly limited, but they attempt to establish the basic approach. Regards, Neil. Now, let's just look at uh the drawings that you sent to Mr. Ashton. Um I think
02:22:12 that you sent to Mr. Ashton. Um I think you attached the Harley initial drawing set, don't you? Yes.
02:22:17 Yes. Yeah. I mean, refer to it in your statement, but let's look at it. It's sea 000011714, please.
02:22:31 Now, we can scroll through these quickly just to or not quickly, but gradually perhaps just to identify what it is you sent. Uh, and I'll just let
02:22:44 it is you sent. Uh, and I'll just let you do that. If Mr. Operator, you could please just scroll down through the the drawing so that the witness can see what it is he sent.
02:22:54 So, that's page three. window head upper levels. On page four, we've got a window jam. That's upside down, but probably doesn't matter. Uh, and then page five,
02:23:09 Uh, and then page five, the vents. And page uh page six, we've got um jam joint upper levels and column front. Page seven is jam joint upper levels.
02:23:22 Page seven is jam joint upper levels. Page eight is column joint. Page nine is window sill lower levels. Page 10 is window head lower levels.
02:23:33 Page 10 is window head lower levels. And page 11 is jam joint lower levels. Just just to remind you of what it is you sent.
02:23:39 you sent. And those were uh window and summarizing them. Window head sill and jam sections plus typical bay west elevation. Now, we could look at any one of these
02:23:51 Now, we could look at any one of these if you'd like to, but am I right in thinking that no materials are identified either in terms of panel or insulation type? Um, not within this set. No.
02:24:03 Um, not within this set. No. No. And there are no details of the proposed cavity barrier locations either, are there? No.
02:24:09 No. And indeed, parts of the window assembly are unlabeled, aren't they? That's correct. Yeah. So, if you go back to your email to Mr. Ashton, just have a look at it. Sea 000011
02:24:21 Sea 000011 730 at page three. Uh yours at 1218. The second line, you describe these as fairly limited, but they attempt to establish the basic approach. And that's right, isn't it?
02:24:33 approach. And that's right, isn't it? That that is all they were. Yes.
02:24:37 Yes. And you then sent just following the facts through uh some studio E section drawings. And the first one I want to show you is sea 000011711
02:24:49 show you is sea 000011711 for the offline version please. We want that for the offline version.
02:24:58 And this is
02:25:05 uh yeah that that that's right. We may just have to blow it up a little bit. This is entitled detailed section sheet one. You can't see it on the screen.
02:25:18 If you go to the bottom, uh the you'll have to read it, I'm afraid, in in portrait, although it's a landscape document, but if you can see at the bottom left hand corner, if you
02:25:29 at the bottom left hand corner, if you turn your head, you can see it says in the third box from the left, details section sheet one. Do you see that? Mhm.
02:25:35 Mhm. Okay. Um and it's dated the 26th of September, 2013. Yes.
02:25:39 Yes. Yes. Uh and on the left hand side of the drawing um the first and the third labels down from the top.
02:25:52 third labels down from the top. Uh if yes, perfect. Under the big 01
02:25:58 um next to the H92123, you can see that it says zinc composite raincreen panel and framing system to sills. You see that? Yes. Now in fact it's right that by this
02:26:11 Yes. Now in fact it's right that by this time this is midepptember 2014 um aluminium composite panels had been selected hadn't they? Um I I believe that had been proposed.
02:26:22 Um I I believe that had been proposed. Yes.
02:26:22 Yes. Yeah. Can can you explain why you are sending Mr. Ashton drawings which show zinc composite cladding when in fact aluminium composite panels had by now
02:26:35 aluminium composite panels had by now been selected. Um well that's not actually quite true. If you look down at the bottom of that, you can see it says aluminum composite TBC. So, um, is true the drawing shows
02:26:46 TBC. So, um, is true the drawing shows both zinc and aluminium composite, although they're both national class zero.
02:26:52 zero. Uh, I wasn't asking you about national class zero, Mr. Mr. Crawford. I just want to understand why it is that at H92 where I've identified it says zinc
02:27:04 where I've identified it says zinc composite rainscreen panel. Can you explain why it still said that given that ACM had been selected? I think there's um there's a Bruce was hoping that the sink would um
02:27:17 hoping that the sink would um would perhaps stay and certainly though issues relating to discharge of the final planning um or final planning decisions are still being made in the background. Um
02:27:32 right. Uh okay. Okay. So, in essence, what I'm saying is that drawing does show two different types of cladding. What I'm saying to you is materially, my understanding is that there's effectively no difference in
02:27:44 there's effectively no difference in terms of performance.
02:27:47 Right. Right. We we we know that there was some element of aluminium on the first four floors, Mr. Crawford, just to be clear about that. But but at H92 H92
02:27:58 H92 uh at 123 which is that part of the NBS spec which refers to the um raincreen higher up the building. It still says zinc and I just just like to try and understand why you were sending Mr.
02:28:09 understand why you were sending Mr. Ashton at this stage drawings which said zinc when it was ACM. Yes. But it also says H92125 halfway up um PPC aluminium composite.
02:28:22 halfway up um PPC aluminium composite. Yes, Mr. Ash, Mr. Crawford, we've been around this before. That's that may be the lower levels, but higher up it wasn't going to No, it's not the lower levels. It's still within the main body of the upper. When you say lower levels, do you mean
02:28:34 When you say lower levels, do you mean levels top 20 levels, or do you mean within the level within that level? A H92125, which is what you're focusing on where it says aluminium. Mhm. Do you remember this that the NBS spec
02:28:46 Do you remember this that the NBS spec refers to grain screen cladding first fours elevation and internal envelope of main entrance canopy and canopies in general? That's 125
02:28:58 123 is not. Can you scroll this section up? I think certainly
02:29:17 Okay. So, um yeah, if you
02:29:22 if you scroll back up to the top again.
02:29:29 Yes. So, this this is with this is Yeah, it's way plus one. Sorry, I see what you're saying. Yeah. Yeah. Yeah. So,
02:29:38 Yeah. So, so can you explain just a ask the question one more time. Why it was that under H92 which referred to what part 123 or parah 123 of the NBS spec uh
02:29:49 123 or parah 123 of the NBS spec uh which is the raincreen cladding through higher up in the tower to the spandrel panels. It still referred to zinc composite when ACM had by now been
02:30:00 composite when ACM had by now been selected.
02:30:02 selected. Well, for the reasons I think I mentioned slightly earlier. Um, but the I know Bruce was keen to try and keep the zinc and obviously the ongoing planning issues
02:30:13 planning issues zinc CM ACM interchangeable in terms of performance but yes it is out of date isn't it? Um
02:30:26 well not not if you consider it it's part say taken from the employers requirement set of drawings which would have been done by the time you sent this document to
02:30:38 by the time you sent this document to Mr. Ashton Mr. Crawford this drawing in that respect was out of date but there's no there's no onus to update that because from that point on Harley we're doing the detailed drawings. Okay,
02:30:49 we're doing the detailed drawings. Okay, Harley. Right. Uh, let's look at something else. If you could please be shown the far left hand side of the uh drawing just above the title metzolene level plus 9.
02:31:03 You have to scroll down. Um,
02:31:13 go down a little bit further. Yes, stop there. Perfect. Um now uh you will see um what is on the screen is is um lower down metanine level plus 9 and then
02:31:26 down metanine level plus 9 and then three zeros. Do you see that? Yes.
02:31:28 Yes. And then three uh arrows or circles above that you can see H92776 thermal insulation. You see that? Yes.
02:31:36 Yes. Now we can see that this drawing does not record the fact that Celotex FR5000 let alone RS5000 had been specified. Why was that?
02:31:51 Um, with all due respect, this drawing was from the employer's requirements, but sorry, you're saying I didn't quite catch that. You're saying the H92776 reference? Yes, thermal insulation.
02:32:03 Yes, thermal insulation. But does that not reference back to the F FR5000?
02:32:07 F FR5000? Uh, well, uh, it does. If you go, of course, back to the, uh, NBS spec, it would say F FR5000. My question is why doesn't thermal insulation
02:32:18 doesn't thermal insulation either refer to R F F F F F F F F F F F F F F F F F F F F FR5000 or RS5000 which by this time had now been specified, but we didn't we didn't know the RS5000 been specified at that point.
02:32:32 I thought that at this point you had the data sheet. No, the the data sheet for RS5000 and you told us this morning that you'd had a conversation with Mr. Mr. Bailey, Ray Bailey of Harley, who
02:32:44 Mr. Bailey, Ray Bailey of Harley, who told you that RS5000 had now been specified. Yes. But you talking about the SE this email was from what? 17th, 18th September. Yeah.
02:32:52 Yeah. Yes. But that's when we received the the data sheet. Do do you know why it was that no product had been specified at all in relation to that arrow with thermal
02:33:03 relation to that arrow with thermal insulation?
02:33:09 But it has been because it's referenced back to 776H H92.
02:33:16 Okay. I don't I'm sorry. I don't really get your point because Well, never mind. I'm just seeking to understand really what I'm seeking to get from you, Mr. Crawford is sorry, I'm not trying is how complete these documents were when you sent them to Mr. Ashton so that he could understand the
02:33:28 Ashton so that he could understand the detail.
02:33:29 detail. Do you see the details that he was after the external construction? Can I just clarify though these drawings we work the drawings up to employers requirements the stage E to the tender
02:33:41 requirements the stage E to the tender set after that point Harley take over so Harley do the drawings after that so what I've sent him is where where the draw we taking the drawings up to plus
02:33:52 draw we taking the drawings up to plus Harley's drawings that's the state of the design that's where the design is at and that includes their proposition for the installation which is the same day I mean even if you had gone back and
02:34:04 mean even if you had gone back and retrospectively updated everything, you wouldn't have been able to do it the same day. But we weren't under any obligation to update it because at that point this was Harley's proposals moving forward. Do you see where I'm coming
02:34:15 forward. Do you see where I'm coming from?
02:34:16 from? Uh
02:34:18 Uh so let's just have a look at another part of this. If you go to the right hand side of the drawing, you can see that uh
02:34:30 that uh there is a a label Uh, under P10. Oh, no. Go back down again, please, Mr. Operator, and go to P10235.
02:34:41 Operator, and go to P10235. Do you see it says thermal insulation to prevent cold bridging? Yes.
02:34:44 Yes. And then there's an arrow to a piece of insulation there. In fact, did you know this? But in fact, that thermal insulation uh was rockwool, but the drawing doesn't specify that rockwool
02:34:56 drawing doesn't specify that rockwool had been chosen, does it? But P10 is in sunundry items and
02:35:02 and indeed
02:35:02 indeed um sunundry items covers precisely that sunundry items. Indeed.
02:35:06 Indeed. This detail is of a roller shutter along the ground floor. Yes.
02:35:10 Yes. Um so it's specific very specific limited bit of detail is not the overall insulation. It's a specific bit of insulation behind a very specific
02:35:21 insulation behind a very specific detail.
02:35:21 detail. Well, let's see if we can get this this way. Uh anybody looking at these drawings, Mr. Ashton receiving them from you from you. Yeah.
02:35:30 Yeah. Would not know when he looked at them what the raincreen was comprised of or what the insulation behind the raincreen was or indeed what the insulation to
02:35:41 was or indeed what the insulation to prevent thermal bridging or cold bridging was? No, I disagree. You disagree. Why do you disagree? Um well, first of all, we sent them the data sheet with the insulation on it. So that was um um Harley's proposal had
02:35:54 that was um um Harley's proposal had their installation on it and then clarified the ACM. Did you send Mr. Ashton the NBS spec? Um I don't recall.
02:36:06 Um I don't recall. Why not? Oh, sorry. I know you recall. Uh would it not have been sensible to send him not only the drawings but the NBS spec so that he could see exactly what the details he was after were?
02:36:18 what the details he was after were? Well, to be clear, my understanding was that he did understand what was being built. So, what I sent him was the Harley details, then Harley's proposal
02:36:29 Harley details, then Harley's proposal in relation to the installation, and then clarified the cladding type. Well, why didn't you say to Mr. Ashton, "Here are the drawings and here's the
02:36:41 "Here are the drawings and here's the NBS spec so that you can make sense of the materials in the external wall construction." You didn't do that. So my question is why not?
02:36:51 Well, NBS spec contains a number of alternatives. What I was trying to do is communicate what I believe with our building.
02:37:02 Why didn't you say to Mr. Ashton, I should just tell you that the bits where it says zinc isn't right anymore. It's aluminium composite. But I think I I think I did. There was a follow. I
02:37:16 follow. I zinc CM and ACM from in performance terms as I understood it were the same and then so he worked on the assumption I think of the zinc CM performance of
02:37:27 I think of the zinc CM performance of which should been the same as the ACM and then when I think at the end of the conversation I did confirm with him that it was my understanding was that we were running with ACM.
02:37:39 running with ACM. When was that conversation please? at the same time same time as the 17th 18th conversation what that you referred to on Thursday where you you told us that he had said
02:37:50 where you you told us that he had said that the seller text was compliant same conversation as that is that what you're saying
02:37:56 saying I think it was yes I think it was really
02:37:58 really I mean maybe I've maybe I've got conversations mixed up
02:38:09 do you agree with this proposition that Exova could not have produced any any reliable analysis of the compliance of the proposed overcladding scheme
02:38:21 overcladding scheme with requirement B4 of the building regulations without knowing what cladding or rainscreen and insulation materials were going to be used in the structure.
02:38:33 used in the structure. But they did know. Yeah. Sorry. Can I have my answer to my question?
02:38:37 question? Sorry. Do you agree that Exover couldn't have produced any reliable analysis of the compliance of the proposed overcladding scheme with B4 unless they did know what was being used as the
02:38:51 did know what was being used as the Yes. And if they didn't know Thank you. You say they did know because you told them you told Mr. Ashton is it right on the telephone. Is that right? Yeah. I I I'm pretty sure it was within
02:39:02 Yeah. I I I'm pretty sure it was within the conversation. Yes. Right.
02:39:05 Right. on the 17th or 18th of September. Yes. Is that what you're saying? Yeah. I think I without going back and checking all the there's so many emails and there's so much data. I can't I
02:39:16 and there's so much data. I can't I can't recall precisely what was explained when, but my understanding is that I clarified it with the insulation.
02:39:27 Now, it's right, isn't it, that Exova never did produce a further issue of its outline fire safety strategy, did it? Um, not that I'm aware of. I I remember having the conversation with Terry
02:39:41 having the conversation with Terry about the um the suitability of the insulation and the suitability of the cavity by their strategy. I remember having these distinct telephone conversations
02:39:52 conversations and then I remember asking him to put in into an email confirmation that he um believed that they were appropriate. He did send a response which I think on
02:40:05 He did send a response which I think on reflection is more of a tacet approval but my understanding is that his belief was that it was compliant. Uh well, we're going to look at the rest
02:40:17 Uh well, we're going to look at the rest of the email chain shortly. Uh but just so I understand your answer, you're saying, are you that you had a tele telephone conversation with Mr.
02:40:29 tele telephone conversation with Mr. Ashton
02:40:31 Ashton on the 17th or 18th of September in which he told you that Senate RS5000 and Rainobond PE55 aluminium composite material raincreen
02:40:42 material raincreen ACM
02:40:43 ACM ACM
02:40:44 ACM were compliant. Is that your evidence? I don't want to put words in your mouth. I'm trying to summarize what I think you've been telling me. And if I'm wrong, please say.
02:41:01 My understanding is that in discussing the fire strategy, the fire the cavity by our strategy in relation to the wall buildup, he understood what the wall
02:41:12 buildup, he understood what the wall buildup was. He'd sent him the installation detail and he un um the installation data sheet and he understood what the cavity barrier strategy was and he understood what the
02:41:24 strategy was and he understood what the um the the cladding panel buildup was and I asked him to confirm that in writing.
02:41:38 And you say that he did confirm it in writing but only tacitly. He he he confirmed in writing that he thought it um it's appropriate, but in reflection
02:41:50 um it's appropriate, but in reflection it's more of a task approval than an explicit one, right?
02:41:53 right? When I reread it. All right. Well, we'll come to see what we do see in writing shortly.
02:42:01 Just to be clear, it it's right certainly from the documents that the inquiry has seen that Exova's proposition in its issue three of its outline fire
02:42:15 in its issue three of its outline fire safety strategy of 7th November 2013
02:42:21 that the proposed changes would have no adverse effect on the building in relation to external fire spread was never confirmed by any analysis by Exova.
02:42:34 That's correct. And it was never confirmed by any other specialist fire consultant in any report during the period you were project architect on? Not that I'm aware of.
02:42:45 Not that I'm aware of. No.
02:42:49 And you never sought to chase one up. And is that because, and again, I don't want to put words in your mouth. Is that because of what you say are the asurances that Mr. Ashton gave you over the telephone
02:43:01 Mr. Ashton gave you over the telephone on the 17th or 18th of Yeah. Well, I remember having conversations with Mr. asked on a number of occasions across the project um on a number of issues, separate issues, but I
02:43:12 number of issues, separate issues, but I remember on the um on this particular issue in relation to the cavity barriers and when the data sheet for the installation was sent, I
02:43:24 sheet for the installation was sent, I remember um um um I remember him alluding to the fact that you'd have to complete the report or something of that nature. And
02:43:35 report or something of that nature. And I never thought any more of it. Firstly, because I basically had the conversation with Bruce about what I understood we had and whether it was compliant and then had the conversation with Exova and
02:43:48 then had the conversation with Exova and to me Exova just confirmed that yes, what we understood compliant was compliant and that was it. And [Applause]
02:44:07 Right now, let's just go back to the email chain. Going back to it at SEA1 000011719.
02:44:19 Uh you can see
02:44:24 the second email down on the first page. This is in response to you where you send him the fairly limited drawings. Uh he Terry Ashton comes back to you and we're now 18th of September 1532.
02:44:37 we're now 18th of September 1532. You see that Neil? If the insulation in the cavities behind the raincreen cladding is combustible. Note the if you'll need to provide cavity barriers as shown on your drawing number
02:44:49 as shown on your drawing number 127906120
02:44:51 127906120 in order to prevent fire from spreading from one flat to one above even if there isn't a continuous cavity from the top to the bottom of the building. Kind regards Terry. You see that?
02:45:02 You see that? Yes.
02:45:05 Now it clearly by this point in the day 18th September
02:45:14 September 1 half past 3 you hadn't yet had this telephone conversation with Mr. Ashton where he confirmed that Celtex was compliant and that ACM was compliant as you now say had you.
02:45:30 And the reason I say that to be clear is he's saying if the insulation in the cavities behind the raincreen is combustible. Now if you'd had the discussion with him about Celotex being non-combustible as you tell us then that
02:45:42 non-combustible as you tell us then that conversation must have happened after 1532 on the 18th of September mustn't it? Um,
02:45:50 not necessarily. I mean, he's saying if the insulation in the cavities and the rain screen is combustible, he may have understood the the information I'd given that that
02:46:02 the the information I'd given that that was the case.
02:46:09 Well, if he had understood that the information you had given him given him showed that the rain screen was combustible and the insulation in the cap cavities was combustible.
02:46:20 cap cavities was combustible. Okay.
02:46:21 Okay. He he and we can ask him uh if he he had thought it was combustible then that would not reflect the conversation that you're telling us you had with him. Can
02:46:32 you're telling us you had with him. Can can you just pull up the email when the data sheet was forwarded because I'm losing I'm losing track there's so many emails I'm losing trackdeed what was sent when yes we can do that
02:46:43 yes we can do that eight years six years ago yes we we can do that uh if you go um to uh the uh email of uh
02:46:54 it's sea 000017 1 1130
02:47:01 1 1130 uh And it's at page
02:47:07 um page two.
02:47:11 See that?
02:47:29 I think the one you're after is at uh 1603 which is where Daniel Ankl Jones sends says to you the insulation is class N.
02:47:42 Yes. That's that's after to be fair to you that is after the conversation that you've had or rather after the email I've just shown you at just before half past 3 on the second. What I'm trying to establish is do you have the email with
02:47:53 establish is do you have the email with the attachment on it that was sent?
02:47:59 Uh yes. And we looked at that earlier. If you stay on this page, it's SEA000011730 page two. We can see we'll go back to this again. Go back to this. I know. Go
02:48:10 this again. Go back to this. I know. Go back to this at page two. Second email down. That's where
02:48:17 where um Daniel Al Jones tells you the insulation is class not and then you email Terry Ashton saying is this interpretation correct? Yeah. What I'm trying to establish is
02:48:28 Yeah. What I'm trying to establish is the email that had the data sheet on it because that's the data sheet was forwarded to Terry. So that would give you the time. Yes. And and according to your statement at 192, you say you sent that comment to
02:48:42 at 192, you say you sent that comment to XOA together with the data sheet. Okay. So which that's what you said in your statement. So confus
02:48:49 So confus you can't see it from you. I agree with you. You can't see it from the email because the email doesn't refer to an attachment. But you say in your statement that it does.
02:48:58 does. Yeah. The problem with the way these emails are presented when you see them in
02:49:02 in when you see the actual email in Outlook, you can see the attachment. with this. I can't that's why I can't determine which which one the attachment was on.
02:49:12 was on. Yeah. Now, I'm just trying to establish the time on the day at which you had the conversation you were referring to. I think we've established that it wasn't uh before uh the um email
02:49:23 that it wasn't uh before uh the um email when you go back to him sending him the detailed drawings. So, uh it must have been must have been after that. Do you think it was after the exchange of emails where you get the you say you get
02:49:36 emails where you get the you say you get the data sheet from Daniel Ankle Jones and then send it on to Terry Ashton? I think it would have been after. Yes. I mean that's logical. [Applause] So
02:49:48 So going to the email chain then and still on this page. It's not inconvenient to stick with this reference. If we can have scrolled down a little bit please this email chain at page two to see the
02:50:00 this email chain at page two to see the top of it. I'm afraid it goes over two screens. Uh
02:50:09 uh right and if you could scroll up to the top of page two. I think that's the email we want.
02:50:19 Right there it is. Just just lost it. Um,
02:50:24 Um, Daniel Uncle Jones said says to you the insulation is class n and then you take you say to Terry Terry Ashton and that's a 16003 and you say to Terry Ashton if we could scroll
02:50:35 say to Terry Ashton if we could scroll down please because we've only got half the email. This is at 1532 and then you go back to him. This is this isn't right. Uh at 1550.
02:50:50 Okay. What's gone wrong here? I'm afraid is that I don't think my um instructions to the operator are getting through. Could I please be shown the top half of page two of this document and the bottom
02:51:03 page two of this document and the bottom of page one?
02:51:07 So we can see the email to you from Daniel Ankle Jones of603 and then you sending that to Terry Ashton at bottom of page one please.
02:51:23 uh just there606007 you look at page one we've managed to get both
02:51:29 get both uh parts of the email screen up on the screen email string on the screen so you send this on to Terry Ashton at 16007 yes
02:51:38 yes and then he responds to you at 162163
02:51:43 and 1621 are the times I'm seeing uh right let's take even more slowly. Right on the right hand side, you've got Daniel Ankerl Jones telling you insulation is class N6003.
02:51:55 insulation is class N6003. Yeah.
02:51:56 Yeah. Uh the email which is I'm afraid split over two pages. Um which you send to to Terry Ashton is at 1607. If you look in on the screen in the bottom left hand sorry I see what you're saying. Yes.
02:52:07 Yes. Uh and then above that Terry Ashton comes back to you at 1621. Okay.
02:52:13 Okay. Where he says a material uh which is class N. Do you see that? Yes. So, just to be clear about timing, which is what I'm trying to look at with you.
02:52:23 you. Um, you say, I think that Daniel Anker Jones sends you the data sheet at 1603. You send that on to to Terry Ashton at607, 4 minutes later.
02:52:34 at607, 4 minutes later. Yes.
02:52:35 Yes. Yep. And then Terry Ashton responds to you
02:52:39 you uh 30 minutes after that or so when he says Neil a material which has a class N rating is not necessarily non-combustible. You see that? Yes.
02:52:49 Yes. Right. Uh
02:52:55 now and then just to finish off the answer perhaps we can look at the very top of of page one just for the timing. You then go back to Terry
02:53:06 You then go back to Terry at 1712 and say, "Hi, Terry. Thank you." Daniel, can you confirm your position in relation to Terry's comment below regarding combustibility and continuous
02:53:17 regarding combustibility and continuous cavity paths? I don't need the rest. Uh, unless you can certainly look at the rest, but I don't want to ask you about the rest.
02:53:26 the rest. So, that's that's the email chain on that day.
02:53:30 that day. Do you see that? Yes. Now,
02:53:35 Now, when do you think looking at that email chain, you had your conversation with Mr. Ashton about Celletex RS5000 being a material of limited
02:53:47 being a material of limited combustibility or not combustible?
02:53:53 Well, it would have been after I sent him the data sheet.
02:53:58 after you sent in the data sheet but before he responds. I can tell you precisely, but it would have been after sent the data sheet because the data sheet would have been to inform him.
02:54:09 to inform him. Right now, let's just look a little bit more closely uh or even more closely um at uh your statement. Paragraph 92.
02:54:20 um at uh your statement. Paragraph 92. If you go back to it, it's par it's page 62.
02:54:26 You say uh in response to the comment Daniel Akal Jones said the insulation is class N. And you set out the rest of the quotation. And then you say again I
02:54:37 quotation. And then you say again I forwarded the comment to X over together with the data sheet for Celtex RS5000 dated August 2014 that Daniel had attached to his email. You see that you that's what you say.
02:54:48 You see that you that's what you say. Um but do you accept that looking at the emails if we can just go back to them please that we had a minute ago on the screen. S EA1730
02:55:00 and we'll look we'll have page two which is what you're referring to
02:55:06 uh which is the one from Ankl Jones to you at 16003. Do you accept that looking at that
02:55:15 that neither Mr. Ankl Jones's email to you nor yours to Mr. Ashton referred to an attachment
02:55:27 This comes back to what I said earlier. I was trying to establish which email had the attachment on it and I can't see it from the way these are presented here. If you you know when you're when
02:55:38 here. If you you know when you're when you're in Outlook and you see you see um you see your email and it's got attachments. So you know because the way this is presented I can't tell. Right. Well, perhaps we can just to be fair to you show you a different email
02:55:50 fair to you show you a different email or rather the same email and a different guise. If you look at SEA000011724,
02:56:02 which is the one you refer to in your statement,
02:56:08 that's what you refer to in your statement. Uh, and it's on the screen there. But again, we don't I think Uh,
02:56:20 we don't see uh Mr. Ankerl Jones sending you the data sheet, do we?
02:56:29 That's the point. Don't think Mr. Ankerl Jones sends you the data sheet because his email doesn't have an attachment to it and he doesn't refer to an attachment, does he? Well, that's how it appear there.
02:56:40 Well, that's how it appear there. Right. Well, just a minute, Mr. Mill. Um,
02:56:46 Um, the top half of this page does seem to refer to an attachment, doesn't it? It does. That That's Mr. Crawford. I was just going to come to that, Mr. Chairman.
02:56:53 Chairman. Right.
02:56:53 Right. I just want to work out where the attachment originates, but sorry, can I just interject the the data sheet was sent
02:57:05 data sheet was sent from um Harley to me? Correct.
02:57:12 Correct. Well, you tell me. Well, well, [Music]
02:57:17 [Music] it says here, attachments, rain screen, cladding, product data sheet.
02:57:25 Well, let's look at it. Let's try a different way of going about it. I think the point Mr. Mill's putting to you is that you can see from the top half of this page that that where there is an attachment,
02:57:37 attachment, it's referred to. Yes. And this is you sending that data sheet to Mr. Ashton. Yes.
02:57:46 Yes. What we don't see either in the bottom half of the page or I think in any other email we've looked at so far an attachment to an email from Mr. Ankerel
02:57:57 attachment to an email from Mr. Ankerel Jones to you. Is that your point, Mr. Minute? Yes, that that's right. So the the just looking at these two emails, Ankerl Jones to you and you to Mr. Ashton.
02:58:09 Jones to you and you to Mr. Ashton. Um Ankerl Jones doesn't attach the data sheet or refer to it. Correct. They seem that way. Yeah. I mean and so we move to the next question. You
02:58:22 and so we move to the next question. You then go to Mr. Ashton and clearly you do attach the data sheet. Yes. And my question is, was it you who decided to attach the data sheet to the email you were sending Mr. Ashton or
02:58:35 email you were sending Mr. Ashton or were you as is possible part just forwarding it on?
02:58:52 I can't I can't recall without seeing all the emails. Okay. I'm used to looking at I'm used to looking at the historic emails and then I can you can see and you can piece things together.
02:59:03 see and you can piece things together. I'm getting excerpts here. What I think happened is I was folding the what what I understood was from my recollection is that it was folded to me from Harley and
02:59:14 that it was folded to me from Harley and then I folded it I see
02:59:17 I see to over that's what I recolct but because I don't have that. Okay. Well, over the over the lunch break we'll we'll we'll see if we can find that because that may well be true. What happens sometimes is you don't
02:59:28 What happens sometimes is you don't always see the attachments on the versions of the emails that come up. But um let's just focus on what is on the message in the email. You it's certainly right looking at these emails that Mr.
02:59:41 right looking at these emails that Mr. Anker Jones doesn't tell you uh to look at the attachment, look at the data sheet and you don't mention the data sheet to Mr. Ashton, do you? when you send it on
03:00:00 within the email you're showing me here. No.
03:00:02 No. No.
03:00:03 No. And your witness statement doesn't refer to any discussion with Mr. Ashton in which you say that he told you that Celletex FR5000 was compliant with uh approved document B as a material
03:00:15 approved document B as a material limited combustibility. Talking about RS 5000 at this point. The data the data sheet was for from RS5000. You are correct. That's the whole point. The RS 5000 was sent to me.
03:00:26 whole point. The RS 5000 was sent to me. It was sent to me from Harley and then I folded from Harley takes over. That's the whole point. I wouldn't have folded it otherwise. All right. Let me put the You're absolutely right, Mr. Crawford. I I misked the question. Let me ask it
03:00:37 misked the question. Let me ask it again.
03:00:39 again. Your witness statement doesn't refer to any discussion with Mr. Ashton in which he told you that Celletex Selletex RS5000 was compliant with approved
03:00:50 RS5000 was compliant with approved document B. Correct. It may not refer to any discussion but there were there were discussions going on and nor does it refer to any discussion in which he told you uh that RS5000 was
03:01:02 in which he told you uh that RS5000 was a material of limited combustibility. Did he
03:01:05 Did he does it? I never said it doesn't do that.
03:01:07 that. I never said that you did. And there's no email record of what you act of where you actually asked him the question. Terry, is RS5000 compliant
03:01:19 question. Terry, is RS5000 compliant with the building regulations? Categorically, no. But I I sent I sent him the that as a package of details of the buildup.
03:01:32 And you ask him all you asked him when you sent him the data sheet is, is this interpretation correct? You don't ask him is RS5000 compliant with the
03:01:43 him is RS5000 compliant with the building regulations, do you? No, but he's asked for details of the buildup. I've sent him details of the buildup and have clarified what the proposed installation type is. I there's
03:01:57 proposed installation type is. I there's a series of conversations that took place around that and for sure it was more than one telephone conversation. What I what I don't have is a record of all those conversations. I just have a
03:02:09 all those conversations. I just have a sense of what was sent and what I agreed.
03:02:11 agreed. Yeah.
03:02:13 Yeah. Given the absence of any re reference in your witness statement to a telephone conversation with Mr. Ashton on the subject of whether Celotex RS5000 complied. Uh are you quite sure in your
03:02:27 complied. Uh are you quite sure in your recollection as you told us on Thursday and again this morning that you actually did have a conversation over the telephone with him? There's definitely there definitely conversations going on in parallel with the emails for sure.
03:02:39 in parallel with the emails for sure. Can you explain why it is that your witness statement, which is lengthy and detailed, made absolutely no reference to such a telephone conversation? Well, there's a a lot of telephone
03:02:50 Well, there's a a lot of telephone conversations um that took place um so I wouldn't have recorded them all. And also, you can't say precisely what you said in telephone conversations. You only know what you
03:03:01 conversations. You only know what you discussed. In general terms, let's say, given that you knew by this stage that Exova had promised a further analysis as to whether the proposed cladding would
03:03:12 to whether the proposed cladding would comply with approved document B so far as external fire spread was concerned, and given what you now tell us, namely that you had a conversation over the telephone that Celtex RS5000 complied, was that not something that
03:03:25 complied, was that not something that you that you would have put in your witness statement? Mr. Crawford, I'm going to ask the question and you can answer it. Is that not something that you would have put in your witness statement had it actually happened?
03:03:37 statement had it actually happened? To be clear, the conversation that I had was in relation to the cavity barrier um proposal in relation to the buildup. That was the conversation I was having
03:03:51 That was the conversation I was having indeed. But given it is a but given the importance of h of of as as exova had said getting a future analysis
03:04:02 said getting a future analysis of whether or not the proposed overcladding complied with ADB and given what Mr. Ashton, you say I was telling you over the telephone in the middle of this email string on the afternoon of
03:04:13 this email string on the afternoon of the 17th of September. I'm suggesting to you, I'm putting it to you that you would have recorded that in writing at the time and you would have put it in your witness statement. And my question to you is you didn't. Why not?
03:04:25 to you is you didn't. Why not? What
03:04:27 What I'm I'm trying to explain to you how how what I understood happened. First of all, that's what I'm trying to say is that the conversation was in relation to the um cavity barrier strategy. Um
03:04:41 the um cavity barrier strategy. Um Harley sent me additional information in relation to the RS5000 and um um um Exover were looking for um
03:04:52 and um um um Exover were looking for um um clarification of what the details and the buildup was and that was that was what that's what was going on in those conversations and that email conversation uh backwards and forwards
03:05:05 conversation uh backwards and forwards that was what was being tried to that was what was being established. I mean, it was primarily around the cavity barrier um strategy, but it it sucked in other stuff. It wasn't the
03:05:17 sucked in other stuff. It wasn't the conversation wasn't about them doing this uh follow-up report. That wasn't what the conversation was about. The conversation was about um the cavity barrier strategy, but inevitably brought
03:05:30 barrier strategy, but inevitably brought the other elements into the conversation. Right, Mr. Chairman? Is that a convenient moment? I'm afraid I'm mid-stream, but Well, I don't think we can do much about that. Right. We're going to have a break now, Mr.
03:05:41 We're going to have a break now, Mr. Crawford. Um, again, please don't talk to anyone about your evidence or things related to Can I just say I don't want you to feel I'm being obstructive. I'm just trying to
03:05:53 obstructive. I'm just trying to recollect relative to what I know I had in emails and in notional conversations I know I had round about the same time. And it's very difficult because there's definitive email trails, but there's
03:06:06 definitive email trails, but there's there are conver there's a lot of telephone conversations and I'm trying to link them in logically to what I was talking about at the time. And that's why I'm emphasizing this was a conversation about cavity barriers, but
03:06:17 conversation about cavity barriers, but it it expanded from that and you could see that because it brought the insulation into that conversation, but it wasn't a categoric conversation about um um dealing with the the follow-up
03:06:29 um um dealing with the the follow-up report.
03:06:32 report. Do you see what I'm saying? I I I don't just want you to feel that I'm somehow dodging or or or not, you know, I'm trying my best and to to relay what I
03:06:45 trying my best and to to relay what I understood happened. No, I we we understand that. Yeah. Yeah. Thank you for clarifying. All right. Would you like to go with the usher then, please? We'll resume at 5 2, please.
03:07:02 5 2 Please.