Grenfell Tower Inquiry - Studio E Evidence - Monday 9 March 2020 (2/2)
00:01:34 [Applause] right will you ask mr. Kaufer to come back in please
00:01:53 right mr. Crawford hey carry on yes mr. Crawford before lunch we were looking at some emails between Harley and you and
00:02:04 some emails between Harley and you and you and mr. Afton Avex over and one of the questions that arose was whether or not you had got the data sheet for rs.5000 from Harley let me just be clear
00:02:15 rs.5000 from Harley let me just be clear about that to be fair to you why sure you please a document bsd zero zero zero zero one four to zero
00:02:36 and this actually has come from Kevin lambs disclosure what it shows is that
00:02:46 on the 18th of September looking at the top email on page one Daniel angkatell Jones sends you the data sheet at 1603
00:02:58 Jones sends you the data sheet at 1603 and then in the email says the installation is classed nought and then you send that on although we can't see it on this version of the email string you send that on to Terry your Ashton a
00:03:12 you send that on to Terry your Ashton a few minutes later saying Terry as this interpretation correct so does that help you orientate yourself in where you got the data sheet from it's clear from this and you did get it from mr. ankle James
00:03:25 and you did get it from mr. ankle James I knew would you respect that's my I understood exactly and one of the problems that we have so you know is that some of the email strings don't always show the attachments because of
00:03:36 always show the attachments because of the way they've been archived so that's that is that is that was that was the position now can we go back to the email where you do forward the message to mr.
00:03:47 where you do forward the message to mr. Ashton
00:03:48 Ashton is this interpretation correct that's se a zero zero zero one one seven three zero at page two
00:04:07 and again I'm afraid we've got this slight difficulty about the time but doesn't it doesn't have matter you say is this interpretation correct see below and it it is it the case that you
00:04:19 and it it is it the case that you yourself are not sufficiently familiar with the regulations and approved document b in particular to know if mr. Anker told Jones his interpretation was correct I think in relation to something
00:04:34 correct I think in relation to something like partly is a very technical document and in some aspects of it are quite apparent and some aren't and particularly where I'd consider this
00:04:48 particularly where I'd consider this something specialist then then I think it's right to verify it with a specialist and that's what I was looking to do check that interpretation is the
00:04:59 to do check that interpretation is the same as Daniel's ready so you didn't go back to approved document b yourself and check the requirements for limited
00:05:10 check the requirements for limited combust ability not okay is there a reason why as we can see you didn't volunteer any commentary in your message to mr. Ashton
00:05:27 not that I recall I mean I know I mentioned before the break through our telephone conversations as well but I don't I don't recall anything specific in relation to this particular question
00:05:39 in relation to this particular question and we can see from this email that you didn't ask mr. Ashton any particular queries regarding the technical detail is there a reason why that's why you didn't
00:05:57 no I mean that as I said there are telephone conversations going on as well and I just can't recall precisely because I know that's what you're
00:06:08 because I know that's what you're looking for are precise precisely what those were and they precisely what was discussed yes I mean that I did think you're saying it was a telephone
00:06:19 you're saying it was a telephone conversation between 1603 and 1607 no but you're asking about what's being said in terms of technically yeah yes so
00:06:31 said in terms of technically yeah yes so my question again why didn't you ask mr. Ashton
00:06:34 Ashton any specific questions regarding the technical detail that you were being given by mr. ankle James well about azimuth interpretation is correct now if
00:06:46 azimuth interpretation is correct now if we go up to the first page of that email chain we can see mr. Ashton's response on the 18th of September 2014 at 1621
00:06:57 on the 18th of September 2014 at 1621 and we looked a little bit before but he says Neal a material which has a class naught rating is not necessarily non-combustible well where the reverse is invariably
00:07:08 well where the reverse is invariably true some class naught products will burn when exposed to a fully developed fire just looking at the first sentence I've shown you did you understand what
00:07:19 I've shown you did you understand what mr. Ashton meant when he said that a class naught rating is not necessarily non combustible although the reverse is invariably true and I think so yes what what did you understand by that
00:07:32 what what did you understand by that it's
00:07:42 a non combustible material will be by default classy no right
00:07:56 [Applause]
00:08:00 and what about the other way around what do you mean done around well the the obverse the reverse what did you
00:08:12 obverse the reverse what did you understand him to mean by that he says the reverse isn't variably true what do you understand by that just what I said which is there are
00:08:23 I said which is there are non-combustible will be by default class zero and class zero by contrast what is
00:08:34 zero and class zero by contrast what is that you say non-combustible will always be class zero by default what class Co as you stated rating is not necessarily non-combustible exactly yeah and in what circumstances the next question in what
00:08:46 circumstances the next question in what circumstances would a class naught rating not being non-combustible did you think
00:09:04 well the test method for class zero the four six four seven six test yes four seven six test is effectively a surface
00:09:17 seven six test is effectively a surface test small square new flame under it whereas the BS en one
00:09:29 flame under it whereas the BS en one three five zero one test is a through material test did what you just given to me by way of an explanation was that
00:09:40 me by way of an explanation was that something you you knew at the time was that something you were alive too nice well let me ask a question in a slightly different way what was your take away your basic met understanding from mr.
00:09:51 your basic met understanding from mr. Ashton's message that class naught rated material was not necessarily non combustible well it could it could be
00:10:02 combustible well it could it could be class zero and be of limited combust ability for example and and in what circumstances with something which was class zero be of limited combust ability
00:10:15 class zero be of limited combust ability did you think at the time I don't know if I did think not I mean did you think about what did you ask yourself the question well what does it depend on
00:10:27 when would it be necessarily a non combustible and when wouldn't it be I don't think I thought that far right so did you ever learn in the end whether
00:10:38 did you ever learn in the end whether rs.5000 walls in fact combustible non combustible or of limited combust ability
00:10:46 I think I suspected it was limited combust ability but my method of verification was for its suitability and
00:10:59 verification was for its suitability and the proposed build-up was with x over just following that up you say I think I suspected it was limited combust ability did you ever actually learn whether it
00:11:12 did you ever actually learn whether it was categorically not
00:11:20 does that mean that from September 2014 mr. Crawford you were at least alive to the fact that you couldn't rely on a class nor fire-rated classification for
00:11:35 class nor fire-rated classification for insulation as demonstrating without any further questions being asked that the insulation was of limited combust ability I don't think I thought that far
00:11:47 ability I don't think I thought that far I mean I think I just I took the product and I read the my interpretation was as per my witness statement in terms of how
00:11:58 per my witness statement in terms of how I read read the statements were made in the front of the product and then I sent it to had the conversation sent it takes over to verify that my understanding was
00:12:10 over to verify that my understanding was there was effectively compliant within the build up now you then go to the top of the email chain please which is se a
00:12:22 of the email chain please which is se a zero zero zero one one seven three zero very top please this is your response back to Terry Ashton same day 18th September 2014 at 1712 so just about 55
00:12:39 September 2014 at 1712 so just about 55 minutes after your after you received his email at 1621 and you say hi Terry thank you and you see see this to Daniel
00:12:51 thank you and you see see this to Daniel axel Jones at Harley and Simon Lawrence a trident and Sonia Connor as well and and Kevin lamb indeed and you say Daniel can you confirm your position in relation to Terry's comment below
00:13:02 relation to Terry's comment below regarding combust ability and continuous cavity paths and then you talk about the Kensington Aldridge Academy what did you
00:13:13 Kensington Aldridge Academy what did you mean do you remember by confirm his position can you confirm your position when you asked Daniel capital jens that question
00:13:29 I'm I suppose that he agreed with Tara's interpretation right now it's fair to say because we can see it here that you didn't offer any commentary on mr. Ashton's email or ask any questions back
00:13:42 Ashton's email or ask any questions back to mr. an kettle Jones did you but I can only go by what some of the emails here I mean looking at it in the round and tell me if this is unfair mr. Crawford
00:13:53 tell me if this is unfair mr. Crawford but isn't it fair to say that in respect of this design issue cavity barriers interlaced with combustible 'ti of the insulation you were attempting really to
00:14:04 insulation you were attempting really to act as a go-between as between Harley on the one hand and X over on the other without really engaging with the substance of the problem
00:14:19 no I think this little unfair I mean I think um I think on one hand you had Harley who were proposing something that
00:14:31 Harley who were proposing something that was obvious like deviation from from from what we said in employer's requirements and you have the specialist for a consultant and another I was
00:14:43 for a consultant and another I was trying to if you like arbitrate between the interpretations and make sure that the always being proposed would ultimately be compliant well you say you
00:14:56 ultimately be compliant well you say you are if you like arbitrating between the interpretations perhaps isn't possibly not the best use I'm not gonna pick you up on now on the word arbitrator's sudden understand that might be a
00:15:07 sudden understand that might be a lawyer's phrase misuse but you is it right to say that you are essentially acting as a middleman in receiving the question from Harley punting it off to x
00:15:18 question from Harley punting it off to x over to answer getting the answer back from x over and then punting it back to Paul Tudor and that the portal by Harley was not mine and so even yes I'll be one
00:15:30 was not mine and so even yes I'll be one I would make and then I would attempt to interpret something as specialist as that without going to the specialist so I was coordinating between the two that
00:15:43 I was coordinating between the two that was how you saw your roles at one of coordination rather than in putting any yeah I was well I wouldn't see is checking for compliance you wouldn't see it as checking one way or the other no I see
00:15:57 checking one way or the other no I see seeking to ensure that it was compliant but not specifically checking myself the
00:16:06 okay can I ask you to stay on this page and look back at the second email from mr. Ashton this is the one at 16 21 to
00:16:18 mr. Ashton this is the one at 16 21 to you we've looked at the first two sentences he then goes on to say in any case you need to prevent fire spread from one flat to the flat above as I
00:16:29 from one flat to the flat above as I stated in my earlier email what isn't clear from the information to hand is whether or not there is a continuous cavity from top to bottom in any part of the cladding apart from around the column casings irrespective of the type
00:16:40 column casings irrespective of the type of insulation now just a few questions about what he says there because I want your understanding obviously mr. Ashton will come and explain what he meant but did you understand that they were act wear are actually two separate issues
00:16:52 wear are actually two separate issues here there was the type and the fire performance of the insulation on the one hand and also on the other the design scheme full cavity bearings did you see that as two separate issues these
00:17:05 that as two separate issues these highlighted that's two separate issues yes yeah did you appreciate that the question of whether there should be cavity barriers along compartment floor lines was not determined by the type of
00:17:17 lines was not determined by the type of insulation used all the combust ability rating I should say of the insulation used
00:17:27 so I'm just gonna really do yes calls
00:17:43 yes I think that's what he's saying did you appreciate that the question of whether there should be as my question to you did no system this should be cavity buyers around the compartments
00:17:55 cavity buyers around the compartments even if I thought anything I'll own that I mean it's interesting I think on the original and the original RFI the proposal that I see Harlee suggesting is
00:18:10 proposal that I see Harlee suggesting is to address with the it's mainly to address the chimney effect and the this is something that Terry's picked up in this when he talks about the continuous
00:18:21 this when he talks about the continuous cavities from top to bottom you can see that his primary concern and I think that concern probably is illustrative of how people in the industry with that
00:18:33 how people in the industry with that type of cladding would think but I don't think it I think being prudent you'd almost be looking to maintain the compartment and protected compartment
00:18:44 compartment and protected compartment but just to come back to my question about the distinction again did let me ask it slightly differently did you think what did it occur to you that Harley had misunderstood the distinction
00:19:00 Harley had misunderstood the distinction here between on the one hand the question of the type and fire performance of the insulation on the other hand the design scheme for cavity barriers
00:19:22 can you ask that again yeah you you and I have agreed that there are two separate separate issues here there's the type and fire performance of the insulation and there's the design scheme
00:19:34 insulation and there's the design scheme for cavity barriers my question is whether you thought at the time that Harley had lacked an understanding of that distinction I think that's a question for Harley I'm asking you
00:19:46 question for Harley I'm asking you whether you thought they might have done
00:20:03 I don't know okay all right it's possible
00:20:22 do you accept that the specification of insulation that doesn't comply with the building regulations and the guidance
00:20:33 building regulations and the guidance and approved document b is something that should have been in your words manifest to the reasonable architect or any architect or any preferred person performing the role of an architect on a
00:20:45 performing the role of an architect on a project to over clad a building in excess of 80 meters in height I think it's your duty to seek to check that and
00:20:57 it's your duty to seek to check that and comply they seek to to make sure they
00:21:08 comply they seek to to make sure they seek to ensure that it does comply yes and would you accept there's a general proposition mr. Crawford today a subcontractor omit omitting cavity
00:21:21 subcontractor omit omitting cavity barriers from locations where they are required by approved document b to the building regulations and the and the guidance in it should have been manifest to any architect engaged on a project to
00:21:33 to any architect engaged on a project to ever found a building in excess of 18 meters in height
00:21:43 not not necessarily then we have to I mean they may have their reasons you see um it's in relation to a db2 but a db2 is only guidance on where to to to place
00:21:56 is only guidance on where to to to place cavity barriers it's not um it doesn't guarantee that you are you would be complying even if you did place them they are nor is that the only means by which you could determine to place them
00:22:07 which you could determine to place them there neither is it in my opinion and specifically diagram 33 inception I'm fit for purpose as a method for
00:22:18 fit for purpose as a method for determining where to place cavity barrows i would oversee again I'd always seek specialist input in order to determine that particularly that this scenario fell outside that described in
00:22:29 scenario fell outside that described in section 9 and diagram 33 which in this case it did in my view do you accept or
00:22:40 case it did in my view do you accept or perhaps better put is it your experience that an architect on a project such as this prior to Novation should should have taken the lead in sorting out
00:22:51 have taken the lead in sorting out compliance issues before the full plans application was submitted to our bkc Building Control I believe that it's even the people involved in that did
00:23:05 even the people involved in that did believe that what they proposed was compliant you believe that now all you believe that at the time I believe that's at the time and I believe that they believe that at the time now did it
00:23:17 they believe that at the time now did it surprise you when the question of whether our s5000 was a material of limited combust ability arose as we've seen in this email chain in the March of 2015
00:23:29 2015 did it surprise you that that hadn't been sorted out and that question answered prior to the full plans application being submitted to our bkc Building Control in the distant past but
00:23:41 Building Control in the distant past but I think I think that they should using rs.5000 other than their equivalent of Fr 5000 I believe that they did believe that was
00:23:53 believe that they did believe that was compliant and the basis of your belief is is what the conversation say I had a
00:24:04 is is what the conversation say I had a handle vermin and the conversations I had when I checked the RS 5000 with briefs I mean he he he to my mind was of
00:24:15 briefs I mean he he he to my mind was of the opinion that this scheme and what had been poised was compliant I don't think I necessarily need you to doubt that but then I checked with ixora with the the new product revealing of the
00:24:29 the the new product revealing of the same product whatever you want to call it that it was compliant and now's my understanding little boys you see given that you say you'd had this conversations with Bruce Ames of hand over about the compliance of the of the
00:24:42 over about the compliance of the of the Celotex or of the installation at that stage my question is really whether it came as a surprise to you to discover in March 2015 some nine or eight months
00:24:53 March 2015 some nine or eight months later that the question of whether or not the Celotex rs.5000 was of limited combustibility had arisen did not come as a surprise to
00:25:05 had arisen did not come as a surprise to you given that you thought it was something that had been resolved already
00:25:13 so I'm not sure if I understand the question well you told us I think and correct me if this is wrong that you during your handover discussions with Bruce he had led you to believe that the
00:25:25 Bruce he had led you to believe that the specification of what was then FR 5,000 Celotex as the insulation product for the US on Greenville tower had been compliant
00:25:33 compliant yes that's what EULA told us my question then is did it not come as a surprise to you to learn in March 2015 some eight or so months after the
00:25:44 some eight or so months after the handover from Bruce aimed to discover that there was there were there were questions around whether the Celotex material was compliant or not by I never saw them there were questions are simply
00:25:56 saw them there were questions are simply seeking to verify that what Harley were proposing was compliant why because it was a different title product when did
00:26:09 was a different title product when did you decide you discovered that it was a different kind of product no different title to the product whose rs.5000 and you discovered that it was rs.5000 I
00:26:20 you discovered that it was rs.5000 I thought you'd said in September which is now yes doesn't 14 to the when it was forwarded to me by Daniel it's when I
00:26:33 forwarded to me by Daniel it's when I forwarded it to solver yes yes yes say did it not come as a surprise to you to discover that when Bruce Hanes had told you that it was a compliant material that matter had not been actually got to
00:26:45 that matter had not been actually got to the bottom of but I don't think that's what happened of what I'm saying right I mean
00:26:54 at the tender stage at the stage of the employer's requirements there was a product and they're there for five thousand I understood please understood
00:27:05 thousand I understood please understood did that that product was compliant when the specialist subcontractors pinned together his package of information
00:27:17 together his package of information he brought forward the datasheet for this product RS 5000 which for all intents and purposes seemed to be reasonably similar but then this was
00:27:31 reasonably similar but then this was forwarded to sova to check for compliance but this is what happened this is how it's here I see so far as you were concerned this
00:27:42 I see so far as you were concerned this was quite a new issue and had to be resolved whose only new issue in as much as the product name was different now
00:27:54 as the product name was different now can I ask you to go to your witness statement and look at paragraph 102 please that's a page 38 you say there that on the 23rd of January 2015 at 50
00:28:11 that on the 23rd of January 2015 at 50 36 Kevin Lam Harley copied me into an email to Simon Lawrence Ryden and said please find attached revised typical windows showing reduced quantity of
00:28:22 windows showing reduced quantity of trickle vents etc you see that yep and then at 102 I'm so sorry I've actually
00:28:34 then at 102 I'm so sorry I've actually read the wrong paragraph it's a different email he says please find attached specification on the upper 20 floors for clarity stroke approval which will add to this as we reassure the lower elements and you see that yes and
00:28:47 lower elements and you see that yes and you say there that he attached the first version of a Harley drawing see 105 nine 100 title specifications for Harley specification okay yeah and then in
00:28:59 specification okay yeah and then in paragraph 103 you say Harley prepared the Harley specification to identify the materials it specified for the detailed design of the cladding system now let's just have a look at the
00:29:13 system now let's just have a look at the specification if we can please this is
00:29:19 se a zero zero zero zero 3 o5 9 just a look at the that's what does the look at the version that was sent to you on the
00:29:32 the version that was sent to you on the 23rd of January 2015 and if you can see the date at the bottom it's date of the 15th of January 2015
00:29:43 15th of January 2015 issued for approval and if you look to the left there's a box or set of boxes with revisions in it there's no revision number in there if you just move across to that and then if you look at the top
00:29:54 to that and then if you look at the top of the page it says specification notes is that the document that he attached to the first of those lifts to the to the email of the 23rd of January which I referred to in your statement to be here
00:30:08 referred to in your statement to be here right now if you go to paragraph 106 of your statement which is on page 39 you sell the 26th of January I email Harley
00:30:21 sell the 26th of January I email Harley regarding the three drawings they sent on the 23rd of January stating please see attachments sorry please see attached comments and I attached marked up drawings see that yes
00:30:36 and can we take it from what you say there that you had read the specification that mr. Lam had sent you on the 23rd of January and had commented on it do you remember that we can look
00:30:49 on it do you remember that we can look at a document in a moment but I just want to get your recollection first and I commented on that per minute yes from the purposes we've already set for the purposes of architectural turn yes yes okay okay well let's look at that
00:31:00 okay okay well let's look at that it's se a 0 0 0 0 3 0 6 0 and on the
00:31:13 it's se a 0 0 0 0 3 0 6 0 and on the first page of that we can see the specification notes very similar to what I've just shown you but this time it's got a studio a architects read stamp on it and some red handwriting and I'm
00:31:24 it and some red handwriting and I'm assuming that red handwriting is yours yes yes and you can see that you've marked it B so you can for conforms to design intent subject to comments you
00:31:37 design intent subject to comments you see that mmm now have a look at it if we have it up the page please and we can shrink it that perfect if we could have a quick look at that or a slow look at it
00:31:48 look at that or a slow look at it doesn't matter you can't see anywhere in there where the insulation for use within the over cladding system is specified is it can we you can't see that no no did you notice that at the
00:32:02 that no no did you notice that at the time but the insulation had already been specified back in the 17th 18th correspondence in indeed and that's that
00:32:16 correspondence in indeed and that's that was my next question having spent two days engaged in discussions 17th and 18th of September 2014 that we spent quite a lot of time on this morning you know this afternoon mr. Croft having spent time on that did
00:32:29 mr. Croft having spent time on that did it not surprise you to see the Hartley's specification when he came in January 2015
00:32:34 2015 did not refer to the insulation for use within the over cladding system well not
00:32:45 within the over cladding system well not necessarily because he had been covered out from that his previous correspondence I mean they might have added it into this sheet yes and they
00:32:58 added it into this sheet yes and they didn't as we can see it did my question is did you notice that they hadn't Mars well I know I keep seeing this post commenting this from the purpose of architecture yes I lost more time when
00:33:11 architecture yes I lost more time when you receive this document and you commented on it did you notice the fact that the insulation type was not specified I don't recall all right now
00:33:23 specified I don't recall all right now you made a comment in respect to the possible need for window restrictors you can see that TBC by client yeah and you stand the specification status be conforms to design intent subject to
00:33:36 conforms to design intent subject to incorporation your comments on what basis were you satisfied that the specification conformed with a design intent where there was no reference at all to the insulation for use in the
00:33:47 all to the insulation for use in the cladding envelope
00:34:05 well I suppose that said before had been covered separately but I don't know if I did mess only think about it in those terms on the shoe was the omission of
00:34:16 terms on the shoe was the omission of any material for insulation not a manifest error which any architect in your position should have picked up not
00:34:28 your position should have picked up not necessarily having this specification she is not complete in any sense it's not complete for for the whole building I mean this was revised several times in
00:34:39 I mean this was revised several times in these studies extended to cover all the cladding across the building it was and we'll look at some later editions of it
00:34:51 we'll look at some later editions of it but at this point having had two days of discussions on on the insulation material was it not manifest and manifest to you and manifest to any
00:35:03 manifest to you and manifest to any architect on this type of project that the insulation was missing but it wasn't missing had been covered separately in
00:35:15 missing had been covered separately in an email but not in a formal specification document such as this which you had stamped yes but is this a formal specification it's not really it's a sheep that relates to drawings well let's move on in time if you go to
00:35:28 well let's move on in time if you go to the next edition of this this is the one of the 25th of March 2015 it's se a zero zero zero zero three one eight zero page one I mean it just
00:35:42 eight zero page one I mean it just mentioned it actually even the title itself says specification knots what did you take from that I start the full specification is it did you think that
00:35:53 specification is it did you think that at the time probably I don't know what possibly well I was wondering why you make the point then I mean you say it's just no I'm making a medley time although I'm making ask you I'm at the time mr. Crawford yeah you saw the word
00:36:04 time mr. Crawford yeah you saw the word note did you think that there would be something else which would come from Harley which would more formally and completely set out what it was they had to do I would read this because they retire to a let's say specification
00:36:16 retire to a let's say specification that it was specifically that notes refering notes that were used against the drying so for example cladding are two three t part two and you relate it
00:36:28 two three t part two and you relate it to what's in the drying I see so it's but one thing is it's not completely specification and in the sense that I think you're referring to write it you
00:36:40 think you're referring to write it you say it's not complete again we see there's no reference to the insulation for use within the over cladding system but this time you've marked you've marked it with an a conforms to design
00:36:53 marked it with an a conforms to design intent and that's on the 27th of March 2015 so we can see in the stamp so question again did you notice at the
00:37:04 question again did you notice at the time that the specification for the insulation was missing from this document I can't comment about standby mother comments which is this sheet I
00:37:16 mother comments which is this sheet I wouldn't consider this sheet as a specification or a complete specification I've seen this sheet as precisely what it says specification notes notes on specification to be right
00:37:29 notes notes on specification to be right in conjunction with the drawings as it was issued with and in conjunction with the drawings well we'll come to one or two drawings in a moment it's just completely run if you go to the final
00:37:43 completely run if you go to the final specification we have and there are one or two others in the intervening period mr. Crawford say forgive me if you want to get back to any of those but this is se a zero zero zero zero three three
00:37:54 se a zero zero zero zero three three eight seven dated the 28th of January 2016
00:38:03 and we can see the date' on that by looking at the box at the bottom which
00:38:14 looking at the box at the bottom which was there and is now not there if you if mister operator co you could move to the left and the DAC thank you you can see the box at the bottom with the revisions going from err the bottom up to I at the top you can see this is
00:38:25 up to I at the top you can see this is revision I 28th of January 2016 you see that yes and then if we can just pan out a bit you that we don't see a stamp from
00:38:38 a bit you that we don't see a stamp from you on that but I think you say in your statement that it was provided to you can you confirm that and if that's why I
00:38:49 can you confirm that and if that's why I said then yeah that doesn't be the case
00:38:58 yes
00:39:04 in it just feel Nate you do its paragraph its paragraph one three six we don't need to turn it up just to be clear for your recollection you say you
00:39:15 clear for your recollection you say you didn't know it with status you say you've stamped it but didn't mark the status but do you believe to mark it stay to say because I had no further comments to make now can I just show you
00:39:28 comments to make now can I just show you some document some some drawings in fact actually from the pep from your witness statement if you go to paragraph 136 this is probably a quicker way of doing
00:39:40 this is probably a quicker way of doing this paragraph 136 on page 46 of your statement you can see there you refer to the Harley spec updated 28th of January
00:39:51 the Harley spec updated 28th of January 2016 which is what we were just looking at mr. crawford and you say on the 28th of January 2016 Kevin lamb Harley copied me into an email to Stephen Blake riding and and attached drawings for the internal
00:40:03 attached drawings for the internal atrium screen for final approvals etc etc and then four lines up from the bottom of that paragraph you say I replied later that day attaching marked
00:40:14 replied later that day attaching marked up drawings including revision I of the Harley specification we've just seen which I had stamped but did not mark status although I believe I'd intended to mark it today to say because I had no further comments to make now and if we
00:40:31 further comments to make now and if we look at se a zero zero zero zero three three eight seven
00:40:40 which is the document revision I to which you refer in paragraph 136 there's
00:40:56 which you refer in paragraph 136 there's no stamp on that again it's the same question there's no reference in that document to the installation for use in
00:41:07 document to the installation for use in the building envelope and I mean take it from me that there isn't even though the document has come on a long way since its version originally in January 2015 my question is did you notice in January
00:41:20 my question is did you notice in January 2016 that the insulation for use in the building envelope was not specified
00:41:29 comment is just the same as before right so is the answer no you didn't is as I
00:41:44 so is the answer no you didn't is as I said before the the installation had been established within our spec and then the proposal for if you like the
00:41:57 equivalent had been raised which was the rs.5000 product you know we may or may not believe to have been essentially the same as the fr 5,000 product and this
00:42:10 same as the fr 5,000 product and this sheet is not full specification this specification no it's not to music clear weather Harley were wherever required to produce a full specification or for what
00:42:22 produce a full specification or for what the terms of that full specification where for example with a lion spec spec notes is there a reason why you never went back to ridin or to Harley and say
00:42:35 went back to ridin or to Harley and say to them look I've had a whole load of these specification notes from you for about a year now none of them refers to rs.5000 can you please put that in
00:42:50 no it didn't occur to me to go back you know given the importance of the
00:43:01 know given the importance of the insulation product and the questions that had arisen about it in the September of 2014 my question is why why didn't it occur to you because it already been established in 2014 what it was so you
00:43:14 established in 2014 what it was so you were content at the time were you to leave it leave this question or the identity of the of the insulation product as as something contained in email traffic as far as the going into a
00:43:28 email traffic as far as the going into a document which had been built up by a series of revisions you see such as we see here
00:43:37 see in more traffic but I think he was pretty explicit what it was and also the the checking was pretty explicit so to
00:43:48 the checking was pretty explicit so to me if someone was coming into this project at this point from the outside and had no idea about discussions or
00:44:00 and had no idea about discussions or anything that had occurred where would that person look to find out what specification or what product was to be used for the insulation at grünfeld
00:44:12 used for the insulation at grünfeld tower and the data sheet was provided by the specialists and contractor and what
00:44:26 the specialists and contractor and what would tell them to look for that because all that information would be held together and by writing and ourselves for that matter where you were where let
00:44:38 for that matter where you were where let me tell change tack slightly different product and it's going to ask you one or two questions about kingspan cool firm k 15 because we mentioned it before did you were you familiar with that product kingspan cool therm k 15 I in July
00:44:52 kingspan cool therm k 15 I in July August 2014 and you off the product you knew of it did you know that it was a phenolic product possibly my other mitten
00:45:01 mitten I couldn't see it definitively at that point were you aware that kingspan cool firm K 15 had been used as an insulation product on the con gruntal tower no okay do you know can you remember when you
00:45:13 do you know can you remember when you first became aware of that after the fire
00:45:25 and I'm going to turn to a cm in a moment before I do I have one or two questions left on insulation on the calc
00:45:37 questions left on insulation on the calc project now studio II as you told us were the architect on the calc project and specifically specifically the Kensington Aldridge Academy yes yes yes were you involved in the design of the
00:45:50 were you involved in the design of the facade for the Kensington Aldridge Academy at a Dewar's a senior architect working on that who did the bulk of the work on that the
00:46:02 who did the bulk of the work on that the senior architect at Studio E yes who was that Marcus Kiefer Marcus Keith and also I forget the name
00:46:14 Marcus Keith and also I forget the name of the individual who did the GA drawings for the SADS Lucas Lucas brand okay
00:46:22 okay were you involved in the selection of the materials that form the climbing the cladding system on the building I didn't do the specification or not you didn't
00:46:35 do the specification or not you didn't do the specifications can you assist us and maybe you can't with what the facade on the Kensington Aldridge Academy is comprised of a large chunk of it is a
00:46:49 comprised of a large chunk of it is a stick system controlling system shook OS is tuple type and cut and walling system that was I mean contractures MTW for
00:47:01 that was I mean contractures MTW for that there's portions of brickwork at the lower levels
00:47:10 and with Windows inset into those and small amount of curtain mulling around the sports hall a small amount of green
00:47:24 the sports hall a small amount of green screen mulling around the sports all right I see okay and was there any insulation used in the cut in the cladding system in the main cladding system and the curtain walling
00:47:35 cladding system and the curtain walling it was a rock wall rock wall okay and and rock wall is for those who perhaps don't know that's non combustible isn't it it's a minute yes yes but all intents
00:47:51 it it's a minute yes yes but all intents and purposes of them yes intents and purposes do you know why a non combustible mineral insulation came to be used on the Kensington Aldridge Academy not least given that it was not
00:48:03 Academy not least given that it was not a building in excess of 80 meters in height well there wasn't just an rock wall used them cancer and Academy what else was there I believe this phenolic
00:48:15 else was there I believe this phenolic and PIR within the brick construction right
00:48:22 and one of the questions is whether the choice of the use of non combustible mineral insulation was related to the choice to use ACM panels on that
00:48:35 choice to use ACM panels on that building sorry what say that again yes was was the choice of mineral wool as the insulation material related in any way to the choice to use ACM panels on
00:48:47 way to the choice to use ACM panels on that building the ECM panels won't use them that building well they aren't there they had a combustible styrofoam insulation does that not don't ring a
00:48:59 insulation does that not don't ring a bell with you which building you talking about your count yes okay I wasn't tall enough that I can take this shortly were
00:49:11 enough that I can take this shortly were you aware of what the composite elements of the cladding system were at kaa I wouldn't be without chatting well perhaps I can show you a document I worked in me to take turn on on this RB
00:49:22 worked in me to take turn on on this RB k zero zero zero to nine nine three five at page three
00:49:46 I'm so sorry I think it's place we're looking it paid for actually and if you go to the first this is the executive summary of and I'll just say what this document is this is a fire safety review
00:49:58 document is this is a fire safety review done by FDS consult for in June 2018 for the Kensington Aldridge Academy and if you go to page four under the executive summary that's it you concede that under
00:50:09 summary that's it you concede that under the first bullet point it says the external walls of the KA building a covered with an aluminium composite material ACM panels which have a core of combustible styrofoam insulation the
00:50:20 combustible styrofoam insulation the type of ACM panel used on kaa is different to that used on Grenville Tower and except for a few small isolated areas is backed up with non combustible mineral insulation now that's what it says there first of all
00:50:31 that's what it says there first of all did you did you know that is that something you're familiar with I wouldn't have been without checking without checking what some underlying this back spec I see okay
00:50:44 can you help me then just with one question was the choice to use a non combustible non combustible mineral insulation related to the choice to use
00:50:55 insulation related to the choice to use ACM paddles with a combustible core I can't say this is Jen we're going to come next to a different topic we've
00:51:06 come next to a different topic we've regained fifty five minutes may be appropriate in our second break the next topic is likely to take about three quarters of an hour ten minutes and come
00:51:26 quarters of an hour ten minutes and come back at five four three please
00:51:36 all right five four three please
01:01:22 yes could you ask mr. Crawford to come back please
01:01:40 all right yes good thank you yes mr. mr. Crawford we're now going to turn to a different topic namely ACM alright so if we've put insulation aside now at the
01:01:52 we've put insulation aside now at the time of working on the grenfell project indeed at any time you were involved in it were you aware of previous fires involving external cladding facades on high-rise residential buildings no so we
01:02:06 high-rise residential buildings no so we you know you weren't aware of a fire in 1991 at knowsley heights or 1999 gone at court were you aware of the lack of house fire in Southwark in 2009 like an
01:02:20 house fire in Southwark in 2009 like an old house fire yes I doubt the name though I was not aware it was connected to a fire cific fire right so what about
01:02:32 to a fire cific fire right so what about fires in the UAE or dubai in 2012 to 13 inches and of 2015 no no can I ask you
01:02:45 inches and of 2015 no no can I ask you to get your witness statement please paragraph 53 which is a to page 23 and you say there I was not involved in the
01:02:56 you say there I was not involved in the development of the cladding design prior to writings appointment however I understand that Bruce say in studio he addresses this aspect of the design in detail of his witness statement now
01:03:07 detail of his witness statement now that's what you say there by July 2014 so when you started to work on the grenfell tower project or perhaps August do you remember the Bruce owns had
01:03:21 do you remember the Bruce owns had suggest submitted an application to our bkc planning department for their approval or face fixed ACM panels just to be clear when I say Bruce stones actually mean through IBI Taylor Young
01:03:34 actually mean through IBI Taylor Young the planning consultants durab did you know that at the time I was aware of the tower mock-up had been done as part of discharging that issue I think
01:03:46 discharging that issue I think right okay well let's look at a document if you can go to our yd zero zero zero one zero seven eight nine please this is
01:03:58 one zero seven eight nine please this is a document from ibi tailee young to saris camel at planning at our b kc date
01:04:09 saris camel at planning at our b kc date of the 29th of june 2014 and it's entitled grenfell tower planning application reference discharge of conditions three and four and there are
01:04:20 conditions three and four and there are some details there dude this is just the first page of it but dude do you remember looking at this document or seeing it as part of your hand over or preparation for coming into the project I don't pacifically recall but it
01:04:33 I don't pacifically recall but it doesn't mean they're don't it doesn't mean that you didn't or it can you can you turn please to page two of this document you can see under paragraph
01:04:44 document you can see under paragraph three rain screen aluminium composite material ACM brushed aluminium and then there's an email address for Alcoa
01:04:55 there's an email address for Alcoa otherwise known as our Koenig and then stainless steel rivets and then under under five aluminium rain screen cassette that's a different part of the
01:05:06 cassette that's a different part of the building now do you remember seeing a document like this which contained that specification in it no no did you have
01:05:17 specification in it no no did you have any discussion with Bruce owns me beside this document when you came into the project about what the rain screen should consist of I think it's
01:05:32 should consist of I think it's inevitable that there will have been some sort of discussion back can't remember specific you can't remember do we take it from that that you therefore did not have any involvement in the
01:05:43 did not have any involvement in the decision to change from a zinc rain screen to an aluminium composite I didn't have an involvement right did you
01:05:55 didn't have an involvement right did you yourself ever take any steps to consider for yourself whether a cm was a suitable material for the purposes of compliance with Part B for of the building regulations my knowledge of a cm is that
01:06:13 regulations my knowledge of a cm is that it's poison it's been around for a while widely used I I didn't view is any different from standard aluminium panel
01:06:28 different from standard aluminium panel so is the answer to my question no but that's because it was widely used and no different from an aluminium standard aluminium panel or we'll come to that hi
01:06:40 aluminium panel or we'll come to that hi I've no concept that it was any different from a standard at home in in poem what do you mean by a standard aluminium panel normally a rain screen let's say for example the rain screen
01:06:52 let's say for example the rain screen put up on kaa and the sports halls it's usually of 1.2 to mil thick aluminium pressed panel with or without a core
01:07:06 pressed panel with or without a core without the core without a core so just so I understand your evidence you didn't think that an ACM and
01:07:18 you didn't think that an ACM and aluminium composite panel was different from a panel alminia panel without a core correct just thought it's a thin laminated panel biscuit
01:07:30 laminated panel biscuit I see so do we take it from that that you never took any steps to investigate whether ACM which of course by
01:07:41 whether ACM which of course by definition has a composite core it is a composite material with a core was different from what you call the standard not necessarily call right
01:07:55 did you investigate what fire classification the ACM proposed for grenfell had I don't Pacific Lee
01:08:08 grenfell had I don't Pacific Lee remember doing so--but I know we had the BBS difficult on fire when in fact if I had done lieutenant I'd have understood it is complying on the basis of being national class you
01:08:20 the basis of being national class you know right well that takes me to the next question you say you you had the BBA certificate on file do you remember
01:08:31 BBA certificate on file do you remember when you first saw the BBA certificate well though it's obviously pulled out after the event but whether I lived had it before then I can finish everything
01:08:44 it before then I can finish everything did you look at the BBA certificate when you came into the project or at any time thereafter just to be clear this is the BBA certificate for the rain airborne PE 55 yeah I think the cold definitive you
01:08:59 55 yeah I think the cold definitive you couldn't recall definitively let's uh I can't I just say I can't recall but the reason I say that is that we sleep Bruce introduced the project and assured me
01:09:10 introduced the project and assured me things may or may not have shown me that it's part of showing information but I just don't recall okay at the point of coming into the project and am i right in thinking that you never yourself used
01:09:22 in thinking that you never yourself used ACM on any of your projects as far as my way
01:09:25 way as far as my way I've never personally specified oh so you're doing the best you can with your recollection would you do you think have been interested to look at the BBA certificate given that this was a product which was new to you
01:09:38 this was a product which was new to you possibly except if my understanding well possibly from understanding was that it was something different than just a normal Romanian panel well let's look at
01:09:49 normal Romanian panel well let's look at the certificate itself this is an SE a zero zero zero zero zero five one six I will see if it jogs a recollection what I should just say mr. Grover but I don't
01:10:01 I should just say mr. Grover but I don't want to do is to show you this document and ask you questions about it if you don't have any recollection of seeing it at the time so I'm not using this exercise as an opportunity for you to make points about the document I just
01:10:13 make points about the document I just want to get your recollection of your thoughts at the time and if I didn't read it or didn't think about it then we'll move on if you go please to the first page of this you can see this is
01:10:24 first page of this you can see this is the BBA certificate and it's got a sort of red white and blue triangle at the top and a picture of a building does that look familiar to you it's familiar
01:10:35 that look familiar to you it's familiar to me but wasn't it because of it's been looked at post-event I see so you don't recall seeing something like that at the time when you I don't have a handover
01:10:46 time when you I don't have a handover for Bruce Ames no right okay
01:10:53 in which case if you don't if that doesn't jog your recollection and seeing it at the time I went I won't ask you about it look let's go to se a zero zero
01:11:04 about it look let's go to se a zero zero zero one three zero four nine this is an email exchange between you and mr.
01:11:17 email exchange between you and mr. Ashton of X over in March 2015 and this is on the 31st of March and it's part of a longer chain of emails that we're going to come back to you later in your
01:11:28 going to come back to you later in your evidence but I just want to ask you to look at page one and the second email down on that page see that it's an email where mr. Ashton writes to yield at 1332
01:11:42 where mr. Ashton writes to yield at 1332 on that day and the context of this so that I can just explain it to you is is the fire resistance of cavity barriers
01:11:58 the fire resistance of cavity barriers and or fire stops and the title to the email as you can see is grenfell tower fire stopping I don't to ask you about that precise topic at the moment because
01:12:10 that precise topic at the moment because we'll come back to it but if you look at mr. Ashton's email to you 13:32 he says Neal this isn't something that would necessarily form part of a fire safety
01:12:22 necessarily form part of a fire safety strategy for a building therefore it would not have been dealt with in the fire safety strategy for this building I agree with Ben K that's a reference to someone called Ricky K at side arrives
01:12:33 someone called Ricky K at side arrives we'll come back to him later I believe that a cavity barrier is all that is required in this application even if we were to agree with our BK c it's difficult to see how a fast stop stay in place in the event of a fire where
01:12:44 place in the event of a fire where external flaming occurred as this would cause the zinc cladding to fail kind regards Terry I've read that to you because I want to show you your response and that's what I want to ask you about at the top of this chain you reply to
01:12:55 at the top of this chain you reply to mr. Ashton at 1412 on that day and you say in the first line metal cladding always burns and falls off
01:13:05 off hence fire stopping is usually just to the back of the cladding line thanks to this confirmation anyway now I just wanna focus on the words metal cladding always burns and falls off were you saying there that there was no point
01:13:17 you saying there that there was no point in installing cavity barriers behind the ACM rain screen because in the event of an external fire there would be nothing to hold them in place to seal the cavity a fat fire stopping you mean well good
01:13:31 a fat fire stopping you mean well good that that's specifically what that's referring to holding fire stopping in place kappa cavity barrier would be kept in place right then your words metal
01:13:44 in place right then your words metal cladding always burns and falls off looking at that it was that your experience I think d2t still with that within my witness you have and I'll come
01:13:55 within my witness you have and I'll come to that yeah before we get to that there's a choice of what's he should have been melts and feels and falls off but that was my expense and the reference specifically was to previous
01:14:08 reference specifically was to previous projects where I'd been working with and the best way to explain it is in a building you you have compartments and see of the facade which can be anything
01:14:21 see of the facade which can be anything from cotton walling or brick wherever it is but the compartment which you know in this case would be an apartment you have compartment walls that lines of fire resistance and the external next down a
01:14:34 resistance and the external next down a wall generally isn't a line of fire resistance unless you have a boundary issue so what happens in if you ever developed fires now then the the the
01:14:48 developed fires now then the the the compartment itself is protected but the the facade will fail buckle melt fall off and the Pacific reference I made to
01:15:00 off and the Pacific reference I made to in the statement was we had been working in a project and it was made clear to me that that's what happened and I think sometimes it's misconstrued people think there's a requirement for some level of
01:15:12 there's a requirement for some level of fire resistance next on wall and there isn't and basically in a farce now they fail except where you've got the relative boundary issue and so yeah that's that's
01:15:26 boundary issue and so yeah that's that's now you said in your statement that your comment here was based on advice that was given to you by a fire engineer on your put on a project in Manchester yeah 2004 yeah that that's right is it yes I
01:15:39 2004 yeah that that's right is it yes I mean I remembered that specifically because I remember sitting up there isn't a villian and he got a bit exasperated with me because those who's an office building and new strategies
01:15:51 an office building and new strategies for we had a boundary show a very closed boundary issue that it just failed and you know if you think of the typicals of office block we have our iminium curtain
01:16:02 office block we have our iminium curtain walling and glass the glass will pop our minim will mount the brackets holding it will melt they'll feel and so just
01:16:13 will melt they'll feel and so just basically collapses in the fashion aisle I mean there's ways to deal with that you see some of the office buildings spread the sitting if you do have proximity issue then you can use local
01:16:25 proximity issue then you can use local dosing systems and so on but basically is this notion that there is no fire resistance with the next down a wall jasmine
01:16:34 jasmine so does it follow from that that although you made this remark in 2015 March 2015 the fact that medal cut metal cladding burns or as you would say
01:16:45 cladding burns or as you would say perhaps melts yeah and falls off was something that you had known since the start of your involvement on the greenfield project metal cladding melts in fields and developed fire scenario
01:16:57 in fields and developed fire scenario yes so you'd always known that yeah it's my question yes [Applause]
01:17:07 was it ever drawn to your attention by anybody that composite rainscreen material like ACM which has got a polyethylene core can contribute to
01:17:18 polyethylene core can contribute to external flame spread no do you agree that if rainscreen product burn or melt then they don't adequately resist fire spread spread a fire over the external
01:17:29 spread spread a fire over the external walls I can see what you're referencing but you I don't think you can say that
01:17:43 but you I don't think you can say that because then you'd have to say effectively every glass now even in Turin in the city this is non-compliant well you might or might not say that that's that is it maybe but do you agree
01:17:55 that's that is it maybe but do you agree that if a rainscreen product burns all melts in the way that you are referring to here in this email then it does not adequately resist the spread of fire over the external wall you know it it
01:18:08 over the external wall you know it it does add too quickly it was just the spread of fire across that stone wall I stood to find in before now you say that now is that something that you've
01:18:19 now is that something that you've actually turned your mind to at the time I say at the time to be specific Bob Bob yes inland from July August 2014 well yes I see the product is to be
01:18:33 well yes I see the product is to be compliant with tough tough national class seal if I had national Class C then it was meeting that requirement even though always burns and falls off in a developed fire
01:18:48 what do you it will eventually melt and feel it'll feel and melt say I'm just
01:19:00 feel it'll feel and melt say I'm just struggling to see if it will eventually fail and melt then how could it adequately resist the spread of fire over the external wall because it meets
01:19:13 over the external wall because it meets the requirement but didn't I mean with the kind of question you're asking is a bit like saying to meet that requirement every stone of wall would have to have a
01:19:24 every stone of wall would have to have a fire resistance and they don't they were only required to meet the standards set out in before which it does
01:19:36 did you ever raise with anybody whether Harley or riding or with any students to do a your experience as identified in this email that metal cladding always
01:19:49 this email that metal cladding always burns and falls off or as you would say melts and falls off yes distinction melts feels and mounts yes who did you raise that with oh sorry does that raise it but yes my question is was was my
01:20:01 it but yes my question is was was my question was did you ever raise with anybody with a Harley alright and always all within studio II your experience has identified in this email that metal cladding always burns mats and falls off
01:20:12 cladding always burns mats and falls off I think is self-evident I think most people in the industry would realize that uh our minim panel at some point but we'd fail I mean our many mething melt about six hundred and fifty degrees
01:20:24 melt about six hundred and fifty degrees it doesn't you know it's instantaneous but it will feel the same way glass will fail
01:20:31 fail our glass will feel long before thou am in him but but ultimately it fails and ultimately it mouths I'm a little concerned that we may be slightly across purposes here if you envisage a fire in
01:20:45 purposes here if you envisage a fire in a compartment denial but only building when I say a tall building your understanding is that the that a metal cladding will fail in in
01:20:57 that a metal cladding will fail in in way of the fire is that what you're saying or the fire will propagate across the cladding to other stories and other parts of the building because it seems to me there's a distinction there which we nice I see what you're saying have no
01:21:11 we nice I see what you're saying have no he'll he'll fail where ultimately melt and feel where it's exposed yeah it wouldn't have been actively propagated
01:21:22 wouldn't have been actively propagated no I mean that that propagation would be tested by the being compliant to the national class for example of being the
01:21:34 national class for example of being the the failure of the cladding as you understood it will depend on the temperature reached by the fire behind yes
01:21:41 yes but the sort of cladding you have in mind I think you would not expect a support combustion itself Pratt
01:21:53 thank you now looking back at this email
01:22:01 as we can see from the second email down from the top of this page which is from Terry Ashton to you mr. Crawford 31st of
01:22:12 Terry Ashton to you mr. Crawford 31st of March you can see in the last sentence that mr. Ashton refers to Zink cladding do you see yes did you spot when you received this email from mr. Ashton that
01:22:23 received this email from mr. Ashton that he was referring to zinc cladding I think I actually sent money more after was incorrect in saying I think I was a cm um well we may need to look at that but but were you surprised that mr.
01:22:35 but but were you surprised that mr. Ashton still thought that the cladding was zinc at this stage I don't know i mean the the vm zinc that was shown in the drawing sentiment was effectively
01:22:47 the drawing sentiment was effectively the same as ECM we'd seen some of the drawings earlier on did it occur to you that mr. Ashton had got the notion that the cladding was zinc from the section drawings that Harley and you that Harley
01:23:00 drawings that Harley and you that Harley but that Harley had sent you and you'd sent mr. Ashton in September 2014 that we looked at earlier today it's possible
01:23:11 we looked at earlier today it's possible he was referencing something is starring yes
01:23:20 now we are at the end of March 2015 here did you realize that construction had started at this point and in fact was reasonably well advanced construction
01:23:32 reasonably well advanced construction generally are in the cladding construction will on the cladding system in fact yes I think the mass climbers were up yes you can see the finish for
01:23:46 were up yes you can see the finish for you at this stage did you think to yourself that you should check where x over had got to with the promised
01:23:59 over had got to with the promised analysis of fire spread external fire spread as a result of the proposed over cladding no I think I said Stacy down I
01:24:12 cladding no I think I said Stacy down I mean my understanding was that we understood what was proposed and the front of the opinion that hose it was compliant and and I saw no reason to go
01:24:24 compliant and and I saw no reason to go beyond that well you we now have you now at this point had on any of you clarity about what precise product was being used in the rain screen namely renob on PE 55
01:24:35 the rain screen namely renob on PE 55 ACM yeah did it occur to you at this stage at the latest to go back to x over and say well now you know what the insulation is now you know what the rain screen material is going to be can we
01:24:47 screen material is going to be can we please have your analysis of the effect of these materials I'd I don't sell fast bread and that's all roll call
01:25:01 bread and that's all roll call don't recall we know that you didn't and I suppose my question is what why didn't you I think I corrected him on zinc says he was a cm and my understanding was
01:25:13 he was a cm and my understanding was that did did he was happy that what we proposed was compliant from before with
01:25:25 proposed was compliant from before with regard to the Pacific's question and the reports no I didn't think of a burn report now we we know from the previous report that Xavier had said in the in
01:25:36 report that Xavier had said in the in the su3 of the FSS the outline fire safety strategy that there would be no adverse effect on external fire spread but that would be subject to a confirmation by an analysis in a future
01:25:47 confirmation by an analysis in a future report was this not the moment to ask him ask mr. Ashton to update X overs analysis based on the use of a cm given
01:25:58 analysis based on the use of a cm given at least the change in the material to a cm and the fact that you knew that it would burn in a fire or melt I phoned you about DCM from before
01:26:22 yes we do not have the promise report from him so I just lost my question that's one more time and in a slightly different way was now not the time at last to go back to X over and say look
01:26:33 last to go back to X over and say look you promised a confirmation in a future report now you know what materials were using can we please have it it could have been yes so why didn't you because
01:26:45 have been yes so why didn't you because I understood that he understood that what we were doing was compliant but you hadn't had that in a formal written report signed by xover had you know so
01:26:58 report signed by xover had you know so was that not something that you as a conscientious architect would have wanted to have had from them with a signature for the file not least because they promised it well I suppose I may
01:27:10 they promised it well I suppose I may have still been expecting you is that something well if you were expecting it why didn't you pursue it well I can't recall without it or not but we can't
01:27:23 recall without it or not but we can't see any documents no what you're saying is you didn't you can see the final report that doesn't mean that I didn't ask for it or ask for it repeatedly or that they didn't intend to produce it and not produce it all that means is
01:27:35 and not produce it all that means is they didn't ultimately produce it yes and my question is I understand your question your question is did I ask them categorically at that time and I've told you I don't recall all right cavity
01:27:47 you I don't recall all right cavity barriers I'm going to ask you some questions about the design of cavity barriers in the facade and we've looked at this a little bit before in some of the questions on the email strings that
01:27:58 the questions on the email strings that we've seen mr. chairman this is a short topic but if we're going to get a second break this afternoon perhaps now's the time to have it or I can cover it off
01:28:11 time to have it or I can cover it off and then we can move on to the next topic you've got quite a few more questions I have oh yes many more but not on this specific topic it's probably more sensible if we break now well do
01:28:22 more sensible if we break now well do you do you feel you need another break now mr. Crawford it's Polly illogical point isn't it well it's matter for you whether you feel you need a break or not yeah take a
01:28:34 feel you need a break or not yeah take a break you'd like a break yes right before you do can I just ask you a question rising out of just a million questions on ACM panels you've described
01:28:45 questions on ACM panels you've described to us what you knew about and the minion panels and their behavior in fire did you have any did we have the same or a different view about a cm which had a
01:28:57 different view about a cm which had a polyethylene core no I I mean I'm not I just viewed it's a laminated aluminium
01:29:08 just viewed it's a laminated aluminium panel I didn't know the fact that the Corps was polyethylene didn't didn't cause you to consider how I behave
01:29:23 I mean as I understand it were an important on the heart the only mark stood the one product I mean my knowledge polyethylene did I didn't know
01:29:36 knowledge polyethylene did I didn't know it was polyethylene or is it I didn't I didn't I just viewed it as a laminated aluminium panel I didn't have any
01:29:49 aluminium panel I didn't have any perception that it was well what we some monitor so that it's become I mean right
01:30:00 monitor so that it's become I mean right yeah thank you very much okay we'll have them without ten minutes now say back Acosta for them please go after forties
01:41:36 yes we do ask mr. Crawford to come back please
01:41:52 all right mr. Crawford yes mr. Crawford I'm going to ask you some questions about the design of the cavity barriers in the facade can I ask you to go back to the building regulations please CLG
01:42:04 to the building regulations please CLG zero zero zero zero zero two two four at page 69
01:42:20 and this is schedule one part b3 internal fire spread structure and if you look at subsection 4 please at the
01:42:31 you look at subsection 4 please at the bottom it says the building shall be designed and constructed say that the unseen spread of fire and smoke within concealed spaces in its structure and fabric is inhibited you see that yes were you aware of that requirement when
01:42:42 were you aware of that requirement when you were working on the ground filled tower project so we're not b3 yet yes including subsection 4 categorically
01:42:54 including subsection 4 categorically fair beta not necessarily verbatim but but a concept generally yes yes now if we look at the guidance to that in a DB which is CLG zero zero zero zero zero
01:43:05 which is CLG zero zero zero zero zero two to four page 82
01:43:13 this is paragraph nine one introduction and it says concealed spaces or cavities in the construction of a building provide a ready route for smoke and flame spread this is particularly so in
01:43:25 flame spread this is particularly so in the case of voids in above or below the construction of a building eg walls floors ceilings and roots as any spread is concealed it presents a greater danger than would a more obvious weakness in the fabric of a building
01:43:36 weakness in the fabric of a building were you aware of the guidance in ADB mr. Crawford at the time on cavities when he became involved in the mental tower project yes so aware of that gamba 33 in section 9 yes the way you did you
01:43:48 33 in section 9 yes the way you did you appreciate that the construction of the new facade on Granville tower would create cavities yes did you appreciate that there was a risk of fire spread within those cavities yes
01:43:59 of fire spread within those cavities yes looking at paragraph 9.2 provision of cavity barriers it says there that cavity barrier should be provided and there's quite a lot of text below that there can i summarize it to subdivide
01:44:11 there can i summarize it to subdivide the cavity where there would otherwise be a pathway around a fire separating element ie compartment wheels and floors yes yes
01:44:21 yes yes closing the edges of cavities yes yes subdividing extensive cavities yes and protecting open is within extensive cavities ie around windows or for
01:44:34 cavities ie around windows or for example around windows yes yes now you could see diagram 33 where that's Illustrated can you please be shown page 82 at the bot was the same page diagram
01:44:45 82 at the bot was the same page diagram 33 at the bottom and this is called provisions for cavity barriers yes it still page 82 and you can see just working from the top of the building and
01:44:56 working from the top of the building and the diagram downwards we can see that one is supposed to put cavity barriers at the top of the cavity you see that yes and within the cavity at the compartment floor line yes see that
01:45:07 compartment floor line yes see that second one down and then third one down around openings you can see the two little arrows yes you see that and that's a that's a window isn't it yes so the little green box also shows you where you have to put a fire stop yes
01:45:20 where you have to put a fire stop yes and that's that's got to be the same fire resistance as the compartment yes yes and we'll come back to that later when we look at the design of the cavity barriers but before we do can we go to
01:45:31 barriers but before we do can we go to 9.3 which is on page 83 the next page in the in the guidance and that says that it's again quite a long bit of text but
01:45:42 it's again quite a long bit of text but guidance says that cavity barriers should be provided to close the edges of cavities including around openings you see that in the first part of 9.3 do you agree that the guidance is clear
01:45:53 do you agree that the guidance is clear that you need cavity barriers around openings I've made several observations so you have to be aware bit while I do this on section 9 and diagram 33 the the
01:46:07 this on section 9 and diagram 33 the the basis of Building Regulations as I understand it when originally the original inception with the D CLG we said they were based largely on crazy
01:46:19 said they were based largely on crazy largely for designing generic if you like wimpy type houses in housing estates and section 33 in my experience over time sorry diagram 33 in section 9
01:46:32 over time sorry diagram 33 in section 9 in my experience over time is that is not fit for purpose I know these reasons that had to believe that and they've informed how I apply
01:46:45 that and they've informed how I apply cavity barriers over time this number of observations I've made first of all and our text or visual 90% of our time is spent drawing and working 3d sketching
01:46:58 spent drawing and working 3d sketching and so on diagram 33 itself looks like a two-up two-down house if you will keep the silhouette of it it looks like to Britt skinned balls together the actually the Vice version and the 2019
01:47:12 actually the Vice version and the 2019 version is even worse because they slap a basement on it so it doesn't give any sense it's for any building of any height and my experience when you actually read
01:47:24 my experience when you actually read through section 9 is that it's very limited it doesn't make any reference for example to double skinned facades to over cladding or to rain screen facades
01:47:37 over cladding or to rain screen facades and I've had the personal experience before and other projects specifically double skinned facades where they typically don't use cavity barriers at all are very limited and so you have to
01:47:49 all are very limited and so you have to assess based on the Pacific's of your building type which in my view are not covered by the guidance and being mine today is just guidance and no amount of
01:48:00 today is just guidance and no amount of well you could spend dozens of hours reading the text and Chinese interpret the language in that section but it doesn't make up for lack of experience
01:48:12 doesn't make up for lack of experience in terms of practical application and I'm mentioning that specifically to experience have had doing double skinned facade which don't allow you to fit in cavity banners in the way that is shown
01:48:24 cavity banners in the way that is shown for example in diagram 33 well go please to CLG well the same document actually page 96 which is the guidance under be
01:48:36 page 96 which is the guidance under be for external wall construction mr. Crawford and I'd like you please to look at paragraph twelve point eight yeah
01:48:45 we've seen twelve point seven we spend a lot of time on that I'm now looking at twelve point eight under cavity barriers which we looked at briefly on yeah Thursday push reference is nine yeah correct it does so looking at that at
01:48:58 correct it does so looking at that at the time had you looked into that at the time you would have understood surely that cavity barriers should be provided in accordance with section nine in respect of grenfell tower no no I mean
01:49:09 respect of grenfell tower no no I mean if you read the actual text you can even you can't satisfy section nine I mean you can't for example cause around all openings in a rain screen facade the way around screen facade
01:49:22 facade the way around screen facade works is this very effectively effectively open so it's ventilated so you have it's pressure equalized the theory behind that is that
01:49:33 theory behind that is that behind the rain screen is the same in the front or equalizes in order to do that every panel is open round the edge if you take verbatim section 9 you'd
01:49:44 if you take verbatim section 9 you'd have to seal around every edge so you can't satisfy a db2 by following section 9 I'm just trying to understand your
01:49:55 9 I'm just trying to understand your your recollection at the time was it your recollection at the time that's my recollection that's how that that wasn't it was it your recollection at the time that approved document b even though it
01:50:06 that approved document b even though it refers to cavity barriers at twelvepointeight in accordance with section 9 didn't require cavity barriers around the windows at Greenville tower
01:50:21 yes was it your understanding of approved document b at the time that notwithstanding the language of 12.8 of approved document b which refers in terms to section 9 cavity barriers were
01:50:34 terms to section 9 cavity barriers were not required around the windows in the external wall construction at grenfell if you're - if you follow a set section and in part you might assume that they
01:50:46 and in part you might assume that they were required
01:50:58 did any did anything about the project lead you to think that cavity barriers were not required around the windows I think this this practical issues with brain screen facades where you can't
01:51:09 brain screen facades where you can't satisfy section line by placing cavity bothers to cause the edges around windows most proprietary in screen systems all the bracketry is right up at
01:51:21 systems all the bracketry is right up at the edge so you can if you look at mmm a few kid product literature and Australian screening systems you can get a cavity barrier closing the edge it's
01:51:34 a cavity barrier closing the edge it's all my my understanding in terms of the strategy cavity balance strategy on grandfa was that there was a scheme that being agreed and agreed I say compliant
01:51:45 being agreed and agreed I say compliant for the employers requirements I then to that and tried to verify it with x over with my understanding of what would be a compliant scheme and well they agreed
01:51:59 compliant scheme and well they agreed will come to the email trap to the email correspondence in due course but I just tried to understand at the moment your your evidence about your thinking at the time of how the rain screen system
01:52:12 time of how the rain screen system proposed for grenfell would comply with the requirements of approved document b paragraph 12.8 and section 9 and again and try to summarize your evidence are
01:52:23 and try to summarize your evidence are you telling us that in fact it wasn't possible in your opinion at the time to construct the rainscreen cladding in such a way that it did comply not to a
01:52:35 such a way that it did comply not to a db2 but that's from their guidance did you raise that concern or question with anybody at the time yes but the conversation with ixora
01:52:46 conversation with ixora in just to be clear in this the one in march 2000 and the march start to vape right we'll look at those emails I don't think you've put in your statement anywhere your opinion at the time that
01:52:58 anywhere your opinion at the time that it was not possible to comply with paragraph 12 point 8 and section 9 of Edo that's only one route to compliance all right now that's some look at
01:53:14 all right now that's some look at paragraph 9.13 at page 86 please this
01:53:25 paragraph 9.13 at page 86 please this says every cavity barrier should be constructed to provide at least 30 minutes fire resistance it may be form by any construction provided for an for another purpose if it meets the provisions for cavity barriers see
01:53:36 provisions for cavity barriers see appendix a table 1 table a1 and item 15
01:53:45 were you familiar with that provision as at July 2015 I was familiar with that provision and what we had in this back although in the spec I think we sure had
01:53:56 although in the spec I think we sure had a 30-30 right and looking down the page at 9.1 for cavity barriers should wear a cavity barrier should wherever possible be tightly fitted to a rigid
01:54:08 be tightly fitted to a rigid construction and mechanically fixed in position you see that yes were you familiar with that as at July August 2014 it's self-evident to me right and
01:54:22 2014 it's self-evident to me right and then if you go to appendix a table a1 which is referred to at the beginning of 9.13 mr. Crawford that's a page one to four of this document
01:54:38 this says that cavity barrier should have a minimum of 30 minutes integrity and 15 minutes insulation doesn't it yes and were you familiar with that yeah at
01:54:49 and were you familiar with that yeah at the time just to get back to an answer to some of my questions earlier on if you are of the view at the time that it
01:55:01 you are of the view at the time that it was not possible to comply with all of the guidance in approved document b in relation to cavity barriers for the proposed rainscreen cladding at Grenfell tower how are you expecting to comply
01:55:12 tower how are you expecting to comply with functional requirement b3 of the building regulations
01:55:24 to install as far as practical cavity by or strategy around the windows
01:55:36 not round windows for the reasons I've given if you didn't provide cavity barriers around the wind days which are openings in accordance with diagram 33
01:55:47 openings in accordance with diagram 33 then mr. Crawford how were you going to comply with functional requirement b3 the cavity barrows were around the compartments and you probably have seen
01:56:01 compartments and you probably have seen from the correspondence and the fact that green screen cladding wouldn't stay in place and the developed fire therefore the cavity virus wouldn't
01:56:13 therefore the cavity virus wouldn't perform a meaningful function in those locations anyway not that you could get them into those locations precisely in the terms set out in b3 additionally we had two barriers in
01:56:27 additionally we had two barriers in close proximity enemy at their head and sites did the header that the sides were going to come to precisely where the
01:56:38 going to come to precisely where the cavity barriers were do you course but can I just ask you this given your answers just now did you ever raise with Harley or Ryden or X over
01:56:49 raise with Harley or Ryden or X over your view that it was not going to be possible to put cavity barriers around the window openings given the design of the rainscreen cladding
01:57:02 I had a conversation with it's over in relation to practical application of capita virus and rainscreen Prasad is that the discussion we see in the emails at the at the end of March is
01:57:14 the emails at the at the end of March is correct anything else well he had their own ideas about a cavity bio strategy that was quite different
01:57:22 different again as you all have seen right okay well perhaps we'll come back and revisit this question again when we've looked at the emails I want to turn in the context
01:57:37 the emails I want to turn in the context of cavity barriers to look at the NBS specification now I know this was prepared before your involvement mr. Crawford but let's look at it it's se a 0 0 0 0 0 1 69 at page 246
01:57:56 and if you look there under four three five paragraph four three five ventilated cavity barriers you see that yes
01:58:04 yes manufacturer down in cladding system sorry down there cladding systems and then product reference llama therm CWR sh-60 horizontal llama therm CW RSV
01:58:19 sh-60 horizontal llama therm CW RSV sixty vertical see that yes and then we can see underneath that fifth bullet
01:58:33 can see underneath that fifth bullet down fire-resistance rating says 30 straight thirty-two BS 476 part 20 1987 and BS en 1366 for 2006 you see that yes
01:58:46 and BS en 1366 for 2006 you see that yes okay does that fifth bullet point down mean 30 minutes installation and 30 minutes integrity yes I see now the minimum performance stated in a DB as
01:58:57 minimum performance stated in a DB as we've seen is 30 minutes insulation and 15 minutes integrity isn't it yes so is it right then that the fire resistance required by the NBS spec here would meet and in fact exceed the minimum
01:59:09 and in fact exceed the minimum performance standard required by a DB yes okay now if we then go up to the last sentence of the first dashed bullet point we looked at that the product
01:59:21 point we looked at that the product reference Lana therm CWR sh-60 horizontal or sv 60 vertical does that or did that suggest that the fire resistance for the cavity barriers
01:59:33 resistance for the cavity barriers actually specified with 60 minutes I'm not sure I don't think alarm at them or even manufacturing Lambeth owns the products the many frames it has done is people down there I should just be
01:59:50 people down there I should just be Klamath erm became satisfied right yeah that's right
01:59:56 so sorry your question was the question was was whether my question is whether the reference to 60 in the product reference of our sh-60 RSV 60 was
02:00:12 reference of our sh-60 RSV 60 was actually a fire-resistance time period of 60 minutes it may well have been right can you explain the difference no except the requirements only for 30 15 I
02:00:23 except the requirements only for 30 15 I understand that and you said that but do you did you notice the difference when you did read this spec no I think I'd have just read the fire resistance rating okay did when you started working
02:00:35 rating okay did when you started working on the project did you independently check the cavity barrier products that had been specified I remember having conversations about the cavity berry our strategy with Bruce
02:00:46 the cavity berry our strategy with Bruce um I don't recall whether individually checked the product specifying okay you remember a conversation about the strategy with Bruce that was that on the handover in it may have been later I'm
02:01:00 handover in it may have been later I'm not sure okay do you you remember ever looking for any test certification that supported the use of these products in a
02:01:13 supported the use of these products in a rain screen system
02:01:19 I don't recall can we look at the Harley design then in August 2014
02:01:31 design then in August 2014 I think it's right that Harley began sending you drawings of their detailed design of the cladding remember that yeah and if we turn to se a zero zero zero one one four nine zero we can see
02:01:45 zero one one four nine zero we can see that this is an email from Kevin Lam - Simon Lawrence on the 22nd of August 2014 which is copied to Daniel Michael
02:01:56 2014 which is copied to Daniel Michael Jones and to you at Studio E as well as to Bruce sounds do you see that yes one of the attachments there are two of them which are GA models for the tower and he
02:02:09 which are GA models for the tower and he says Simon please find attached some preliminary drawings to prove the basics of design and set out prior to us producing full design package it would be useful for us to discuss these principles that are meeting on Tuesday
02:02:20 principles that are meeting on Tuesday morning as we see that yes and the attachments there are se a and I'll just show you these se a zero zero zero zero two eight five one just have those up
02:02:33 two eight five one just have those up thank you and as you could see from the date at the bottom they need to blow it up at the 20th of August 2014 you see that and drawn by in the box of f BD and
02:02:47 that and drawn by in the box of f BD and there's a little there's a little quadruped head lamb-lamb yes and KVL which is mr. LAN yes and that's how we know it's his and then you could see the drawings there
02:02:59 then you could see the drawings there and you see that yes now correct me if I'm wrong but there are no cavity barriers indicated on that drawing oh there that's correct no and if we look through each of the next few drawings
02:03:10 through each of the next few drawings just scrolling down slowly I think it's right isn't it that there are no cavity barriers on each of those either
02:03:17 either any of those that's correct right did you think it was strange given that the employers requirement drawings had included some cavity barriers no because they should RFI at first loose end time you said virtually the same time
02:03:36 time you said virtually the same time the RFI we saw before was September wasn't it yes sir same what do you say same time perhaps it's my fault same time is what these drawings I see so I
02:03:52 time is what these drawings I see so I see say these drawings predate the RFI they do I mean these drawings were preliminary and I think I commented the time are very basic they were attended sure the basic layout let's say of
02:04:04 sure the basic layout let's say of panels and then RFI followed shortly afterwards
02:04:16 when you receive these drawings you didn't know that the RFI was coming a few weeks later did you that's correct so when you receive these why didn't you go to Kevin lamb or anyone else at
02:04:28 go to Kevin lamb or anyone else at Harley and say wait a minute why are there no cavity barriers around the windows as shown in the employer's requirement drawings well you may have done I possibly don't I don't recall
02:04:40 done I possibly don't I don't recall these for as I stated our preliminary drawings to show the proportions and setting out well that's what you say we may have done we have no record of that and it's not in your statement that you did have to proceed on that basis so
02:04:52 did have to proceed on that basis so that's why I was asking you why you didn't but I'm not sure that that's the case that's what I'm saying to you I mean I suppose what I'm saying is these are preliminary drawings and those showing proportions and dudes is Fache
02:05:05 showing proportions and dudes is Fache past let's say at setting out and things like the detail all right follows on from that I mean if you for example
02:05:16 from that I mean if you for example produce this drawing six months later there were no camped about us then yeah sure
02:05:21 sure send alarm bells ringing right okay well let's just see what you did do if you go please to se a zero zero zero zero two eight five three
02:05:34 thank you these are your well you help me the red handwriting is yours I think we're used to that now yeah I mean as I recall that when we did these comments
02:05:49 Kevin sent them out for initial comments but portions and this setting out no show a number of workshops that we had as well when we met them one site and the drawings were discussed so you know
02:06:06 the drawings were discussed so you know cavity bars may have been discussed and noise well alright but just looking at your comments on these drawings mr. Crawford we can see there's taking it in
02:06:18 Crawford we can see there's taking it in in stages we can see first of all there's a box on the first drawing that the bots in the bottom left Neil Crawford 27th of August 2014 and you put studio e status B yes does that
02:06:32 you put studio e status B yes does that that's as it were a handwritten form of the stamp that normally goes on these yes I see and status B means conforms to design intent subject to comments yes
02:06:43 design intent subject to comments yes and here are your comments intention was this is on the first one to keep this joint wide joint have I misread that yeah there's actually several sets of
02:06:54 yeah there's actually several sets of comments done on these drawings there are Brewster said I just said the they were literally an initial appraisal of an issue the initial attempt to reconcile our
02:07:11 the initial attempt to reconcile our architectural intent with the practical a practical initial set of short drawings we could see on these drawings
02:07:22 drawings we could see on these drawings and take your time and have them scroll down for you if you like if we go to the next one down please mr. operator we can see here are a set of comments on this second page indicate which is trickle
02:07:35 second page indicate which is trickle vent admit fixing and extend sill to create drip detail is that right drip detail and critically eliminating line of fixings etc one can look at these and
02:07:46 of fixings etc one can look at these and look at look at all of them it's really about what's not there we can't see you saying anywhere here
02:07:53 here why is there no cavity barrier around the windows that's correct would this not have been the time to raise that in your comments I said we
02:08:06 raise that in your comments I said we had several we had meetings on-site and workshops and is highly probably highly probable that they were and that's why Harley raised the RFI do you have a
02:08:18 Harley raised the RFI do you have a specific recollection of raising the absence of cavity barriers around the windows with Harley at around this time I can't recall Nick
02:08:33 well let's look at the Harley RFI which we looked at earlier this morning it's to get back to it it's H AR zero zero
02:08:45 to get back to it it's H AR zero zero zero zero three six one six can I just say that's with that initial set of drawings that when they were sent out under that was species of being preliminary and four initial comments I
02:08:56 preliminary and four initial comments I mean the they weren't set out in the sense that the way new there's any finality to them and so you would normally expect for example more detail to be added over time as the the
02:09:09 to be added over time as the the drawings were developed are constant and I think what we have so far is at this stage in time when it comes to you for comment on the 27th of August 2014 you don't you don't comment on it that there
02:09:21 don't you don't comment on it that there are no cavity barriers I've seen that yeah let's move on then to the RFI here it is we saw it earlier this morning 17th of September and the query and just
02:09:33 17th of September and the query and just to repeat it now that we're talking about cavity barriers please may you confirm the required extent of the horizontal fire breaks within the cladding areas and then the suggested
02:09:44 cladding areas and then the suggested solution and again i'm and i'm repeating the repeating this to you I'm afraid 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 between but this
02:09:56 between windows this is between but this is because there is no chimney effect here and therefore the cladding will not add to the spread of fire you see that yes so there's no there's no question
02:10:07 yes so there's no there's no question that's raised do we need cladding do we need fire breaks or as they call them or cavity barriers around the windows is there it's not part of the question no the use of the word fire breaks is
02:10:19 the use of the word fire breaks is interesting do you agree with me that the word fire break is not a term used an approved document b
02:10:31 not in document be bitter notes those used in BR 135 yes I mean is it a word you've come across and your experience
02:10:42 you've come across and your experience as an architect up to that point I think I think fire breaks fire stops cavity barrier can be intermittently used perhaps wrongly but they are they're
02:10:55 perhaps wrongly but they are they're used interchangeably yeah and just change overnight I know I didn't want to put that word in your mouth but I suspect it that's what you meant yes yes now that's potentially quite confusing isn't there because
02:11:06 quite confusing isn't there because there's a difference between a fast stop and the cavity barrier there is yes yes did you ever read did you ever go back to Harley and say look don't use don't use fire brakes
02:11:17 use fire brakes can I please I'd be clear what you're asking are you saying character barriers what are you saying fire stops I think fire breaks to me you it's clearly men cavity barrows you thought it clearly
02:11:28 cavity barrows you thought it clearly meant cavity barriers Yeah right and why did you think that because I couldn't see what else he would mean I was okay so you thought it meant cavity bearers now Harley suggested in the
02:11:40 bearers now Harley suggested in the suggested solution that we've just seen that the installation of fire breaks to you cavity barriers was to avoid a so called chimney effect does that mean fire spreading up the problems uninhibited yeah I mean what what I
02:11:53 uninhibited yeah I mean what what I understood and I think I might explain this the first things it's really difficult that white was there imagine these Wendell's this is the window and start repeating and you've got the
02:12:05 start repeating and you've got the columns in between they understood the most important thing to do is break that practicality all the way up the building and although the description started
02:12:16 and although the description started confusing I understood it is they wanted the cavity pilot between the windows like this because the window is actually projected so you didn't have the chimney
02:12:27 projected so you didn't have the chimney effect without the front and you'd stop it at the columns so if you like this is there
02:12:33 there strategy for addressing the chimney effect right I see that so at this stage is it right that so far as you could see
02:12:44 is it right that so far as you could see Harley weren't sure where the horizontal cavity barriers should be placed I think if there are life to it that's really would have placed them and what would that have been any good well I'd you
02:12:58 that have been any good well I'd you might find that exists in quite a lot of rain screaming cladding or variants of that but my view was that wasn't sufficient right and if we can now go
02:13:13 sufficient right and if we can now go please to the emails se a0001 173 zero
02:13:20 page for now I'm I'm sorry to have to drag you back to his email run again this is September 2014 and we looked at
02:13:34 this is September 2014 and we looked at this probably ad nauseam this morning I'm afraid mr. Crawford but there it is there's the question asked by mr. ankertill Jones which he referred on to x over on the 18th of September and asked mr. Ashton for his view do you
02:13:48 asked mr. Ashton for his view do you know why studio E was not able to answer that question why were you not able to answer that question yourself well I think this two points had me first of
02:14:01 think this two points had me first of all we we did have a cavity by our strategy the emolia personally of the shortcomings of section 9 and
02:14:12 shortcomings of section 9 and particularly in its obviate e be to its of if you like restricted were met in terms of what it seems to refer to and in my view it doesn't cover it doesn't
02:14:24 in my view it doesn't cover it doesn't adequately cover dealing with a green screen facade or a double skinned facade or an ultra-light facade for that matter and so it made sense to me to initiate
02:14:35 and so it made sense to me to initiate the conversation with x over 2 to understand their understanding of what was reasonable in that context yes I mean you don't in the
02:14:47 that context yes I mean you don't in the message that you sent to mr. Ashton say to him impart to him the sense of what you're telling us which is that you
02:14:58 you're telling us which is that you think there are shortcomings in section 9 in a db2 which means that it doesn't easily apply to the cavity barrier strategy that you were adopting you
02:15:10 strategy that you were adopting you don't say that do you not an email no say mister quite referenced in the email Pacific Lee Hartley's interpretation in the stacking act and I suppose that's
02:15:22 the stacking act and I suppose that's because I thought I'd might have missed something highly highly produced well many more or four clouds than myself so maybe they know something I'd wanted to saw right did you seek the advice of
02:15:35 saw right did you seek the advice of anybody else at studio AE first before getting to mr. Ashton with your question I tend have had the conversation with Bruce probably about what our strategy was and what he believed what did he
02:15:48 was and what he believed what did he tell you um I think he's pretty adamant that our strategy was cracked right and can you just you talked about the cavity barrier
02:15:59 just you talked about the cavity barrier strategy can you just summarize that for me so that I'm clear about what you mean in the context of these messages I said yes one word that we had it yes your cavity burrows data fit um it was cavity
02:16:10 cavity burrows data fit um it was cavity barriers that related to the compartment lines so for example illustration I use earlier if this is the plan of the apartment and you've got the sides here
02:16:23 apartment and you've got the sides here you've got compartment wall around here compartment walls typically 60 minutes except with Iran to escape to the 120 and so this if you imagine that's the
02:16:37 and so this if you imagine that's the floor plan of the whole apartment you wouldn't have a cavity bar at the rooms where they hit the external wall but you'd have them where the compartment lines are which you can see in the fire strategy trunks
02:16:48 strategy trunks so for example imagine this is the apartment you'd have 60 minute assorted you'd have to you'd have the compartment you'd follow the compartment line so
02:16:59 you'd follow the compartment line so you'd be protecting one department from the next yes I see thank you and just so we're clear the compartment sorry the
02:17:10 we're clear the compartment sorry the cavity barrier strategy that you've just explained to us doesn't involve any strategy requiring the Installer installation of cavity barriers around the windows no no were you not surprised
02:17:22 the windows no no were you not surprised that a specialist cladding contractor like Harley would have a query of this nature perhaps but then when you read actual email really see about this here
02:17:35 actual email really see about this here isn't it um look what fire officer as opinions tend to vary and that is definitely the case I know one of the reasons I think that is the case is
02:17:46 reasons I think that is the case is because approved document b is really not fit for purpose and that respect now we've looked at this series of emails
02:17:58 we've looked at this series of emails and drawings you've sent to x over already if we go up to page 3 of this email chain we're on page 4 we need to go to page 3 you could see that the
02:18:10 go to page 3 you could see that the second email down from youthful mr. Ashton of 1218 on the sub 18th of September you could see you say hi Terry please see attached are sections and the
02:18:21 please see attached are sections and the initial drawings set we've had from Hartley's the initial drawings from Hartley's are fairly limited but they attempt to establish the basic approach we look at that this morning and then at the you go please to se a 0 0 0 1 1 7 1
02:18:34 the you go please to se a 0 0 0 1 1 7 1 0 we get back to the drawings which we'd looked at again this morning
02:18:49 we can see there those are the attachments and I think I've given you a wrong reference but if you go to se a one zero zero zero one one seven one
02:19:00 one zero zero zero one one seven one four
02:19:01 four that's the pack of Harley drawings we've already looked at and those are the same ones dated the 20th of August 2014
02:19:13 ones dated the 20th of August 2014 without your notes on it so it's the same pack of them that they brought you think we're calling preliminary drawings which don't show any cavity barriers and my question is did you not think it
02:19:24 my question is did you not think it necessary to clarify with mr. Ashton exactly where he was advising that the cavity barriers needed to be placed by reference to these drawings when you say
02:19:36 reference to these drawings when you say a German Holly no mr. Ashton did you not forget necessary to clarify with mr. Ashton exactly where mr. Ashton was advising the carroty barriers needed to
02:19:47 advising the carroty barriers needed to be placed by reference to these drawings but I think I did sorry can I see the original email again but the original email is back at as se a 0 0 0 1 1 7 1 0
02:20:05 we see attached are sections and initial drawings from Hartley's so he had our section switched sure yes where we thought the cavity bar should be and that and they had Hartley's drawings without the cavity bar is drawn on yes
02:20:17 without the cavity bar is drawn on yes so he could see basically our cavity by our strategy yes and you could see let's say where Hartley's had got to in their design so he had if you like information
02:20:30 design so he had if you like information to make for him to make an input yes exactly
02:20:36 exactly I think I'm agreeing with you but I'm just pressing you a bit more did you not think it necessary to get him to clarify where exactly the cavity barriers needed to be needed to go
02:20:47 and I think that's what we was doing I see yeah all right I mean again I know you don't like me saying this but the reality is there's telephone
02:20:59 reality is there's telephone conversations going on at the same time as emails I'm not seeing pacifically now or between the CEO of that email but that is the case at all events he never
02:21:11 that is the case at all events he never comes back to you at least we don't see him ever coming back to you saying well you need to have cavity barriers around the windows no
02:21:28 and then indeed at this stage all you had to send 2x over which was available to you other than the preliminary
02:21:40 to you other than the preliminary drawings from Harvey with the employers requirements drawings from 10 months before that yes which had a cavity bearish strategy on indeed now moving
02:21:54 bearish strategy on indeed now moving forwards in time to January 2015 on the 13th and 14th of January 2015 I think
02:22:05 13th and 14th of January 2015 I think you've got another pack of drawings from Kevin lamb and that is just to be clear with you it's se a 0 0 0 1 2 4 8 9 it's also referred to in your statement for
02:22:16 also referred to in your statement for the transcript of paragraph 97 but we can see the email there and Kevin lamb sends you that as a copy the email itself goes to Simon Lawrence you see
02:22:29 itself goes to Simon Lawrence you see that and you see the attachment I can't see the attachment yes and then it says Simon please find attached finalized all 160 of North and South windows all as agreed in the last meeting just before
02:22:41 agreed in the last meeting just before Christmas the sample window will be one of these if you have any concerns please advise immediately as manufacture is now starting see that yes and then if you go to se a 0 0 0 3 0 4 0 and these are the
02:22:58 to se a 0 0 0 3 0 4 0 and these are the drawings that you refer to at paragraph of 99 of your statement on page 90 page 37 that's just for the transcript here they are and here are the drawings and
02:23:13 they are and here are the drawings and if you look at page 1 you can see they were originally created on the 20th of August 2014 that we were looking at before and now they have progressed from
02:23:26 before and now they have progressed from August through to January 15 construction do you see this is now revision II yes in the Box on the left hand side at the bottom and you've marked looking at the first one you've
02:23:37 marked looking at the first one you've marked that B conforms the design intent subject to comments and you did that on the 16th of January 2015 yes and we can see your comments yes yes
02:23:50 yes and we can see your comments yes yes right and again in this drawing even revision II January 15 Harley did not
02:24:02 revision II January 15 Harley did not indicate where on those drawings any cavity barriers should be located did they know and you didn't pull them up on it did you um that's not totally true isn't it no well in this drawing you
02:24:16 isn't it no well in this drawing you didn't did you in this specific drawing not no and indeed none of the other drawings in this pack comprising what you're sent in on the 15th of January that's right
02:24:28 on the 15th of January that's right isn't it correct your poor would point out is that these windows were it's really strong for to reflect late client session and windows requirement session
02:24:41 session and windows requirement session that to the change in the window sizes yeah so there was the separate conversation was going on in relation to the cavity by our strategy that stretched back to the 17th to September
02:24:54 stretched back to the 17th to September and continued on in various workshops in relation to determining the final strategy so these these drawings were an attempt to pin down the revised window
02:25:08 attempt to pin down the revised window format that it come about due to a number of Lee changes in the actual design and size of the windows and
02:25:19 design and size of the windows and indeed if you look at page three here is a drawing typical Bay levels one to twenty South elevation this is revision B 14th of January 2015
02:25:34 sorry 13th of January 2015 I'm so sorry on page three which you've stamped a conforms to design intent yes yes but that doesn't have any cavity barriers anywhere on that does it no and it's
02:25:49 anywhere on that does it no and it's right there for isn't it that there it therefore did not even reflect studio ease employers requirement drawings which did have cavity barriers a crap I've explained the situation and I
02:26:01 I've explained the situation and I shouldn't the cavity bearers to you and it's not that it's not that these the there wasn't the understanding that cavity bearers were going in it's just
02:26:13 cavity bearers were going in it's just that the strategy is being developed separately I mean for example these drawings don't show the cladding real positions but you wouldn't see well therefore it's not an applicable drawing
02:26:27 therefore it's not an applicable drawing I mean there's a lot of things these drawings done and sure no my question perhaps I misunderstood it given that
02:26:39 perhaps I misunderstood it given that the studio II employers requirement drawings did contain some cavity barriers how could Harley's drawings which didn't contain cavity barriers be
02:26:51 which didn't contain cavity barriers be stamped a state assay conform to design intent because who talked about architectural intent the cavity Baron spent part of the architectural intent the same way that the cladding rails one
02:27:02 the same way that the cladding rails one part of that architectural tent same way that cladding brackets when part of the architectural tent all those things could have been shorter than this drawing was the absence of any cavity barriers on this not a manifest error
02:27:14 barriers on this not a manifest error which any architects should have identified no absolutely not for the reasons have given there was absolutely clear that we had a cavity by no strategy that the cavity by our strategy was being developed they'd been numerous discussions about
02:27:27 they'd been numerous discussions about it had been meetings on site and it was understood that we had a cavity buyer of strategy and it was to be added to the drawings which it was I think it took them too
02:27:39 them too marched actually at the the final agreed scheme on but nonetheless the idea that somehow because it wasn't shown on this drawing that it wasn't being discussed
02:27:50 drawing that it wasn't being discussed or absolutely a student that had to be there it's a bit like saying well the cladding rails aren't they are so surely you you are we're gonna finish off this neither questions now mr. Crawford
02:28:02 neither questions now mr. Crawford because of the hour but you're right that Harley did not produce drawings showing what they called fire breaks until the third of March and we'll come to that now tomorrow morning but just focusing on this document this period of
02:28:13 focusing on this document this period of time given that Harley had been producing revisions of the August 14 drawings now for some months and had not shown any cavity barriers at all what
02:28:24 shown any cavity barriers at all what were you waiting for there's a lot I feel that broken record here but basically did as I said and you know book is help restorer of emails on
02:28:35 know book is help restorer of emails on it they've been a lot discussion on the cavity banish strategy and getting into a great position that involved among starlings Building Control so workshops etc well these drawings are showing
02:28:48 etc well these drawings are showing where Harley were having to respond very quickly to late changes by the Klein on the window arrangements they've come about for a number of reasons the planning reasons client
02:29:01 reasons the planning reasons client reasons these changes were being done very late on and the there's a lot pressure for Harley to get into some form of production in order for them to do that degree the basic basically
02:29:13 do that degree the basic basically architectural ten mr. chairman it's been a long day and it's now gone D hot spots for a I'm afraid I'm in the middle of a line but I think mr. Crawford's had a
02:29:25 line but I think mr. Crawford's had a long day and can we give mr. Crawford some reasonably we can but not least
02:29:38 some reasonably we can but not least because of the the quality of the evidence and the witness himself but also because Miss Granger sits to my right will have something to say about if I do
02:29:48 if I do so yes right well mr. Crawford I'm sorry I've got to ask you to come back for more questions tomorrow but as you've heard from mr. millet he'll finish questioning you
02:29:59 millet he'll finish questioning you tomorrow that'll be it so when a break now would resume at 10 o'clock tomorrow please yes and again I have to ask you not to discuss your evidence or any aspect of it
02:30:10 aspect of it over the break right yes okay well then you gave you the option we'll see you tomorrow morning don't leave your coat
02:30:26 right thank you very much ten o'clock tomorrow