Studio E Evidence - Thursday 5 March 2020 (1/2)

Full transcript

00:01:20 good morning everyone welcome to today's hearing today we're going to hear more evidence from one of the architects at Studio E yes mr. Bennett mr. Chairman I

00:01:35 Studio E yes mr. Bennett mr. Chairman I now call our next witness mr. Neal Crawford yes thank you very much

00:01:55 I swear by Almighty God I swear by Almighty God that the evidence I shall give that evidence I shall give shall be the truth shall be the truth the whole truth nothing but the truth

00:02:09 truth nothing but the truth thank you very much mr. Crawford sit down make yourself comfortable all right right yes morning mr. Crawford

00:02:20 all right right yes morning mr. Crawford Mari and can I ask you please first to give the inquiry your full name mr. Crawford thank you and thank you very much I should say first of all for

00:02:31 very much I should say first of all for coming to the inquiry and assisting us with our investigations I'm going to be asking you questions today and probably beyond today if you have difficulty understanding anything I'm asking you

00:02:43 understanding anything I'm asking you and please just say and I can put the question in a different way or or ask a different question and can I also ask you just to keep your voice up so that the transcribers who are on your right

00:02:54 the transcribers who are on your right there behind those screens can hear you clearly and get down accurately what you say yes now you have made a witness statement for the inquiry and you will find it in a file in front of you on the

00:03:07 find it in a file in front of you on the desk and it will also appear on the screen and I just like to show it to you please it's s e a three zeros one for 275

00:03:21 and that is the first page of it can you please formally identify that as the first page of your witness statement yes thank you and it's dated the 9th of November 2018 and you also provided a an

00:03:36 November 2018 and you also provided a an exhibit I think if we can bring that up please

00:03:39 please that's se a three zeroes one four two seven six if we can please have that

00:03:57 have you read this witness statement recently yes and can you confirm that the contents are true yes you please to turn to page 82 there's a signature

00:04:14 turn to page 82 there's a signature there is that your signature yes and the date is the 9th of November 2018 thank you

00:04:21 you now I want to start if I can please by asking you some questions about your qualifications and your experience all right yes okay now first of all qualifications you've set out your

00:04:33 qualifications you've set out your experience from paragraph 20 of your witness statement on words and you've also helpfully provided us with your CV can we look at that please that's se a 3

00:04:47 can we look at that please that's se a 3 0 is 1 4 276 page 2 and this is I think correct me if I'm wrong mr. Crawford as at 2018 yes yes I think you're putting

00:05:01 at 2018 yes yes I think you're putting in to CBS there's that one and my previous employment also yes well I just want to look at this one ok sorry if I can that's quite all right it's quite all right there's anything you think I

00:05:12 all right there's anything you think I should look at we're not looking at then please do tell me and the reason I say 2018 is because if you look at the fifth entry down on project experience at Studio E you can see James Allen's girls

00:05:24 Studio E you can see James Allen's girls school completion 2018 yes I'm assuming that this was a 2018 CV you know on the left of the page there you can see qualifications dip B arc ons

00:05:36 you can see qualifications dip B arc ons does that mean that you've completed parts 1 & 2 of the of the architects qualification yes that's right now I think you tell us in your statement and

00:05:48 think you tell us in your statement and this is paragraph 20 we want to look at it you can but you trained at the McIntosh school of architecture yes and that was between 1991 and 1997 yes yes yes and I think this is this right you

00:06:00 yes and I think this is this right you undertook your part one sandwich year in 1994 through to 1995 at bdp Glasgow yes I what's PDP classical and it's my

00:06:12 yes I what's PDP classical and it's my forces architects and Los Angeles yes exactly then that was for something like six months yes and that would be what during the summer of 1995 yes okay and

00:06:23 during the summer of 1995 yes okay and can you just help us with morphosis architects what in what capacity were you working there what was your job morphosis um I worked on a project in

00:06:39 morphosis um I worked on a project in South Korea at that time I was going under the heading of village fashion abandon there's something else that is working is not potential assistant so

00:06:50 working is not potential assistant so it's always the very junior at that point in my career so it was model making and then some drawing and also worked on a small master plan project

00:07:02 worked on a small master plan project with the principal mission for a theoretical master plan right in Cuba

00:07:15 theoretical master plan right in Cuba yeah thank you very much and can you just tell us when did you complete your part to qualification that in 97 1997

00:07:26 part to qualification that in 97 1997 and is it right that you at least as at 2018 when you did this CV we're looking at hadn't completed the RI be a part three final qualifying exam that's

00:07:38 three final qualifying exam that's correct

00:07:39 correct and it right in thinking that the part 3 RI VA exam involves quite an intensive unit study of the building regulations and the related approved guidance

00:07:52 and the related approved guidance amongst our things yes amongst other things yes did you study the building regulations and the approved guidance that goes with them at any part of your parts 1 & 2 we had

00:08:05 any part of your parts 1 & 2 we had building science is part of our course thinking undergraduate taking the postgraduate as well and that did cover quite quite a number of elements of

00:08:18 quite quite a number of elements of building regulations I see are you able to remember what elements of the building regulations that those parts covered L and but there are other

00:08:32 covered L and but there are other sections as well I'm sure it was very mind that would be over 20 years exactly can I just be clear those the English reg English and Welsh regulations or the

00:08:44 reg English and Welsh regulations or the Scottish regulations that you studied and the recent Scotland Sorby the Scottish Rite yeah - did you as part of your parts 1 & 2 have any opportunity to

00:08:55 your parts 1 & 2 have any opportunity to study the english and welsh building regulations and associated approved guidance where they'd be different no in

00:09:12 guidance where they'd be different no in the sense that some of the regulations are basically same in some aren't so yes yeah in the sense that they'd be parts that were different I think it's a logical that I would have studied them

00:09:24 logical that I would have studied them back in C and did any of those regulations that you studied at it parts 1 & 2 do they relate to fire safety now

00:09:41 1 & 2 do they relate to fire safety now you say well we have been told I should say that in the appendix to studio e's opening submissions to the inquiry and that you began your part 3 training but

00:09:54 that you began your part 3 training but stopped partway through for personal reasons I don't want to know about the personal reasons just to be clear about that but is that correct yes okay and can you tell us the dates when you started and when you stopped do you

00:10:05 started and when you stopped do you think I sent a cold 2007 that you started yes and I think it's the course five six months something nervous okay

00:10:16 five six months something nervous okay so during 2007 yes I recall okay and do you know what can you remember how far through the part three training you got

00:10:31 it had citric acid about half to two-thirds right did did any of that half or two-thirds cover the building regulations and associated guidance it may have done but

00:10:45 associated guidance it may have done but I would say that point in my career I'd have been exposed massively to building regs before before then so I mean I can't like I can't say if a beam of

00:10:57 can't like I can't say if a beam of naughty that yes I see if you say exposed when you say exposed you mean exposed as a result of in the field practice as opposed to yes had been my chops from learning working for ten years so it and could just tell me which

00:11:10 years so it and could just tell me which country did you do your part three studies in England that was in London you said say say okay yeah and is there

00:11:24 you said say say okay yeah and is there a reason other than personal reasons which I should stress I don't want to know about but is there a reason why you never received your part three training

00:11:34 and and can you give us a general impression that apart from the formal study that we've we've explored together you and I just now can you just give us a general impression of what level would

00:11:45 a general impression of what level would you say or familiarity that you had as at about July 2014 when you started working on the ground field tower project that you had with Part B of the

00:11:57 project that you had with Part B of the building regulations and approved document b

00:12:02 I would say the way that as an architect that you use Building Regulations is it's much in the same way you using an

00:12:13 it's much in the same way you using an encyclopedia I you don't read it from front to back you look at the documents as they become relevant so for example 2014 that done dozens of projects so in

00:12:27 2014 that done dozens of projects so in each project you would look at the regulations that were relevant to that person to that project or pertinent to what you were doing on that project so far be as familiar with because I'd

00:12:39 far be as familiar with because I'd worked on projects where clearly where that is a large part of the building and if our strategy is fundamental and any any project right thank you between 2014

00:12:54 any project right thank you between 2014 and 2016 were you a member of our the our IBA no can I turn to some of your in the field experience yeah if I can call it that before working as Judy area I

00:13:07 it that before working as Judy area I think you worked at Foster and partners between 1997 and 2009 yes in what capacity or role were you working there initially at the start initially I'd be

00:13:19 initially at the start initially I'd be working as our part to graduate right and where you I think you were then promoted to associate in 2004 we get

00:13:30 promoted to associate in 2004 we get that from your state yes yes and House senior was an associate position within fosters the foster structure has changed over the years sorry okay speaking about

00:13:42 over the years sorry okay speaking about the time I was there the structure and the hierarchy changed over time including in the period that I was there so

00:13:53 so [Music]

00:13:56 [Music] I think at the time the structure was

00:14:01 part 1 part 2 Architects associates I think who's directors then and then senior partners

00:14:12 directors then and then senior partners but I think the the firm did restructure really struggling out dates but towards the end of my time there and then the

00:14:23 the end of my time there and then the whole system was kind of recalibrated right I see so at the end of your time there in 2009 were you still an associate or we did you have another job title oh so nice are shaking now can we

00:14:35 title oh so nice are shaking now can we please look at your witness statement se a0001 for 275 at page 74 and I'd like to look with you please at paragraph 241 where you refer to your

00:14:52 at paragraph 241 where you refer to your work on a project at three to four Hardman square spinning fields Manchester you see that yes and that I think was something that Foster and partners designed in around 2004 as you

00:15:03 partners designed in around 2004 as you say yes and you say that you with a capital P project capital L lead for Foster and partners on that on that project was that in relation to that

00:15:14 project was that in relation to that particular project or was that a broader job title no I'm on that project which I worked on pretty much start to finish

00:15:25 worked on pretty much start to finish who's it's a partner and then within my time period I worked on that project I was made an associate so I was at a team

00:15:36 was made an associate so I was at a team at that time I recall 67 people working on that project so I for example would be going to Manchester doing meetings and so on so what I mean project lead

00:15:47 and so on so what I mean project lead was that the lead architect on the project or were you answerable to somebody else supervising your work I do to partner above me right yeah okay and did that partner supervise you on a

00:15:58 did that partner supervise you on a daily basis or only on a sporadic basis from tied soon on that project because I've pushed the team's flux depending in which stage you're at and

00:16:09 which stage you're at and sourcing and so on it is that the project partner was very involved and then later on is the I suppose yet procured on-site he was it was I was

00:16:21 procured on-site he was it was I was life more to deal with the whole project right I see and did you work on any other projects at Foster and partners as a project lead if you have my CV from

00:16:38 a project lead if you have my CV from foster partners if you could pull that off they tell you certainly we have that at se a triple zero one four two seventy six at page three

00:16:56 that's not right

00:17:01 well I tell you all do will well we'll find it and we'll come back out if we need it I'll move on then oh that's it there we got it right okay so have a look at that okay so for

00:17:14 so have a look at that okay so for example on the mill Harper quartz for project I'm going to come to ask you some questions about that but yeah do tell me now about that on that project who's the same partner above me and I

00:17:26 who's the same partner above me and I was if you like overseeing that team or beating up that team yes and India Terra no I came in later to help on the yo

00:17:38 no I came in later to help on the yo School of Management again I was working under a partner and I traveled to New Haven - every three weeks quite

00:17:49 Haven - every three weeks quite intensively over a period working on that I worked an initial competition phase of that and worked with our separate partner on that that led up the competition team that won the project

00:18:01 competition team that won the project and then so in that sense yes she might see us in some sense project leads periods of that but the typical

00:18:12 periods of that but the typical structure and there from piece to work under our partner I see yeah so I think and then if you go down the list Hardman's square with the explained I think there's more if you can scroll up

00:18:24 think there's more if you can scroll up yes if we could to scroll up I can but I did think people to scroll up a little another page there is no there is

00:18:35 another page there is no there is certainly another page page four okay so the the top project there I was working with the chief executive of Boston partners at that time and just because

00:18:47 partners at that time and just because that the residential projects in London and Malaga yeah 2003 to 2004 yes and I bought directly with him and these were his personal house these private houses

00:19:01 his personal house these private houses and the the one in London was part of Albion Riverside which is the project below where I helped assist it on for a bit also worked on a building that was

00:19:13 bit also worked on a building that was part of they'll be in Riverside complex which never got built but is now has now been built out albeit a different scheme and I kind of headed up

00:19:24 different scheme and I kind of headed up that portion of the that project is very much smaller than the building you're seeing their arms the building behind right and then these are projects a little more junior thank you very much

00:19:36 little more junior thank you very much now I just want to ask you about the mill Harbor Development you you referred

00:19:47 mill Harbor Development you you referred to that a paragraph 21 of your statement I'm happy to get back to that if you want me to but but since you've mentioned it and we can see it on this see it on this CV that does include a residential tower yet the new Harbor

00:20:01 residential tower yet the new Harbor project was part of our a master plan for a large developer we worked in force and partners worked in combination with som another large practice and the whole

00:20:15 som another large practice and the whole site was divided in two who is Kevin crosswalk site in games of skill and and square meter age the portion that we dealt with was with effectively four

00:20:27 dealt with was with effectively four buildings one was a market office building one was a private market residential building tear about 450 units and then the two antara buildings

00:20:40 units and then the two antara buildings south of affordable housing and I think they were of very mixed units who you had along the ground you had some townhouses and various types of apartment above so

00:20:54 and various types of apartment above so he's quite varied he went up through the building

00:20:58 building two of those blocks at the front the office brought behind and then the market tear on the corner and and so that that lose for buildings were

00:21:09 that that lose for buildings were fostering partner site and then to the east of that there was the s website the whole the whole project was one submission so we were working

00:21:21 submission so we were working although we were working independently on that half who's still working with us when coordinating the whole master plan now if you go back to your foster CV at

00:21:32 now if you go back to your foster CV at page 3 please on the screen that's se a well we have it there you can see that next to the mill harbour picture 2008

00:21:44 next to the mill harbour picture 2008 there's a little bit of text if we could have that blown up it says at the end of the description planning submission now complete do you see that yes did it ever

00:21:55 complete do you see that yes did it ever get beyond the planning stage the unfortunately that project is very much a casualty of the 2008 there's a nine financial crisis okay and if I could

00:22:08 financial crisis okay and if I could take you then to your witness statement paragraph 21 that's se a three zeros one for 275 page nine where you talk about the mill harbor development you you say

00:22:24 the mill harbor development you you say there that you were the project associate reporting to the partner that Foster and partners kill or donating a team of up to 20 people yes just to be clear what does that mean that you were one of a team of 20 people rather than the principal architect on the project

00:22:36 the principal architect on the project no and the the the planning submission was close you might imagine just piece of this scale of it yes and so the structure was the partner than me then

00:22:48 structure was the partner than me then the team I see who I supposed to my argue well it was the case that because the scale of the project I was very much in a managing last strike although it

00:23:00 in a managing last strike although it did do some cladding renders as part of that what yes I see I was going to ask you did that project involve over cladding of an existing high-rise

00:23:11 cladding of an existing high-rise building the areas are one isn't you build now you've referred to the Hardman square project and we've still got paragraph 21 up on this on the screen there mr. Crawford you you

00:23:24 on the screen there mr. Crawford you you say there in the second line you were involved from inception to completion and on cladding issues which discuss at paragraph two for one that was a

00:23:36 at paragraph two for one that was a project on which you acted this project lead when you say completion do you mean completion of the project as a whole or or just up to the end of Foster's involvement with Darwin's Square project

00:23:51 involvement with Darwin's Square project it was part of a development by Allied London yes in our ID London it was a large tract of land and central Manchester when spinning fields foster's

00:24:03 Manchester when spinning fields foster's were appointed at that point to do buildings three and four it's a termed at that point and that was just that's a portion I was involved with from start to completion it also includes carpark

00:24:17 to completion it also includes carpark and associated landscaping that connected the two buildings and and that whole development there were the route developments there are buildings that

00:24:28 developments there are buildings that were being built I think Shepherd Robson were doing a tariff simultaneously and then there's an R phase that came much later that we've been involved with yes I see I see can I ask you then to go to paragraph

00:24:39 can I ask you then to go to paragraph two for one of your of your statement which you've referred to here at paragraph 21 and that's on page 74 mister operator of the same document and

00:24:50 mister operator of the same document and you say in the last sentence there that you were the project lead and you say I now recall that Aerith facades assisted

00:25:01 now recall that Aerith facades assisted in designing the cladding as a facade consultant with metal ballefoy sure through food thank you as a subcontractor yes that was that a project on which you had a specialist

00:25:14 project on which you had a specialist fur consultant namely Arab facades

00:25:18 now I'm interment like that the there was a there would have been a fire strategy right as it had been by I can remember offhand who it was but we'd have been a separate fire consultant

00:25:29 have been a separate fire consultant during the fire strategy I said the facade consultant doesn't perfectly just deal with

00:25:36 deal with fire the Assad consultant generally is used to assist him that in the design and procurement process of a specialist

00:25:47 and procurement process of a specialist at the sad so so it's it's not that we are allocated to fire in precise if you see what I mean I see what you mean so do we take it from that that it was

00:25:58 so do we take it from that that it was errant facades which designed the cladding and affected the procurement of materials no they didn't design the

00:26:11 materials no they didn't design the cladding B and dude we were consulted on the development of the design of the of the cladding and he wouldn't have procured the materials you know right so

00:26:24 procured the materials you know right so so I see but you do I take it from that but you also had a separate specialist farken safar consultant or fire subcontractor there have been a fire

00:26:38 subcontractor there have been a fire consultant who have dealt with the fire strategy for the building yes C and that was a non foster's entity was it I can't

00:26:51 was a non foster's entity was it I can't remember who was bitten of like the head yes I'm not where the moist a specialist fire entity I think you've already told us but just confirmed the Hardman Square project wasn't a residential project

00:27:03 project wasn't a residential project it's an commercial makes you saw is predominantly office with retail at the ground level yes and did I think it didn't therefore involve a high-rise residential building above 18 meters no

00:27:15 residential building above 18 meters no he was an office building mafia 10 meters and I think it's right also that the Hardman Square project involved predominantly glazed curtain walling with metal spandrel panels yes it was a

00:27:27 with metal spandrel panels yes it was a unitized curtain walling system yes ok can we now turn to a different topic mr. Crawford which should ask you what was your actual job on on the Hoffman square

00:27:39 your actual job on on the Hoffman square project in respect of the facade specifically do you remember I didn't much the drawing for the facades I know it's been the project assuming the

00:27:50 it's been the project assuming the project started and miss evolving I was the PAX East that I would was responsible for and developing up where the building envelopes without the

00:28:01 the building envelopes without the facades and the roofs yes I see

00:28:09 and was that did that involve detailed facade design it was designed and build project as I recall it involved

00:28:25 designing the building at send facades to a level of architectural intent

00:28:37 to a level of architectural intent out-sing right okay we will come back to look at yeah what that means later on in your in your evidence did it involve the procurement of materials for the facade your involvement selection and

00:28:48 your involvement selection and procurement

00:28:58 up to a point can you help us what point and for example it was pretty obvious from the investor studies you do and you when you start till I say explore options with the facade and design it

00:29:10 options with the facade and design it that okay you might want this material of that material for it to appear as our many amor terracotta whatever you happen to choose so yes we knew how we wanted

00:29:21 to choose so yes we knew how we wanted to look and it was reviewed internally from the perspective of his appearance but when it was when I went to tend or there are aspects of it that were

00:29:32 there are aspects of it that were discretion the specialist cladding contractor to to procure and specify I see thank you and now I do want to turn

00:29:46 see thank you and now I do want to turn back to the product to the topic I was going to your introduction to the ground for our project yes all right now you worked as an associate architect on the benefit our project can I just ask you when you move

00:29:58 project can I just ask you when you move to Studio II in 2009 you came in I think as an associate didn't you no not recently I was meeting associated quite quickly I see all right

00:30:11 associated quite quickly I see all right at the point you you joined studio II in 2009 can you remember who your your line manager was at for which worked with

00:30:22 manager was at for which worked with Andre director-level right yeah and they say just Andre not not other and later director the other tracks that time would have been Gary

00:30:33 tracks that time would have been Gary and David and I don't think I've ever actually what directly alright and what about mr. Sains Bruce owns yes he was

00:30:45 about mr. Sains Bruce owns yes he was already there was he more senior to you or when you were appointed to a associate level soon after your joining it was he at the same level as you or he was he more senior to you when I started

00:30:57 was he more senior to you when I started the studio II Bruce was senior to me in the first project I worked on dark academy he'd he'd been working on with Andre and I slotted in underneath him when I got

00:31:09 I slotted in underneath him when I got Madon Madon an associate other briefs there went by the title of associate I consider him senior to myself I see was

00:31:21 consider him senior to myself I see was that did there ever come a time when you considered him no longer a senior to you but but you're equal in terms of the hierarchy at that studio II he may not

00:31:32 hierarchy at that studio II he may not have seen it the same way but that doesn't matter I think to be fair and to be respectful given the time that he'd been there and standing within the practice he'd probably be viewed as slightly senior to

00:31:44 probably be viewed as slightly senior to myself thank you now your involvement in the Grenville tower project started in July 2014 I

00:31:56 tower project started in July 2014 I think didn't it initially yes initially and were you the formal project architect at that point or did that come later well the term architect I believe

00:32:10 later well the term architect I believe is protected and so technically I can't call myself an architect I don't have a part three I followed yeah but were you occupying in practical terms the same

00:32:22 occupying in practical terms the same role that a project architect would carry would would carry out from that point on when I started it was very much a faced introduction to the project I

00:32:34 a faced introduction to the project I think somewhere in my witness they many mentions there's an initial contact with Building Control which was logical because of my involvement in calc yeah but myself if you like day-to-day

00:32:48 yeah but myself if you like day-to-day involvement in grandpa was feast and and wasn't it wasn't that in mid-july to control of all the reigns and bris still

00:33:00 control of all the reigns and bris still very much involved particularly with aspects where he had the continuity for example the planning and so on so if you're like when I started I was working

00:33:11 you're like when I started I was working I would say to his instruction and but this do certain things you're aware of that had to be done and so he truly was - my fault

00:33:22 was - my fault yes do you know do you remember who appointed you to the role that you were appointed to on the rental tower project it it's been a management insertion

00:33:34 it it's been a management insertion because the the is almost the equation of the practicies workload and the people available to work on it and so it would be it would have been a decision

00:33:46 would be it would have been a decision that bris non-derivative taking I see and now mr. Sainz told us in his evidence on and it just for the transcript it's day six page 172 at line 19 that a project architect

00:33:58 at line 19 that a project architect would normally be someone that has completed their part three examination would you agree with that normally but

00:34:09 would you agree with that normally but not exclusively but is that I mean this loose well I don't go off topic but there's plenty of practices that have very senior people who are not fully qualified right and in the light of your

00:34:26 qualified right and in the light of your experience are up to the point we've discussed so far is it fair to say and if it's not please tell me that you when you started work on the grenfell tower project in July 2014 you had no real

00:34:38 project in July 2014 you had no real experience of refurbishment of an existing high-rise residential building

00:34:45 yeah now I'm going to ask you some questions next about your about your practice and your continuing professional development within studio

00:34:57 professional development within studio II yes

00:35:01 can I ask you please first to look at se a three zeros one four four two one

00:35:17 this is the studio II LLP training policy dated the 1st of February 2013 you see that mm-hmm when it comes out well that's the first page of it if I can look at page 2 under

00:35:31 page of it if I can look at page 2 under CPD in the in the left hand column to

00:35:42 CPD in the in the left hand column to the second paragraph down under CPD it says the practice operates a continuing professional development system for all members of the office you see that yes

00:35:54 members of the office you see that yes if it is based on the Riv a CPD policy required of its members and can be split into formal accredited courses or seminars and informal in-house research or training sessions the detail of the

00:36:06 or training sessions the detail of the CPD policy can be found in the CPD procedure sheet the our iba requires individuals to accumulate a minimum of 100 points of formal and informal training during the year and then at the

00:36:18 training during the year and then at the very bottom well just a bit lower down than that it says in the next paragraph second line down CPD professional development plans we see that are

00:36:30 development plans we see that are submitted by each member of staff annually with the CPD record sheets submitted for the four director review prior to the staff reviews each year and then at just one more bit for you to look at mr. Crawford at the very bottom

00:36:41 look at mr. Crawford at the very bottom of that column it says the bottom of the page all partners and staff within studio LLP participate in the company's continuing professional development now

00:36:52 continuing professional development now as I say that was as a 2013 February 2013 just a few questions about it did

00:37:03 2013 just a few questions about it did you create and update a CPD plan I certainly taken all the CPD sessions that we had I did fill in plan by their

00:37:15 that we had I did fill in plan by their affiliate and diligently every year that you know sta I'm not sure did you submit those that you did create and update force director review the

00:37:28 and update force director review the that recorded our CPD attendants were held by our office manager and a form required to fill I know sheets I said

00:37:42 required to fill I know sheets I said when we attended a CPD seminar I see and did the office manager keep records that they collected from you they kept the ultimate records yes do you happen to

00:37:53 ultimate records yes do you happen to know whether they still exist I think some exists they don't love the Ahly all right now studio e's solicitors have disclosed lists of seminars that were

00:38:04 disclosed lists of seminars that were organized for studio e staff partners and staff in the years 2011 12 and 13

00:38:15 and staff in the years 2011 12 and 13 2016 and 2017 but not for 2014 and 2015 just to be clear for you we've been told that no training seminars were actually

00:38:27 that no training seminars were actually organized by Studio E in those years 2014 and 15 does that reflect your understanding yeah that probably does do

00:38:41 understanding yeah that probably does do you know why there were no training seminars organized by Studio E in those years I'm not sure whether though none organized I suspect there were some but

00:38:54 organized I suspect there were some but possibly not with the frequency of Valerie I think the practice

00:39:05 had some issues were change from the limited from the LLP but with limited and Telep even battery and limited and

00:39:16 and Telep even battery and limited and and so bother the two entities in existence and and we also had what would issues with the practice downsized and

00:39:28 issues with the practice downsized and moved location this may have been a factor in it I see but I mean having said all that all of CBT is it's not restricted to it's not restricted just to formal

00:39:41 it's not restricted just to formal seminars that of course multiple other aspects of CPD which which we are undertaken on continually and as individuals and and related to projects

00:39:52 individuals and and related to projects did you personally undertake your own CPD as you went along during those years I I think if out answer and see that you know if you're working you are because

00:40:04 know if you're working you are because you're you're constantly looking other buildings what's the visiting buildings constantly reviewing aspects of buildings that are interesting to you or

00:40:15 buildings that are interesting to you or relevant to you on projects did you fill in sorry you want to finish on us no I mean did you fill in CPD sheets and give them to the office manager in respect of those personal private CPD development

00:40:27 those personal private CPD development no she kept by the office manager inhalation - CPD logs were have Excel

00:40:38 inhalation - CPD logs were have Excel spreadsheet that were purely in relation to this the formal one-hour lunch time seminar I thought so to summarize it is this right that where there was a formal

00:40:50 this right that where there was a formal seminar put on for CPD there be an attendance sheet and that would go back to thee yeah to the office manager but where you did it privately by researching something online you wouldn't necessarily fill out oh no I

00:41:01 wouldn't necessarily fill out oh no I mean I think some some people might have kept their own logs because they would have been relevant to there are iba

00:41:09 requirement can we look please at a list of the seminars that were organized in the years when they were SCA please three zeros one four four two for the

00:41:22 three zeros one four four two for the stove mister operator and this is a CPD seminar list for 2010 and if we just look at that do you agree and we can see

00:41:33 look at that do you agree and we can see it but looking at the titles of those seminars there are no seminars listed there which would have been relevant to anybody's experience or learning for over cladding work or fire safety when I

00:41:48 over cladding work or fire safety when I say over cladding work overcrowding work on a high-rise building to over cladding specifically no yeah and what about fire safety

00:41:57 safety well well I would argue did some of those did have fire safety components to them for example just Swiss as part of their presentation would have discussed

00:42:10 their presentation would have discussed the product in relation to two fire I see side respect could you give me an example perhaps off of this page of where of which seminar might include a fire safety element um

00:42:23 fire safety element um um well wind because it's bathrooms heck fun me do because it's an internal lining product so the ceramics it's unlikely latch we smear pads may have

00:42:37 unlikely latch we smear pads may have had some overlap with that because it's a roof access system all the rest system all the ways have been normally associated with fire issues there's all

00:42:49 associated with fire issues there's all is floorings or there may have been some a little bit have been perhaps some issues in relation to the fire performance of the flooring the expanded metal company there may have been just

00:43:02 metal company there may have been just Swiss I suspect it would have been something because they didn't be limitations on how he used timber structures in relation to file

00:43:14 structures in relation to file and 3fx this is that this is computer visualization osorno yep okay it sounds very much from what you've just said that these were effectively

00:43:27 that these were effectively manufacturers of specific products coming in to the office and giving you a discussion or lecture or presentation

00:43:38 discussion or lecture or presentation about the topics there in the context of their own products that that's very much the way CPG seminars are run what

00:43:54 the way CPG seminars are run what happens is manufacturers and consultants and

00:44:04 get accredited together on our IBA CBT seminar if you're cynical we might say that there's a marketing dimension to

00:44:15 that there's a marketing dimension to some of that yes I'm just right well then let's let's look at some more specifically if you go to the next document which is se a three zeros 1 4 4

00:44:26 document which is se a three zeros 1 4 4 to 7 this is the seminar list for 2011 and I'd like you to look please at the third one down King fell fire safety

00:44:37 third one down King fell fire safety management and BS nine nine nine nine do you remember whether you attended that seminar 7th of September 2011 lunchtime

00:44:52 I can't say I recall what I did or not right does this trigger our recollection did it cover do you remember or do you remember a seminar on b4 of the building

00:45:04 remember a seminar on b4 of the building regulations involving someone called King fell victim a common conical okay

00:45:14 you can we look at the next document which is se a zero zero zero one four four two three please this is the 2012 list and in that list there is a seminar

00:45:30 list and in that list there is a seminar given on the 12th of September third up from the bottom where the CPD provider is Celotex and the description is using Celotex to meet part l 2010

00:45:42 Celotex to meet part l 2010 do you remember attending that seminar I may have done that one specifically now we can see it was given it was given by Celotex did did studio we have a contact at Celotex a Pacific contacts I'm not

00:45:57 at Celotex a Pacific contacts I'm not aware of

00:45:57 aware of do you know how and how Celotex came to get the invitation to provide the training to Studio E I don't know I mean it's not unusual for manufacturers to

00:46:10 it's not unusual for manufacturers to solicit to give seminars yes it may be that it's quite often quite it's often

00:46:21 that it's quite often quite it's often the case that I'm the products will be being used and another project and the the manufacturer or supplier or a consultant may offer to give a practice

00:46:33 consultant may offer to give a practice weight seminar off the back of that and see right and that offer would normally be made to whom would it come to the contact on the project or will it come through the office manager or a partner

00:46:45 through the office manager or a partner it might initially might go through the contact in the project that they'd usually be directed to the office manager to organize it right I see and

00:46:56 manager to organize it right I see and just it I know it's difficult but your experience overall would would most of these seminars be instigated by the the product producer or would there be instigated at an invitation from Studio

00:47:09 instigated at an invitation from Studio II to that product producer no I I think it thinking back there's been cases where we've as a practice ask people to volunteer suggestions for CPD seminars

00:47:25 volunteer suggestions for CPD seminars because they were you know of interest are relevant to them but sometimes but but they can't come from all these different angles yeah I see when you say when you say

00:47:36 yeah I see when you say when you say people in that last not so do you mean you mean laugh staff yeah okay

00:47:42 but I think you told it you can't recall whether you attended this on or not just like this seminar that specific one I kind of a called its affinity further right okay can I ask you then to look at

00:47:55 right okay can I ask you then to look at the next one which is 2013 se a triple zero one four four to zero

00:48:07 this is 2013 by now-familiar list of lunchtime seminars from provide suppliers of materials there's a seminar

00:48:19 suppliers of materials there's a seminar second down butler and young 17th of april and the topic is building regulations update do you remember whether you attended that seminar I may have done I really

00:48:30 that seminar I may have done I really can't say definitively who were Butler and young but learn young well among

00:48:41 and young but learn young well among other things there are improved inspectors I see approved inspectors being deprived privatized version of

00:48:52 being deprived privatized version of Building Control that's what I was going to suggest right I see if you did you can you please look

00:49:04 I see if you did you can you please look at the next one which is 2016 which is se a triple zero one four four one nine

00:49:17 this is 2016 5 seminars in that year between March and November and the first one is tetra consulting new CDM regulations 2015 you see that yes did

00:49:29 regulations 2015 you see that yes did you do you remember whether you went to that thinking it would have been quite an important one I mean yes because it's been the principal designer role yes and

00:49:41 been the principal designer role yes and that's twenty sixth of sorry 23rd of March 2016 and the regulations I think had come in in the or come into force in the October of the previous yeah do you

00:49:52 the October of the previous yeah do you remember that yes that's correct so and who are tetra consulting

00:50:02 I'm not sure I could see definitively right say can we can we proceed on the assumption and if we can't please say that by the spring March of 2016 you

00:50:15 that by the spring March of 2016 you were reasonably familiar with the new CDM regulations 2015 I was familiar with the BART caveat man because I think the

00:50:28 the BART caveat man because I think the industry full stop is struggling to get his head around what the new CDM 2015 regulations actually were all right so it's serious familiar with them I'd say as familiar with the issues that are

00:50:39 as familiar with the issues that are presenting fair enough and then finally on this list can I ask you please to look at se a triple zero 1 4 4 2 2 which is the seminars for 2017 from February

00:50:53 is the seminars for 2017 from February to November and if you look at the seminar just below halfway down trimco ill brook you see that there there's a

00:51:06 ill brook you see that there there's a seminar in on the 21st of June at lunchtime a guide to detailing of interfaces on Windows and facades do you did you attend that seminar do you think I consider definitively right it's it

00:51:21 I consider definitively right it's it postdates the fire but my question is did do you remember what had given rise to a need within Studio e to have a cinema a seminar on that subject matter

00:51:36 I mean you see it push states the fire but by a week yeah indeed and so these a thesis seminars just have been organized

00:51:48 thesis seminars just have been organized and advanced it exactly and so the question is I put it again the question is do you remember what had given rise to a need within studio e to have a seminar on that subject matter I thought

00:52:01 seminar on that subject matter I thought that would have been a Pacific elite I think it's just that you go through a variety of subjects and topics and that

00:52:12 variety of subjects and topics and that one was deemed appropriate and I mean I'm sure there was a specific need in that sense and who are trimco ill Brooke do you know I'm not entirely sure

00:52:24 do you know I'm not entirely sure actually that I'm connected do you remember whether you went to that seminar

00:52:31 seminar I can't definitively say right do more generally a mr. Crawford prior to or or during your work on the ground felt our project did you ever attend any training

00:52:44 project did you ever attend any training on the Part B 4 of the building regulations specific before training well any training which was on or perhaps included Part B four of the

00:52:57 perhaps included Part B four of the building regulations it's possible but you know the regulations are building regulations are so extensive the unusual

00:53:12 regulations are so extensive the unusual think of them in those terms in terms of CBD sometimes right and and I take it that the same answer would apply to a question relating to approved document b

00:53:23 question relating to approved document b did you ever a train ever attend any training on approved document b and specific training yes in isolation no I

00:53:35 specific training yes in isolation no I can't think well either in isolation or together with other blood this is the point I'm trying to make I think with the other related topics it's inevitable so for example if you have someone who comes in and talks let's say they talk

00:53:46 comes in and talks let's say they talk about cladding system or something like that then they're going to reference Part B I see okay see what saying so for example we might even something as

00:53:58 example we might even something as mundane as flooring it might start to reference you know sustainability and other parts of the regulations relevant to that it's not that you've had a specific session on right well do you

00:54:11 specific session on right well do you remember ever having any incidental training as part of a wider topic on either Part B four of the building regulations or approved document b specifically not that i rid of

00:54:23 specifically not that i rid of inevitably and just a couple of more questions a lot on a similar topic prior to or during your work on the ground fault our project do you recall ever

00:54:35 fault our project do you recall ever attending any training on how to design a rainscreen cladding system and did you ever attend any training specifically or

00:54:47 ever attend any training specifically or as part of a wider topic on fire classification and testing and certification of materials mr. chair and

00:54:59 certification of materials mr. chair and I'm going to turn to a different topic but we have been going justjust just about 55 minutes I'm happy to continue if the witness is happy to continue well

00:55:11 if the witness is happy to continue well surely have at least one rate during the morning

00:55:17 morning you take roughly halfway through the morning but we can have more frequent breaks

00:55:23 breaks the witness feel so that would be helpful how do you feel would you like a break now or do you have to carry on for another 25 minutes I prefer hourly breaks to be honest yeah

00:55:36 I prefer hourly breaks to be honest yeah so you'd like to break now well it's a good time for mr. Miller it was yeah well then we'll break now resume at five past eleven ten minutes

00:55:47 resume at five past eleven ten minutes time a bit of stretching legs of sir can I ask you please not to talk about your evidence or anything related to it well your until you've finished all together yes

00:56:07 five hours to lemon please

01:05:56 yes we met have mr. Crawford back please

01:06:10 all right mr. Crawford yes Thank You mr. minute thank you very much mr. chairman mr. Crawford I'm now going to turn to a new topic which is your familiarity with

01:06:21 new topic which is your familiarity with the building regulations and ADB which we've already touched on and at the moment I'm just going to keep these quite quite general at the start of your work on the ground felt our refurbishment in in July 2014 were you

01:06:35 refurbishment in in July 2014 were you generally aware of the requirements of Schedule one Part B fire safety of the Building Regulations 2010 generally yes generally yes and were you generally

01:06:48 generally yes and were you generally aware of Part B three internal fire spread generally yes okay and were you generally aware of Part B for external fire spread yes at the start of your

01:07:02 fire spread yes at the start of your work on the ground felt our project did you take any steps to familiarize yourself refresh your memory with the requirements of schedule 1 parts b3 and b4 internal and external fire spread

01:07:22 out of Luke tonton we are an FF thought they were relevant as they came up okay so you'd is this fair generally you would consult them both the regulation

01:07:35 would consult them both the regulation and the and the schedule it hasn't when you thought you needed to look at them yes I see more generally do

01:07:47 look at them yes I see more generally do you do you agree with the general proposition that fire safety is fundamental to the work of an architect's practice yes and do you accept and this is a proposition that I

01:07:58 accept and this is a proposition that I want your comment on that any competent architect would at least have an awareness of the existence importance and the purpose of the provisions within the building regulations and the related approved documents yes at the outset of

01:08:13 approved documents yes at the outset of your work on the ground-floor tower of refurbishment did you take any steps to familiarize yourself with the guidance in approved document b on fire safety

01:08:30 again alone as in when basis so can I take it from that that you didn't sit down open an approved document b and read it through when you started your

01:08:41 read it through when you started your work on them no I don't believe any architects so can we take it from that

01:08:55 architects so can we take it from that that there was no time during your work on the project that you thought yourself well I must sit down and actually have a place look at approved document b and scan through it if i felt there was

01:09:06 scan through it if i felt there was something in it that i needed to be aware of and did you actually ever was there an occasion when you did consult approved document b specifically on the

01:09:18 approved document b specifically on the grove word yes and could you just just in general terms can you remember what the what the issue was for which you were consulting approved document b but one wood had been cavity by Rose

01:09:31 but one wood had been cavity by Rose cavity barriers anything else well one of the first tasks I looked at when I started work on the project was the

01:09:47 started work on the project was the changes being made to the lower floors and in fact well as I understand that they consistently changes being made and when I started one of the things Bruce

01:09:59 when I started one of the things Bruce alerted me to was that some of the the client my client I mean Katie CMO that

01:10:10 client my client I mean Katie CMO that wanted to make some additional changes to the configurations of mezzanine and walkway level and in doing those

01:10:21 walkway level and in doing those departme I see we'll come to this in a bit more detail into your course mr. Crawford comfortable yeah but we'll come to this in detail in a bit more detail

01:10:33 to this in detail in a bit more detail into your course but just while we're on the topic do you ever recall any issue arising which prompted you to look at

01:10:44 arising which prompted you to look at that part of approved document b which dealt with external wall construction

01:10:52 i'm certainly certainly familiar with diagram 40 writes down wall construction and the sections that relate to relevant

01:11:03 and the sections that relate to relevant boundaries for example I see but things like relevant boundaries you'd be looking at more start of a project I mean one of the things when you come on

01:11:15 mean one of the things when you come on to project particularly very late which which I was was coming on it GTL stages those things have already been covered and dealt with

01:11:27 have already been covered and dealt with so you even back to the start to check right unless you unless you felt there's something inherently wrong with you say

01:11:41 something inherently wrong with you say in your last answer that you came onto Grenfell at at at a very late stage and that you said the transcribers got it down as JTL jko well in the old work

01:11:53 down as JTL jko well in the old work stage he's not aware of any t-section gkl right okay well we'll come back to look at that later just in again a general question what was your understanding of the purpose of approved

01:12:06 understanding of the purpose of approved document b document B is guidance to to fire regulations

01:12:17 fire regulations it consists of five sections that deal with different aspects yes now can I just ask you about your knowledge of

01:12:28 just ask you about your knowledge of Industry guidance related to fire risks as an architect working on the ground floor tower project can we take it that you were keeping abreast of developments in the industry oh you you can't

01:12:40 in the industry oh you you can't technically caught me an architect I'm so sorry alright and or short what what should I call you then okay all right

01:12:51 should I call you then okay all right as the project need then on the Granville tower project were you keeping abreast of developments in the industry that concerned the projects that you were were working on by by keeping

01:13:02 were were working on by by keeping abreast

01:13:03 abreast if you mean keeping up with yeah I'm I I'm a reading less a building design are disease nor whatever

01:13:14 disease nor whatever architectural related press there as though they're yes al decayed lists but I don't I don't I'm I'm not actively looking for for specific publications on specific

01:13:30 for specific publications on specific issues at last I feel impertinence what I'm doing

01:13:32 I'm doing did you keep yourself up to date with relevant industry guidance on the subject of cladding and external wall constructions well

01:13:45 my expense it's you probably seen from the Seabees has been dealing with a lot of different types of cladding and different types of buildings and so

01:13:59 different types of buildings and so every time you do a new project and you're looking at new type of cladding then you start looking at those things I think when you inherent a project or

01:14:10 I think when you inherent a project or start working on a project further down the line when I think those decisions have already been made and then you wouldn't necessarily be going out and looking in the same capacity those

01:14:24 looking in the same capacity those things you might look if you thought there's something inherently wrong and what you're inheriting by otherwise you ain't even beat so yeah you wouldn't

01:14:37 ain't even beat so yeah you wouldn't even be analyzing that information in the same context yes okay um I'm gonna move to a different topic just before I

01:14:48 move to a different topic just before I do can I go back one which is which relates to approved document b when you started working on the ground fault our project were you aware of that there were special rules covering external

01:15:00 were special rules covering external wall construction above 80 meters yes that's right I'll come back to we'll

01:15:11 that's right I'll come back to we'll come back to the proof document be later in your evidence I now want to change topic if I can and ask you some questions about the contract between studio E and writin were you involved in

01:15:24 studio E and writin were you involved in any way in the negotiation of the contract between studio E and writin no not now we know that ridin ridin and se a limited the Anthony agreed I can call bespoke or

01:15:38 Anthony agreed I can call bespoke or tailored contractual terms and we know that that the that produced a final document a deed of appointment in February 2016 do you remember that yes yes and can I

01:15:52 do you remember that yes yes and can I show you that please that is ry d three zeros 9 4 2 8 a 2 2 8 ry d 30s and it's dated the 3rd of February 2016

01:16:05 dated the 3rd of February 2016 between ride and maintenance limited contractor and studio II architects limited consultant and it's a deed of appointment do you remember whether you saw this

01:16:16 do you remember whether you saw this deed at the time it was executed 3rd of February 2016 or thereabouts

01:16:23 no I remember what happened with this deed issued you can see right to the end in the project and I remember being on

01:16:35 in the project and I remember being on sites and Steven blank tape issues I can remember one of them asked me to chase

01:16:46 remember one of them asked me to chase the appointment relative to Britain Andre Louis Bruce back at the office in terms of getting it signed off but I had no I hadn't off review of the document

01:17:00 no I hadn't off review of the document and see what I mean so I knew of it but I was involved in the sign off of it or the content of it just to be clear you the transcribers got you down as saying you've got no overview or had no

01:17:12 you've got no overview or had no overview did you have an overview or did you not have any no I had an overview in the sense that I knew the document existed right but not its content I see yeah see can I take it you never saw a

01:17:23 yeah see can I take it you never saw a draft of this before it was executed no all right

01:17:26 all right what about after it was executed did you did you have did you see it not my only knowledge in relation to the

01:17:35 the draft after it was executed is those asked issue as built drawings the next day something summer I see did mr. stones ever tell you or mr.

01:17:48 did mr. stones ever tell you or mr. kachelle ever tell you at least the gist of what was in the document I was aware that it generated some stress because we

01:18:04 that it generated some stress because we were effectively being held to ransom in our final payment so I was aware of the stress that was generating that's in that label if you like but Bruce and

01:18:17 that label if you like but Bruce and Andre would have been did isolate that from me but I was aware right let's um go back in time then to April 2014 which

01:18:31 go back in time then to April 2014 which i think is before your involvement and can I ask you please to be shown ry d zero zero zero one four two one five

01:18:44 now this is a letter dated the 17th of April 2014 which was sent to mr. stones

01:18:57 April 2014 which was sent to mr. stones by Simon Lawrence and if you look at page one you can see that it's and you

01:19:09 page one you can see that it's and you can see the half way down contains a number of terms of the appointment governing the appointment of studio II

01:19:20 governing the appointment of studio II by writin and if you go to page three you can see that there is a schedule of architectural services I'm going to look at that with you in a moment in a bit

01:19:31 at that with you in a moment in a bit more detail but you can see that there are some balloon comments on the right-hand side of the document which mr. stones put in when sending this back to mr. Lawrence my first question is did

01:19:44 to mr. Lawrence my first question is did you see this document in this form or even another form when you joined the project in the summer of 2014 no I don't believe edit did you ever see

01:19:58 no I don't believe edit did you ever see this document do you think I don't think so did mr. Sains ever explain to you that there was a draft contract in

01:20:10 that there was a draft contract in existence which he was discussing with Simon Lawrence

01:20:15 I may have been subliminally aware of it but it wasn't in the sense that the superest had been running with the project from the start and so he'd been

01:20:26 project from the start and so he'd been dealing with contractual matters I guess from the outside so I may have been suddenly aware that those were going on just because his proximity to me and

01:20:37 just because his proximity to me and office at that time thank you so obviously but I personally was not involved with the contract or its contents or repeating it and seeing it

01:20:49 contents or repeating it and seeing it did when you join the project did you have a discussion with mr. stones or indeed anybody else's Thierry about the

01:21:00 indeed anybody else's Thierry about the terms on which to do II was then working I don't recall having that kind of conversation for example the handover

01:21:11 conversation for example the handover meeting but I think took place would have been to discuss more what was outstanding and wanted to be done to

01:21:22 outstanding and wanted to be done to complete the project recall having art and I see a conversation about it contract miss contents or requirements do you remember roughly when the handover meeting took

01:21:34 roughly when the handover meeting took place

01:21:39 August 2 1 4 August 2014 you think yeah ok September August I think it's August 2014 right were you working on the

01:21:52 2014 right were you working on the ground filter project before that handover yes I mean I think that handle one meeting was meant to be unheard of you know we sit down and this is we were

01:22:03 you know we sit down and this is we were our this is what I wanted to a chance meeting that meeting did who was present mr. Sains more slightly between the two

01:22:15 mr. Sains more slightly between the two of us

01:22:16 of us did mr. sands give you a file of document important documents relating to the project no although it'd be unlikely

01:22:28 the project no although it'd be unlikely for Bruce to give me a hard copy of anything because of the thing he'll direct chronically and especially Bruce is paperless office in terms of this

01:22:40 is paperless office in terms of this board of markings no he does have a lot of paper by he's he's more people less than most of us did mr. Sainz give you a list of documents that that would have been obvious to you but you should look

01:22:52 been obvious to you but you should look at such as the the stage D or stage e reports I think I asked to see the staging in fact he had a hard copy

01:23:04 staging in fact he had a hard copy contradict myself he had a hard copy of the state of the tender said well we'll come back and look in in in due course in your evidence to that yeah just focusing on

01:23:16 evidence to that yeah just focusing on that handover meeting do we take do I take it that there was nothing discussed between you as to the terms on which to do II was currently engaged well let's

01:23:29 do II was currently engaged well let's see I News design and built and the objectives in terms of what was expected of us

01:23:40 of us he would have made clear to me you say you knew it was designed and build who did you think at that stage studio ease client was I knew ruby novated to Ryden

01:23:52 client was I knew ruby novated to Ryden I see and did you not think to ask mr. stones about what terms studio he had

01:24:03 stones about what terms studio he had been devoted to novated to ridin on well he may have explained those to me he's quite probable youth I mean I

01:24:15 he's quite probable youth I mean I suppose from my earlier point where I was talking about discussing the expectations of what I was to be working on its kind of rolled together with the

01:24:28 on its kind of rolled together with the sense

01:24:29 sense did you ask or did you seek from mr. stones a clear explanation about what studio he had actually agreed with ridin

01:24:40 studio he had actually agreed with ridin it would do

01:24:48 but I think as I mentioned the the conversation was more about what their expectation was to complete the project you know the extent of the design work that being completed and things that hadn't been in terms of strength so line

01:25:04 hadn't been in terms of strength so line by line contractual interpretation of that know how did you think you were going to be able to perform your role as project architect without knowing with some degree of precision what the terms

01:25:15 some degree of precision what the terms of the D&B contract were well again coming back to what I said earlier that the handover meeting Bruce was explaining what the expectation was in

01:25:28 explaining what the expectation was in terms of what I'd be working on to completion of the project

01:25:38 did let's look at the draft that's on the screen at the moment can I just look at that with you if you go to the shed you'll on page 3 this is the 17th of

01:25:50 you'll on page 3 this is the 17th of April 2014 draft schedule of architectural services you can see at item 4 under generally seek to ensure

01:26:03 item 4 under generally seek to ensure that all aspects of the architectural designs comply with the employers requirement documents prepared by RT Lea did you know when you came into the project that so that is something or

01:26:15 project that so that is something or that obligation was something which was even if not formally in place something which right an expected of Studio E

01:26:29 I would expect um architectural designs to comply with employers requirements except what you asked

01:26:41 except what you asked not quite my question was did you know when you came into the project that studio that that ridin was expecting studio II to seek to ensure that all

01:26:52 studio II to seek to ensure that all aspects of the architectural designs comply with the employers requirement documents prepared by Artie Leah

01:27:19 I'm not sure okay I've got a few questions of the same nature in relation to one or two of these other clauses look at five and they are drafts of

01:27:30 look at five and they are drafts of course did advise the contractor wherein the architect's opinion there are short falls within the employers requirements and advise of the assumptions to be made when you came into the project did you

01:27:41 when you came into the project did you know or did mr. sane to tell you that Ryden were expecting studio e to advise the contractor in other words writing wherein the architect's opinion there are short falls within the employer's

01:27:53 are short falls within the employer's requirements and advise of assumptions to be made did he tell you that

01:28:13 I think if you saw something that was explicitly a shortfall you would highlight it but I don't remember explicitly being quoted that terminology

01:28:27 explicitly being quoted that terminology very well in in relation to number 7 Clause 7 obtained building regulation approval for and on behalf of the contractor and there's a there's a

01:28:39 contractor and there's a there's a comment there perhaps we could pass over that looking at 10 seek to ensure that all designs comply with all relevant health technical memorandums all relevant health building notes fire code

01:28:51 relevant health building notes fire code and any other relevant NHS publications did mr. Sains tell you that that is what Ryden were after but he was resisting it he didn't I'm not worthy well I don't

01:29:03 he didn't I'm not worthy well I don't recall them categorically telling them that then I wouldn't expect see Clause like that right just just a few more if you turn the page please to page 4 I'm

01:29:17 you turn the page please to page 4 I'm gonna say a clause like that time in the NHS commented and I'm say sir I'd given you a wrong reference if you go to stay on page 3 and go back up a little I want

01:29:30 on page 3 and go back up a little I want you to look at number 8 which says seek to ensure that all designs comply with the relevant statutory requirements including scheme development standards mm-hmm

01:29:39 mm-hmm did mr. sands tell you that Ryden were expen when you came into the project expecting that studio II would seek to ensure that all designs comply with the relevant statutory requirements

01:29:50 relevant statutory requirements including scheme development standards I don't recall they explicitly told me that birds probably expect that thank you for you expect you would expect

01:30:02 you for you expect you would expect Studio II to be under that obligation yeah yes and looking at number 20 on page 4 if you could please provide as

01:30:14 page 4 if you could please provide as built drawings when required did mr. stone tell you that Ryden were expecting Studio II to provide as built drawings when required or again was that something you would ordinarily expect today I don't think you'd know ensued

01:30:28 today I don't think you'd know ensued order not expect expected that said it's not unusual but I wasn't aware that we

01:30:39 not unusual but I wasn't aware that we that we had to

01:30:47 I see looking at page four number twenty-eight provide the contractor with general arrangement drawings interface

01:30:59 general arrangement drawings interface details performance specifications and other technical information reasonably necessary to see quotations from subcontractors and suppliers was that something that mr. stones told you when

01:31:11 something that mr. stones told you when you came into the project that Ryden were expecting studio II to do

01:31:21 well I'll targeted that information already existed in the tender sellers stage II information but in response to

01:31:34 stage II information but in response to a specific question he didn't specifically tell me that you didn't and then number 29 just below it examine subcontractors and suppliers drawings and details with particular reference to

01:31:46 and details with particular reference to tolerances and dimensional coordination finish durability appearance and performance criteria and report to the contractor did mr. Soames ever tell you when you came into the project is that

01:31:58 when you came into the project is that Ryden were expecting Studio II to do that

01:32:11 he didn't explicitly tell me it's do that but I'd like to assume that and then if you look please over the page of

01:32:23 then if you look please over the page of page 5 unless they're parked sorry I'm so sorry you wanted yeah a recent parked at least in part yeah which part

01:32:38 at least in part yeah which part I'm so sorry to get back which part would you think with you would well I think the bit where I hesitate slightly is performance and precisely what is

01:32:49 is performance and precisely what is meant by that right does that mean that if mr. sands hadn't explained to you that that was what right and we're expecting you you wouldn't you wouldn't expect to have to advise well I have to

01:33:03 expect to have to advise well I have to examine the subcontractors and suppliers drawings with a particular reference to performance again again it means to find performance but yes or performance

01:33:14 performance but yes or performance criteria see and then if you can go back where I was going to which is page five

01:33:24 paragraph 33 provide supplementary notes to drawings and provide further drawings to show sufficient information to construct the project to completion

01:33:36 construct the project to completion consisting but not limited to the following and then there's a long list a tutti a external wall stroke internal wall and partition construction details

01:33:50 wall and partition construction details again is is that something which mr. stone told you Ryden were expecting studio II to do list

01:34:02 studio II to do list right

01:34:10 so would it be fair and if it isn't fair please say but it wouldn't be fair to summarize your position in the summer of 2014 when you came into the project that

01:34:23 2014 when you came into the project that you were not aware of the of the precise obligations the studio II either had undertaken all was expected by riding to

01:34:34 undertaken all was expected by riding to undertake to them I think my understanding of the obligations came from verbal discussion with Brits so you

01:34:46 from verbal discussion with Brits so you know your question have I seen precisely this list and checked off no my obligations were understood from the conversations with Bruce in relation to

01:34:58 conversations with Bruce in relation to where the project was and what the final expectation was can I then look at the deed with you which we looked at earlier the 2016 deed of appointment RI ry d

01:35:13 the 2016 deed of appointment RI ry d triple zero nine four two two eight at page three

01:35:22 - I want to look at a little bit more detail with you because we know that this was what was formally executed now I know and again you didn't see it at the time but I just want to see if I can get your sense of where matters stood

01:35:36 get your sense of where matters stood can I ask you please to give look at paragraph two point three the consultant warrants that it is exercised and will continue to exercise reasonable skill

01:35:47 continue to exercise reasonable skill and care and diligence in the discharge of the services to the standard reasonably to be expected of a competent professional experienced in the provision of professional services to work similar to the size scope complexity quality and nature of the

01:36:00 complexity quality and nature of the development were you at any time aware that studio II had made that warranty no

01:36:14 that studio II had made that warranty no I mean let me rephrase I knew I think I would have known there's a there was a warrant in place but not the specifics

01:36:26 warrant in place but not the specifics of it right so - one of the specifics of its but is that it was warranting that it has in the past exercised reasonable skill and care and diligence in the

01:36:38 skill and care and diligence in the discharge of the services which are defined did you know that in other words it was warranting it's it's past quality no

01:36:52 can I ask you to look at paragraph 8 on page 5 under the heading CDM regulations

01:37:04 page 5 under the heading CDM regulations the consultant is aware of the construction design and management regulations 2015 the CDM regulations and acknowledges that in relation to the services it is a designer as defined in

01:37:17 services it is a designer as defined in the CDM regulations and will use reasonable skill care and diligence to comply with its obligations and duties as a designer as defined and specified within the CDM regulations did you at

01:37:30 within the CDM regulations did you at the time this is February 16 have any understanding of what that required Studio e to do they've been a lot of discussion from the practice from the

01:37:41 discussion from the practice from the new 2015 regulations came in and the implications of principle design on whether that was something that

01:37:53 whether that was something that practiced foods adequately provided and the industry generally was struggling with how I think coming to terms with that new regulatory set through I

01:38:05 that new regulatory set through I understood the conversations to some extent in relation to that

01:38:14 yes I see so that's similar to what you told us before can I ask you then to turn on please to the annex which is page 8 of this document that's where it starts which is

01:38:29 document that's where it starts which is the shed you love architectural services and can I look please first of all at item 4 which we looked at in similar

01:38:40 item 4 which we looked at in similar terms same terms in the in the April 2014 draft seek to ensure that all aspects of the architectural designs

01:38:51 aspects of the architectural designs comply with the employers requirement documents prepared by RT Lea so similar question as at February 2016 was that something that you knew studio he had contractually promised to write

01:39:11 specifically no moving to item five advised the contractor wherein the architects opinion there are short falls within the employers requirements and advise of assumptions to be made again

01:39:23 advise of assumptions to be made again was that something that you knew Studio II who contractually promised to Ryden I didn't know categorically it contractually contractually obliged to

01:39:34 contractually contractually obliged to provide it bowed expected it an item seven responsibility for coordinating building regulation approval for and on behalf of the contractor did you know

01:39:46 behalf of the contractor did you know that studio he was obliged to Ryden to do that I understood that we had a responsibility for coordinating the Building Control submission and

01:40:00 Building Control submission and similarly statutory requirements including scheme development standards by February 16 did you know that studio he was obliged to do that item eight I'm

01:40:11 he was obliged to do that item eight I'm so sorry seek to ensure that all designs comply with relevant statutory requirements including scheme development standards again yeah again I didn't categorical categorical we know

01:40:22 didn't categorical categorical we know it but as soon that right and would you agree with me that statutory requirements would include the

01:40:33 requirements would include the obligations in the building regulations yes and the CDM regulations

01:40:43 yes and indeed as we look at I don't know it's just just so just to clarify this document isn't yeah he's he's from

01:40:54 this document isn't yeah he's he's from this is the deed of the 3rd of February 16 so this is the retrospect from science yes and the old designs

01:41:06 science yes and the old designs complying with the rel relative relevant statutory requirements and as far as put within this forest they were Arab designs that is that how you understood

01:41:19 designs that is that how you understood it yeah so you understood all designs where you say you say you haven't seen this document no but are you saying that all designs means all designs done by

01:41:31 all designs means all designs done by Studio E yes why do you say that well if you had a specialist if you had a specialist contractor then it'd be for

01:41:42 specialist contractor then it'd be for them to seek to comply with the regulations was that your understanding throughout your involvement in the Grenfell tower project yes did anybody tell you that that was what was agreed

01:41:55 tell you that that was what was agreed with Rhydon

01:41:59 categoric mm-hmm I don't think so did anybody tell you that or did you have did you have any discussions with in Studio E which reflected that

01:42:11 Studio E which reflected that understanding okay if I can cyst that back a bit I think cam I'm thinking specifically in terms of a few comments

01:42:23 specifically in terms of a few comments let's say if you comment on the cladding then we would comment from the perspective of architectural intent well we'll come we'll come to that in detail

01:42:34 we'll come we'll come to that in detail in relation to some specific documents in due course so I'll Park the questions on that for that for the moment just looking at item nine obligation to produce a CDM design

01:42:45 nine obligation to produce a CDM design risk assessment did you know this to do II was obliged to do that well we did have our own internal risk assessment yeah and then item eleven cooperate I'm

01:42:57 yeah and then item eleven cooperate I'm so sorry

01:42:59 so sorry yes item 11 studio II to cooperate with the contractors buying department into consideration and selection of alternative materials did you know that studio he was obliged to do that not

01:43:15 studio he was obliged to do that not categorically no item twelve with other consultants we're appointed developed the scheme designs agree with the contractor the type of construction and quality selection of materials did you

01:43:27 quality selection of materials did you know that studio he was obliged to do that

01:43:48 not categorically item 13 I'm sorry sorry can I just see him yes these are all taken from a document that I've said there I didn't look at a review so I

01:44:02 there I didn't look at a review so I can't categorically see that in any of them that they understood that no I indeed I understand that all I'm asking you for is your understanding without the document but they're given this is

01:44:14 the document but they're given this is what the document says yeah and I take it that that's how you understood my questions yes okay thank you very much and then item 13 kill coordinate any

01:44:27 and then item 13 kill coordinate any design work done by consultants specialist contractors subcontractors and suppliers and very sorry same question again did you know the studio he was obliged to do that

01:44:52 it's quite quite general statement well

01:45:04 and it could coordinating the sense of lead designer I guess right and then if we move down the page to item 27 when

01:45:18 we move down the page to item 27 when our page should be on page 10 we've already looked at at at 19 as-built drawings and item 21 provide a

01:45:30 drawings and item 21 provide a collateral warranty for all designs as detailed in the employer's requirements did you know that studio II had agreed to do that to provide a collateral warranty for all designs as detailed in

01:45:44 warranty for all designs as detailed in the employer's requirements no did right you know what I mean by collateral warranty I understood you've got collateral warranty required but it's

01:45:55 collateral warranty required but it's not specifically in those terms right item 27 examine subcontractors and suppliers drawings and details with

01:46:06 suppliers drawings and details with particular reference to tolerances and dimensional coordination finish durability appearance and performance criteria and report to the contractor did you know this to do he was obliged

01:46:17 did you know this to do he was obliged to Ryden to do that and again we see that before the performance criteria phrase used yeah Minister sent in comments before okay and second from last you'd be glad to

01:46:32 and second from last you'd be glad to hear item 30 superstructures there's an obligation there to provide design and provide gents right to design and provide general arrangement drawings as

01:46:43 provide general arrangement drawings as follows you see that yes did you and there's a list of things there did you know that studio II was obliged to do that all those

01:46:55 II was obliged to do that all those things

01:46:58 I think we didn't do that so I see today know that we were obliged to do it yes

01:47:07 no but we did I knew that we hadn't done that I see and and then under 31 just

01:47:23 that I see and and then under 31 just over the next page page 11 studio he was required to provide supplementary notes to drawings and provide further drawings to show sufficient information to

01:47:34 to show sufficient information to construct the project to completion consisting but not limited to the following and then a external wall internal wall and partition construction details 120 110 1 what one in twenty one

01:47:47 details 120 110 1 what one in twenty one in 10 one in five did you did you did you know that Studio II was obliged to provide external and internal wall and potash and construction details up to

01:47:59 potash and construction details up to one in five scale I was not worried that we had a specific obligation to produce Seward cific wall to specific details

01:48:12 Seward cific wall to specific details and then item C window jamb stroke head stroke sill details the same and again the same one in twenty one in 10 one in five it says one fifteen to one in five

01:48:23 five it says one fifteen to one in five did you know the studio he was to provide that specifically not specifically though and then at the very bottom of page twelve if I can ask you

01:48:34 bottom of page twelve if I can ask you to look at that it says site visits you see the very very bottom under under paragraph forty for site visits not twenty-five number is required

01:48:46 is required do you remember that being an obligation I wasn't aware of that as an obligation from this document for the reasons I mentioned before not seeing the document

01:48:57 mentioned before not seeing the document a bit it was brought to my attention very late in the project that that's always in fact an obligation [Applause]

01:49:09 you were the main project person I don't use the word architect in respect to the Granville tower from July 2014 would you

01:49:27 Granville tower from July 2014 would you normally run a project without having close familiarity with the either the proposed contractual terms or the actual contractual terms in a design and build

01:49:38 contractual terms in a design and build contract that you either were going to or had undertaken to the design and builder

01:49:44 builder I think there's a number of comments certainly can this I think um first of all I think it's not unusual for projects to run little contractor land

01:49:58 is also known usual for projects to run with very badly put together contracts they don't actually reflect or is being expected on site or by the contractor

01:50:11 expected on site or by the contractor it's not unusual to find projects free of contracts they are they've been pieced together from other contracts by contractors to the extent we are even

01:50:24 contractors to the extent we are even names and references are wrong in this instance to answer your question specifically Bruce is still very much the lead in terms of having the overview

01:50:35 the lead in terms of having the overview the project you what ton of him start to finish and he's bought specifically on the with Andre on the contractual side of things by briefing from Bruce was

01:50:46 of things by briefing from Bruce was what I was expected to do to complete the project so in this instance no I don't think I had been brought in

01:50:57 don't think I had been brought in earlier I had perhaps been more concerned with this not from the stage house and the workers being asked to do no so

01:51:08 no so at any time prior to February 2016 when the deed this deed of appointment with its deed of architectural services we've just looked at together was executed did

01:51:20 just looked at together was executed did anybody at Studio E Bruce stones or Andrea she'll ever come to you and art and ask you whether it was safe for studio II to enter into

01:51:31 was safe for studio II to enter into that the contractual undertakings we've just been looking at together on the 2016 no bows I think we did earlier this morning was that I was aware that we saw

01:51:44 morning was that I was aware that we saw it was an issue of there was troubling them because they were being held to

01:51:56 them because they were being held to ransom and the final payment and wonder pressure to him to sign an agreement can I go back to your statement well before

01:52:12 I go back to your statement well before I do I'm so sorry before I do do you are you in a position to agree with me and if you're not then they say that this

01:52:23 if you're not then they say that this document this this deed accurately reflects the services that Studio II have been appointed to provide to Ryden from the outset

01:52:37 from the outset I can't see because I wasn't involved from those so all right from the outset of the relationship with Rhydon but does the term the Novation

01:52:55 I think that there is have to be a question it's Bruce I see yeah all right but I less suspect not you suspect no yeah and why would you suspect not

01:53:08 because I don't think that was his understanding expectation we can explore that with him now can I just ask you three general

01:53:20 can I just ask you three general questions about about what studio he was required to do would you agree with me that Studio II was at least in general terms required to check for itself whether the design complied with the

01:53:31 whether the design complied with the building regulations with their own designs yes yes we're there your words your met you're adding a qualification yes I see

01:53:40 yes I see and that qualification I'm interested in where it comes from was it your your own private understanding or was it something you ever discussed within studio II either

01:53:51 ever discussed within studio II either with Bruce owns or with anybody else well so I think that terms are used for not what I was asking you whether the

01:54:02 not what I was asking you whether the qualification you're adding which was that you're no no before that

01:54:09 I'll rephrase the question again would you agree with me that Studio II was at least in general terms required to check for itself whether the design which was the basis of being the completion of the

01:54:22 the basis of being the completion of the building complied with the building regulations okay so yeah and my qualification was on the basis the this aspects of design which you are not

01:54:33 aspects of design which you are not involved in which are specialist design so for example if you have a specialist mechanical and electrical component then you're not you're not qualified to

01:54:44 you're not you're not qualified to verify Liz compliant how would you so that qualification was that something that you ever discussed internally within studio II I think that's what

01:55:01 within studio II I think that's what would have been assumed I mean no can you qualify compliance of something you have no knowledge of can you explain from your own

01:55:12 can you explain from your own understanding why it was that nobody at studio he put that qualification into the deed of appointment or ever told writin in terms that that was the

01:55:24 writin in terms that that was the limitation of studio is responsibilities so far as building regulation compliance was concerned

01:55:37 I think Bruce in somebody's comments on that earlier version of the contract went some way to addressing that when he shall seek to comply rather than or

01:55:49 shall seek to comply rather than or verify it complies right now in my in answer to my question a few moments ago you said that that you just find the

01:56:01 you said that that you just find the answer you wouldn't be expected to be involved in you would you you would not expect to be involved in a design way you which we were not involved in and

01:56:12 you which we were not involved in and this was line fourteen of page 67 but it's right isn't it that you that you as in studio II was definitely involved in

01:56:23 in studio II was definitely involved in the facade and the facade design so your previous reference I haven't seen that's just for the transcript but you when you answered my question a moment ago you

01:56:34 answered my question a moment ago you you said that your qualification was on the basis that this aspect of design which we were not involved in which was specialist designs and then you gave an example of a specialist mechanical and

01:56:46 example of a specialist mechanical and electrical component looking at that qualification you've introduced the facade was something that you were definitely involved in wasn't it you as

01:56:58 definitely involved in wasn't it you as in you and years in studio II yes we were involved in the design of it too until it was let as a specialist

01:57:12 contractor package observation and you say you're drawing a line are you between previous involvement and the

01:57:23 you between previous involvement and the time of Novation to answer the question I think you're asking and I know you've alluded to wanting to go on to later is what I'm seeing specifically is the cladding package commented on

01:57:36 cladding package commented on architectural intent

01:57:41 can I ask you then to look at your statement at se a triple zero one four to seven five at page seven and this is

01:58:00 to seven five at page seven and this is paragraph 14 please where you say Ryden was appointed as the main contractor on 30th of October 2014 after its appointment it took over

01:58:11 its appointment it took over responsibility for the design of the project following the Novation which is a common feature of projects procured under a design and build route C from paragraph 32 below when you say there

01:58:25 paragraph 32 below when you say there that Ryan took over responsibility for the design of the project do you mean that Riedel took over responsibility to the TMO for the design is that what you're saying no they took a

01:58:36 you're saying no they took a responsibility yes to whom who to whom are you saying that Ryden took took over that responsibility to to their client

01:58:49 that responsibility to to their client yes the okay now if we look then at paragraph 32 of your statement that's on page 14 of the same document

01:59:02 and you say in the last sentence there however under a main contract for a design and build project riding as the

01:59:14 design and build project riding as the main contractor is responsible for the design and construction of the project you say that it correct me if I'm wrong but it's right isn't it that Ryden appointed subcontractors and sub

01:59:26 appointed subcontractors and sub consultants actually to carry out the detailed design work on the facade and indeed other aspects of the project

01:59:35 yes but they sat under a ridin and Studio II after Novation was one of those sub contractors or subcontinent

01:59:46 those sub contractors or subcontinent sitting under ridin yes so if you go then to paragraph 34 of your statement same page just a bit lower down you say

01:59:59 same page just a bit lower down you say my understanding studio he was not involved in the contractual arrangements with sprite and subcontractors is that right and began to put together its detailed design team quite soon after its appointment and you go on to give

02:00:12 its appointment and you go on to give some dates and then you say key members of the design team at this point were Harley the specialist cladding designers which designed the details of the cladding jsw the M&E contractors and

02:00:24 cladding jsw the M&E contractors and curtains limited the structural engineers are you suggesting by that list which doesn't include studio II the studio II was not a key member of ride

02:00:35 studio II was not a key member of ride ins design team

02:00:52 more like that typically says riding confirmed it's subcontractor and designers we're employed as consultants

02:01:05 designers we're employed as consultants I mean just to be clear that the list that you're setting out at 34 one two

02:01:18 that you're setting out at 34 one two and three is your list yes yes and and I'm suggesting to you I mean possible

02:01:29 I'm suggesting to you I mean possible the easy thing to do is look it's and a paragraph ten in the diagrams in yes absolutely we can do that if we can get back to paragraph ten of your of your

02:01:41 back to paragraph ten of your of your statement which we will find on page four there is a diagram I think below on page eleven next page is that what you

02:01:54 page eleven next page is that what you want to share just a moment it may need to be explicit or it may need to be expanded so that everybody can can read it it's not a very easy document to read but if you go to I'm so sorry mr.

02:02:08 but if you go to I'm so sorry mr. Crawford this is not that easy to see but it's easy and portrait less so in landscape but if you look at the page is divided into two as key relationships prior to writers appointment and then

02:02:20 prior to writers appointment and then lower down key relationships after write-ins appointment yes and is that what you want to look at at the lower part yes and so that makes the distinction and the blue boxes from contractor to consult yes and just say

02:02:32 contractor to consult yes and just say that everybody looking at this document can follow it this is after writing this appointment we have two red boxes KCT mo as the top red box and and the and they

02:02:45 as the top red box and and the and they appoint right unless they're contractor bottom red box yes yeah and then looking to the right you got blue green and a blank box the blue boxes are

02:02:58 blank box the blue boxes are subcontractors one of which includes highly facades and that one of the green boxes is Studio E protect so after after Novation you were

02:03:09 protect so after after Novation you were subcontract you are a subcontractor or sub consultant of writen sub consulting sub consultant and going back to your list of design team members in your

02:03:24 list of design team members in your statement at paragraph 34 page 14 if we can having shown you that but can I just repeat my question the list that you've set out here doesn't include studio II

02:03:35 set out here doesn't include studio II and my question is why not given given that you're setting out key members of the design team well I suppose if you are to rewrite that you'd see writing

02:03:48 are to rewrite that you'd see writing confirmed its sub contracted designers as and then list the blue ones and then it's some consultants and list the green ones

02:04:02 what's the difference that you're drawing between subcontractor designers and sub consultants the subcontractors took complete responsibility for their

02:04:17 took complete responsibility for their package of work and the sub consultants were retained enough consultancy basis now that distinction that you're drawing

02:04:28 now that distinction that you're drawing is one I just want to understand where it where it comes from because we've seen that it doesn't come from the contractual documents so where does that distinction come from does it is it

02:04:39 distinction come from does it is it something you assumed at the time or is it something that you were told at the time and I say at the time I mean well July 2013 ah well if you take if you take this subcontractor designers

02:04:50 take this subcontractor designers they're designing and they're manufacturing and they're producing and installing the products the consultants aren't

02:05:02 and we'll come to that in due course but can we look at your statement at paragraph 15 to 17 which is on page 7 you just look at and this is under the

02:05:16 you just look at and this is under the executive summary at the top of the page mr. crawford but if you look at paragraph 15 16 and 17 and just read those to yourself

02:06:10 so to summarize you're saying here I think that studio Eve's role was to comment on whether the work carried out by others was was in line with

02:06:21 by others was was in line with architectural intent set out in the employer's requirements that's the final paragraph of paragraph a final sentence of paragraph 15 and that that is that is

02:06:34 of paragraph 15 and that that is that is a distinction that was drawn at the time by you was it well that was a role I

02:06:46 by you was it well that was a role I should say that you understood at the time that your role after Novation was limited to commenting on whether the work carried out by others was in line with architectural intent yes there's

02:06:57 with architectural intent yes there's several that I understood at the time right

02:07:09 can you explain can you explain that if you can't you can't why it's the distinction that you've been drawing on a number of the different documents we've seen is not one which ever found

02:07:22 we've seen is not one which ever found its way into the formal contractual documents such as the deed of appointment I've encountered in the 16 I that's my

02:07:33 I've encountered in the 16 I that's my experience and on projects that's how you comment right but can you explain why that distinction which which is quite an important one from Studio E's point of view it was never reflected in

02:07:44 point of view it was never reflected in the deed of appointment of February 2016 do you know why that was personally no I think that's a question for bris sorts of questions for mr. Sains can I just be clear are you saying that this was your

02:07:56 clear are you saying that this was your understanding of how things work based on your experience in the construction industry yes and I suspected the Bruce's as well but I can't comment as bad I

02:08:11 wonder whether we was about to suggest another break right I think I have another short break now that mr. Crawford again don't talk to anyone about your evidence please well your room will resume at 20 past yes

02:08:33 25:12

02:20:44 yes would you like to ask mr. Crawford to come back please

02:20:58 right mr. Corfu trip City to carry on yes

02:21:01 yes mr. Crawford I now want to ask you some questions about an architectural intent can I ask you please to go to your statement that paragraph 54 which is at

02:21:13 statement that paragraph 54 which is at page 23 on the document which is still up on the screen now this paragraph sits

02:21:26 up on the screen now this paragraph sits under a heading cladding studio ease input on the Harley drawings and then you go on to say from time to time Harley asked me to comment on a drawing or a set of drawings I discussed this in

02:21:38 or a set of drawings I discussed this in the context of specific drawings further below but in summary I would then usually send back some observations commenting on the architectural intent which you've put in quotation marks I would then record my comments on any

02:21:50 I would then record my comments on any particular drawing using a stamp describing the documents a status a B or C the status the meaning of the status a B or C is a convention which is widely used and commonly understood in the

02:22:01 used and commonly understood in the construction industry then you go on to say it essentially meant what was stated in the wording on the stamp a conforms to architectural intent B conforms to our architectural intent subject to

02:22:13 our architectural intent subject to incorporation of comments revise and resubmit for a status C does not conform with architectural intent revise and resubmit so you you put architectural

02:22:27 resubmit so you you put architectural intent in quotation marks is that because it's a special expression known in the architectural profession

02:22:42 I think it's not in the construction profession yeah I mean you say that the meaning of the status is a convention widely used and commonly understood in the construction industry but what does the expression architectural intent mean to

02:22:56 expression architectural intent mean to your understanding

02:23:03 it's this basically is the architecture as you designed it to appearance aesthetics spatial utility functional utility I see

02:23:19 spatial utility functional utility I see appearance aesthetics spatial utility and functional utility spatial and functional spatial and functional does that mean that you don't include in the expression architectural intent

02:23:31 expression architectural intent technical requirements yes ad civets yeah would you also say that within the

02:23:43 yeah would you also say that within the expression architectural intent you don't include selection of materials no I think the architectural intense what I

02:23:54 I think the architectural intense what I meant when I mentioned appearance could imply material it's bitter something implies color and finish but say so selection of materials so far

02:24:07 but say so selection of materials so far as the look and feel of a material is concerned yes yes does that mean that an architect would not normally consider

02:24:19 architect would not normally consider technical requirements and specification of materials

02:24:26 well the between the designing well as I say up to tender stage but if you're talking in this specific context with

02:24:37 talking in this specific context with ombre architectural tent about architectural tents commenting relative to specialist contractors interpretation

02:24:48 to specialist contractors interpretation of the employers requirements

02:24:56 I'm not quite sure I really I've got that answer clear in my own mind are you saying that after the tender stage but first of all do you say that after the

02:25:07 first of all do you say that after the tender stage whether or not there's a design a design and build contract or at the design and build contract stage the

02:25:18 the design and build contract stage the hot one sing and in the context in which this is written this is talking about commenting on a specialist contractors drawings I see so you used is this right

02:25:33 drawings I see so you used is this right that you are using the expression architectural intent and what that implies and doesn't include to describe the limits of studio EES obligations

02:25:45 the limits of studio EES obligations after innovation yes but you could talk you could talk about scheming you see with the architectural intent at any

02:25:57 with the architectural intent at any point and you could describe the architectural intent I've ever just described as we've just a great description but in the context what you're reading here yes I see let me

02:26:08 you're reading here yes I see let me just ask you something on your statement can I ask you please to be taken to be taken to page 60 paragraph 187

02:26:21 you say and take it from me that this is paragraph 187 although it starts on the previous page you see in the last sentence an ultimate sentence you say

02:26:34 sentence an ultimate sentence you say however if I noticed anything that was obviously not compliant with building regulations I would raise this with the specialist designer and/or Building Control as necessary mm-hmm so can we

02:26:46 Control as necessary mm-hmm so can we can I take it from that that that even though your understanding was that studio e's obligations related were were confined by architectural intent in the

02:26:57 confined by architectural intent in the way you've described it post Novation nonetheless if you saw anything in in a design done by a subcontractor that was obviously not compliant with the with the building regulations you had an

02:27:08 the building regulations you had an obligation to raise that or you would raise that with the specialist designer or building control what I would say is that um the comment in relation to architectural intent but if you see

02:27:19 architectural intent but if you see anything that's manifestly wrong I see then you have an obligation to yes point time and he will come to manifest error

02:27:31 time and he will come to manifest error in a moment because you cover that in your statement I don't want to show that to you but before I do do you accept that you were also responsible for identifying anything that a competent

02:27:42 identifying anything that a competent architect would be expected to identify if there was a divergence from building regulation requirement yes I suppose now

02:27:54 regulation requirement yes I suppose now can I ask you to look at paragraph 256 of your statement this is page 78 of the same document

02:28:04 paragraph 256 and that's under the heading reliance on third parties summary and I you might want to look at the whole paragraph just read that to

02:28:15 the whole paragraph just read that to yourself so that you've got the context in your mind before my question

02:28:47 yeah all right now what I want to focus on with you is the second sentence as set out in the section above in order to fulfill my role in coordinating the

02:28:59 fulfill my role in coordinating the Building Regulations approvals process for designs prepared by others and then you say I would identify any potential problems with those drawings that would be manifest to an architect say for

02:29:12 be manifest to an architect say for example if a handrail was located at the wrong height in contravention of Building Regulations guidance and then you go on and then rely on the expertise of those with either a more detailed knowledge of the design in question all

02:29:23 knowledge of the design in question all those with more specific expertise to coordinate the approvals process but just focusing on the expression that would be manifest to an architect do you accept what the wearer design may

02:29:35 do you accept what the wearer design may have included technical matters beyond the scope of an architect's ex own expertise then that wouldn't absolve that architect of their duty to check

02:29:46 that architect of their duty to check the designs produced by others at all

02:30:01 you well you check them in the in the capacity if we just described down yes

02:30:12 just to be cleared just because they design might include technical matters which were outside the scope of your own expertise you wouldn't just say well I don't need to check those at all you'd

02:30:23 don't need to check those at all you'd still check them if you asked to check them yes yeah well if they came to you if they crossed your desk yes and if they hadn't crossed your desk but you you needed the drawings in order

02:30:34 but you you needed the drawings in order to be able to coordinate the buildings of control process you'd ask for the man look at them is that right

02:30:48 possibly now let's just look at an example

02:30:52 example can I ask you to be shown please se a 0 0 0 0 3 2 4 2 8 1 and this is a a Harley

02:31:07 0 0 0 3 2 4 2 8 1 and this is a a Harley drawing dated and it's at the bottom on the right hand side it's quite small but take it from me it's the 30th of

02:31:19 take it from me it's the 30th of September 2014 so it's after you're after the start of your involvement and it's an elevation you see yeah and it's marked approved for

02:31:31 yeah and it's marked approved for construction and then above it there's a red stamp on the right hand side studio E architects and you could see the a B and the C and you've ringed it with a be

02:31:44 and the C and you've ringed it with a be yes yes and then you've signed it and it you've dated it 12th of June 2015 and you put your name Neil Crawford in the box yes yes and you can see that the

02:32:00 box yes yes and you can see that the stamp status a just above it says it's not very easy to see on this one but it says can conforms to design intent yes mm-hmm

02:32:08 mm-hmm and do you accept that design and although this one was marked B we're looking at a design intent would include the question of compliance with performance criteria of what is on the

02:32:19 performance criteria of what is on the drawing

02:32:34 not necessarily well can you help me with the terminology we talked about all you talked about architectural intent in your statement we had a discussion about

02:32:45 your statement we had a discussion about that a minute ago in the stamp you used design intent is there a difference I would say that the stance is the stamps are an industry standard

02:32:56 are an industry standard so these exist across all projects that method stamping is used for all projects or contract types project instead that's

02:33:12 or contract types project instead that's why I've qualified architectural intent

02:33:18 so just that I'm clear you've explained your understanding of the expression architectural intent but we see that you've used the stamp which says design intent is there a difference between the

02:33:30 intent is there a difference between the two expressions or or do we take it from you that you and you use the stamp with design intent you meant it architectural intent I don't think there is a

02:33:42 intent I don't think there is a fundamental difference between the two interpretations but to be precise in the architectural intent I see you said

02:33:54 architectural intent I see you said there's no fundamental difference is there any difference it's a different word different word for the same thing you think I see now I'm going to ask for

02:34:07 you think I see now I'm going to ask for the box to be blown up if I can please that the big red stamp if that could be yes thank you very much I can you see that clearly mr. Crawford yes it's not perfect I accept you can see

02:34:20 perfect I accept you can see three-quarters of the way down the box that there are three columns date checked by signature and name and then underneath that date authorized signature and then name you say this is

02:34:35 signature and then name you say this is an industry stamp is it there for industry practice that each drawing which is looked at and stamped will be looked at by two people the signatory

02:34:49 looked at by two people the signatory and then the checker or the the checker and then the authorized signatory not necessarily as I mentioned before the stamp is I feel I guess a generic stamp

02:35:02 stamp is I feel I guess a generic stamp yes so allows for use across potentially any project with an office

02:35:13 it might be more appropriate just to have written status be and not use the full stamp and what is normally in your experience the purpose of the authorized

02:35:25 experience the purpose of the authorized signature as opposed to the checked by signature

02:35:39 if you have to have a process where you are double-checking some some companies may have for larger projects for example Pacific times project and there's no

02:35:51 Pacific times project and there's no second signature on this drawing is that because there was no system within studio e whereby a second person would check the stamp that you had signed I'm

02:36:05 check the stamp that you had signed I'm not aware that we operating a double check it's a sign is that generally true across the whole Grenfell tower project yes and I think that's true across most

02:36:18 yes and I think that's true across most offices you've told us about your role being limited to checking whether the drawings conformed to architectural intent or design intent I'm going to

02:36:30 intent or design intent I'm going to assume we can use those two words interchangeably mr. Crawford and lessee Tommy

02:36:33 Tommy we shouldn't but we've discussed that my question is did you ever seek to agree with Rhydon will check with Rhydon that they were happy that your role should be

02:36:46 they were happy that your role should be limited to checking whether drawings conformed to architectural intent or design intent

02:37:02 I believe that what dude have expected us to be commenting on you say you believe that's what they would have expected you to be commenting on was

02:37:14 expected you to be commenting on was that what was that belief based on standard inter industry practice do we take it from that that you never actually had a conversation with ridin

02:37:26 actually had a conversation with ridin along the lines of we are only checking the drawings we get from Harley for example for design intent and nothing more

02:37:36 more well design intent and anything that we saw in it is manifestly fair enough I see did you ever have a discussion with Rhydon about what you understood by

02:37:50 Rhydon about what you understood by architectural intent or design intent I

02:37:56 think you'd be very unnatural conversation to have that trying templates I I didn't

02:38:08 are you this is a repetition and a sense of the same question we were looking at on the contracts before but are you able to explain why the contractual

02:38:21 to explain why the contractual documentation didn't say that studio E's role was limited to checking drawings for architectural intent or design intent

02:38:30 intent I can answer beyond what I said before

02:38:42 now you've used the expression manifest to an architect a paragraph two five six of your statement perhaps we should just just go back to that so that you're clear page 78 please se a triple zero

02:38:56 clear page 78 please se a triple zero one four two seven five page 78 paragraph two five six just looking at the expression it's in the middle of the paragraph that the drawings that would

02:39:07 paragraph that the drawings that would and the B is missing manifest to an architect just focusing on that do you agree that issues such as specification of materials which don't comply with the

02:39:20 of materials which don't comply with the building regulations should be manifest to an architect

02:39:32 [Music]

02:39:37 in general terms yes

02:39:43 and can I then in light of that take you to page 17 of the same witness statement paragraph 42 please page 17 paragraph 42 I'm sorry to jump

02:39:57 page 17 paragraph 42 I'm sorry to jump around and and if you need to look at there's more widely we can do that but you you say there in the first sentence however I did not consider that the

02:40:09 however I did not consider that the review of drawings of others during the project was to double-check that they were technically correct all necessarily compliant with the building regulations above and beyond their consistency with

02:40:20 above and beyond their consistency with the architectural intent now can you help me with this

02:40:32 can we could do this by way of an example I think if you go please will be shown se a zero zero zero zero three one six zero stop mister operator

02:40:44 six zero stop mister operator that's se a zero zero zero zero three one six zero and this is a a document of

02:40:56 one six zero and this is a a document of a number of pages which comprises the Harley specification notes revision B which started life on the 15th of

02:41:08 which started life on the 15th of January 2015 if you look at the very bottom right hand corner not the very bottom right hand corner but the bottom on the right hand side and if you look

02:41:19 on the right hand side and if you look at the box to the left of that it says specification and if you look at the box to the left of that it says 3rd of March 2015 revision or rvg firebreak and this is this is revision B of this

02:41:32 is this is revision B of this specification just just say that we're clear now on the specification notes if we could just focus on page 1 can we please blow up page 1 just to have that on the screen thank you

02:41:44 on the screen thank you the document contains some red handwriting is that yours yes and

02:41:53 yes and at page one that we've got two arrows there one is for key for color areas and the other points to the left to G value

02:42:08 the other points to the left to G value equals naught point five nine which is part of the section glazing G one vision and you say this seems quite high think

02:42:20 and you say this seems quite high think MF expected naught point for question mark is MF max fordham yes okay and the the G value of glazing is is that a

02:42:32 the G value of glazing is is that a matter of architectural intent or is that would you say dis detailed design input its architectural tenets as much as it affects the color what is a G

02:42:43 as it affects the color what is a G value chief I'll use the energy transfer through glass right the energy transfer through glass isn't so I have it different would you understand the

02:42:55 different would you understand the energy transfer measurement through glass to be an aesthetic or appearance or spatial matter which would forward and why is that the way energy transfer through glass is modulated is by applying I've actually

02:43:12 modulated is by applying I've actually metallic courts applied onto the glass so if you've got a double glazed unit you have imagine you put two pieces of glass and you have faces numbered one

02:43:23 glass and you have faces numbered one two three four in order to control the energy transfer through glass into by using low emissivity glass

02:43:36 glass into by using low emissivity glass which deals with energy loss I always get this confused which face the finish she's gone nothing at peace for but to

02:43:49 she's gone nothing at peace for but to control the g-value of glass you you this a metallic glare that goes onto the glass that effectively rebounds the

02:44:00 glass that effectively rebounds the energy or it makes the glass more thermally more energy efficient in terms of the transparency and it's generally the higher the higher the g-value the

02:44:14 the higher the higher the g-value the the more metallic surface is pure on it and so the darkroom goes so if you imagine sometimes you see buildings that look like gamma sunglasses ice on it then this is because well it might not

02:44:27 then this is because well it might not necessarily be because of the g-value but it could be for other reasons but generally the with eye chief are you then the glass gets dark I see so in a

02:44:40 then the glass gets dark I see so in a nutshell you have a sepia on to the g-value to be lower because it would look better hey it's be inline with the architectural intent alright can I ask you to look please at page 10

02:44:51 can I ask you to look please at page 10 of the same document which is a drawing and it's drawing see one zero five nine number 31 B and I just want you to look

02:45:04 number 31 B and I just want you to look it's on the top of the page you stamped this on the 6th of March 2015 mr. Crawford I think and this is a drawing from Harley revisionary 3rd of March

02:45:16 from Harley revisionary 3rd of March 2015

02:45:17 2015 fixing membrane construction and there's red handwriting again which I think we can recognize as yours yes we're in the middle of the page as an arrow and it

02:45:28 middle of the page as an arrow and it says is there risk of air leakage through here and then EPDM query at ends if I read your let your handwriting out correctly

02:45:45 yes okay is that a matter of architectural and Tindall would that be a detailed design input I think I might

02:46:02 a detailed design input I think I might be something that came under the heading of manifestly I see and what we'll look at one more in the same run of documents page thirteen please looking at drawing

02:46:18 page thirteen please looking at drawing see 105 nine three to six where you

02:46:29 see 105 nine three to six where you query the logic behind Hartley's positioning of breathable membranes behind the face of the insulation I'm so sorry that's the middle it's the middle drawing on page it's paid thirteen which is on the screen near the bottom above

02:46:41 is on the screen near the bottom above the tapcon sign breathable membrane breathable doesn't membrane go on outside face of insulation please clarify logic if I read your writing correctly there yes again is that a

02:46:55 correctly there yes again is that a matter of architectural intent or is that a disease of detailed design input

02:47:02 something it's manifestly wrong that's another manifest error is it potentially right because on the face of it these look quite detailed granular

02:47:13 it these look quite detailed granular technical interventions by you but you say there manifests to any architect looking at this drawing would say that's a manifest error it needs to be corrected is that right well I can't speak for any architect no

02:47:24 well I can't speak for any architect no or in your experience of the standards to it you have been used to operating yeah now can I ask you please to go to your witness statement I get to turn to

02:47:36 your witness statement I get to turn to a it's a similar topic but it is to tell you what it is it's it's a it's a conversation that you say you had with mr. Simon Lawrence of writing about

02:47:49 mr. Simon Lawrence of writing about design and responsibility if you could go to page 16 of your statement please paragraph 37 and would you read paragraph 37 to

02:48:01 and would you read paragraph 37 to yourself first of all please and then I'll ask you some questions about it

02:48:26 yes thank you now if we look at the fifth line down you say however Simon Lawrence right and said to me in an informal conversation around the start

02:48:38 informal conversation around the start of my involvement in the project that ride intended not to use its architects as much as it might do as such he envisage to do E's role as being more responsive with Rhydon

02:48:50 being more responsive with Rhydon maintaining a greater degree of control over the design process than I would normally expect from a design and build contractor in that regard I had less to do for riding than I expected now first

02:49:04 do for riding than I expected now first can you remember even roughly when that conversation took place yes the project

02:49:16 on site with the Simon and the bish you'd call five what you said a little bit more a very strong recollection of

02:49:27 bit more a very strong recollection of it because it did surprise me he said we tended not to use our tests a lot as much we tend to not to to architect so much through this stage in

02:49:38 architect so much through this stage in this stage of the project I've watched for that fact you say that you were on site with Simon Lawrence that's the Grenville tower site yeah what was the that was that a site

02:49:49 what was the that was that a site decision and no it was near the start and yeah might be it could be the Cypress or it's the early design team

02:50:01 Cypress or it's the early design team meetings right you say near the start of the early on with early on of my involvement sorry right so given that you started in in or after July 2014 yeah and place it to the summer of is

02:50:13 yeah and place it to the summer of is this right the summer of 2004 yeah it had been the August or something okay all right was anybody else present when he said that to you no although I do

02:50:24 he said that to you no although I do know and I think British made the same comment and is equally surprised that similar comment was made to have a separate time right given the surprise that you say

02:50:36 right given the surprise that you say and indeed is reflected in your statement to some extent did you report the gist of that conversation back to Bruce I think I think it probably does did you report it back to Andre kachelle

02:50:49 did you report it back to Andre kachelle I didn't say that did you think to make a written record of it no I'm one thing

02:51:00 a written record of it no I'm one thing I would say it with contractors on projects is different contractors have different have different so company

02:51:16 different have different so company ethos in terms of how they work how much they use or don't use architects at certain stages of the project basically when you go into our project it can be

02:51:28 when you go into our project it can be very much down to the team of people that are working on that project I mean it's not new but one thing that's commonly known as the construction managers project managers or you can

02:51:40 managers project managers or you can track system move a lot between organizations and so my spinach has always been let's you try and understand the team that's there as well as the

02:51:51 the team that's there as well as the ethos of the contractor because they're two together give you a sense of was it not important to record what Simon

02:52:06 not important to record what Simon Lawrence was saying to you because it affected the scope of your rollers as architects on the project going forward in a way that you weren't expecting yeah and I mean I think I had the

02:52:17 yeah and I mean I think I had the conversation very simply because it did it struck me is slightly unusual yeah

02:52:28 it struck me is slightly unusual yeah which is why I'm suggesting to you or asking you why if it was slightly unusual as you say you didn't think to send him an email to confirm the conversation or record it in a note or something and well I can this as opposed

02:52:40 something and well I can this as opposed give that background of working with different people and different companies you know it started working with Ryan and what with Ryan before you know I could contrast them against working with before as a company

02:52:55 against working with before as a company first and then as a set of individuals on a project and one thing you learn is they did the project project they can vary quite this can vary quite dramatically but it sorry to answer your

02:53:09 dramatically but it sorry to answer your question did I think of writing that down in some form no I think I had the conversation with bris by personally didn't think - noted or noted back but

02:53:21 didn't think - noted or noted back but only because you do get this variance working with different contractors right

02:53:31 you say in your statement that

02:53:45 was that ridin would maintain a greater degree of control over the design process do you see you say that three lines are from the bottom was there any discussion of what mr. Lawrence actually

02:53:57 discussion of what mr. Lawrence actually meant by greater degree of control over the design process

02:54:12 no but I would see God he didn't stay but the way he behaved he he did I mean he's someone who described his

02:54:23 I mean he's someone who described his very being very hands-on so he'd he would do things that another contractor might automatically seek to push out to consultants or subcontractors you take

02:54:35 consultants or subcontractors you take on board himself and do it and I think he just did it because he saw it's expedient to getting things done I mean notes I suppose one of the reasons I didn't have any concern is

02:54:47 reasons I didn't have any concern is because I did from the interaction I had with them oh I saw use probably more competent than your average person in

02:54:58 competent than your average person in that role I just want to follow up on on this answer because you're saying here I think that he would do things another contractor might not but might automatically seek to push out but

02:55:09 automatically seek to push out but you're describing his conduct on the project I'm asking you about the conversation in the conversation when you had it did he explain what he meant by write and maintaining a greater degree of control over the design

02:55:20 degree of control over the design process well he didn't he didn't say that I mean what he said was that he'd be tended not to use architects so much

02:55:31 be tended not to use architects so much Jim

02:55:32 Jim Ryden tell you not to use after so much of this stage of the works his point said right did that come as a disappointment to you

02:55:45 I remember at that time not being entirely sure why he said it it was at a time when I was hounding one bit to get building control on board I'd sent several emails saying we and I don't know whether was just somebody who liked

02:55:57 know whether was just somebody who liked to have more control sometimes project management jobs prefer to have more control and there might be good reasons for that given that you remember not being entirely sure why he said it can I

02:56:09 being entirely sure why he said it can I ask you why you didn't ask him what he meant by having greater degree of control over the design process I'm seeing as he didn't see greater

02:56:22 seeing as he didn't see greater country-based a degree of control over the design process he said the bride intended not to use architects much in this stage of the bottom right so when

02:56:34 this stage of the bottom right so when you say in your statement that he envisaged studio his role as being more responsive with Rhydon maintaining a greater degree of control over the design process that's your understanding of what he meant when he said they don't

02:56:45 of what he meant when he said they don't use architects so much is that that's my understanding of I support you meant and what I did right how do you worked with Rhydon before to the summer of 2014

02:56:57 Rhydon before to the summer of 2014 no so that was your first experience all yes and when you had this conversation was that early on in your professional relationship with mr. Lawrence yes I

02:57:08 relationship with mr. Lawrence yes I think I said that earlier yes probably right

02:57:28 did you think at the time that it was appropriate that Ryden should seek to will say that it was going to seek to limit studio he's role in this way I

02:57:44 think it's a city down there I found unusual which is why I remember it so clearly yes and because you thought it was unusual my question is did you think it appropriate for you to say to him look Simon that's a bit strange why are

02:57:57 look Simon that's a bit strange why are you seeking to limit our role in that way not necessarily for the reasons I gave earlier which is that when you start project

02:58:08 start project well this meet I'm personally experiencing you start project and you meet the the main contract so the first thing you try and do is assess the Kennedy Thorsen working method of the

02:58:19 Kennedy Thorsen working method of the company and then of the individuals so in this case you know I was getting an insight into ridin and him as an individual how he choose to work and the

02:58:30 individual how he choose to work and the fact that that might be different from an Arkham and our set of contractors they could be good reason for that I mean my experience different scale of contractors you do get a very different experience so for example coming out at

02:58:43 experience so for example coming out at the back of a couch you're working with a large international I'm contracted horizon I suppose a very different way of operating yes and at least that that

02:58:55 of operating yes and at least that that that's interesting I did in your experience at that time and you ever come across a successful tenderer design and build contractor who had turned to

02:59:06 and build contractor who had turned to you and said we don't tend to use architects that much it'd be not said it but I had actually done that I mean one thing you find is with with smaller or

02:59:17 thing you find is with with smaller or domestic or different size contractors is you do you can get quite a varied experience in terms of expectation or you have you expect you to respond or to

02:59:28 you have you expect you to respond or to what degree they lean on you for information or to verify what they're doing and again this comes back to part my rule paradox it part the rule I

02:59:39 part my rule paradox it part the rule I see the you have to do is an individual where the honours understand the ethos and expectation of the project team and contractors you're working with because they can be quite

02:59:50 working with because they can be quite different yes mr. chairman I've got one or two more questions on this line before we move to a different door slightly different make me me if it's convenient with you and the witness yes

03:00:03 convenient with you and the witness yes five minutes tops yeah yes thank you can you explain mr. Crawford why it was given this conversation that you had with mr.

03:00:16 conversation that you had with mr. Lawrence at that time can you explain why the effect of that the limitation on your on your role wasn't recorded in the formal deed of appointment when it came

03:00:27 formal deed of appointment when it came to be executed in February 2016 I think that's a question for Bruce again can I

03:00:39 that's a question for Bruce again can I ask you to look at paragraph 38 of your statement page 16 and again if you want to read the whole paragraph please do I just want to focus on something you say

03:00:50 just want to focus on something you say in the second from last sentence

03:00:56 perhaps given what we've just been talking about you should read the whole thing

03:01:10 yeah and just focus with me if you will on the second from last sentence where you say Ryden did not involve studio a in all the site meetings which took place or design decisions and we were

03:01:22 place or design decisions and we were not copied into all emails that is obviously a description is that a description of the entirety of your involvement in the project in other words a general experience that you had

03:01:36 words a general experience that you had yes I see and did you ever object with writing to that approach did you ever say to them well you should be involving us in all site meetings and design

03:01:47 us in all site meetings and design decisions well we were employed by right and their discretion to use home when they felt fit right in the capacity we

03:02:09 they felt fit right in the capacity we service their requirements as they requested now mr. Crawford this may not be a question you can answer say but if you can't please say but can you explain how it came about that

03:02:20 you explain how it came about that studio he was able to warrant to the TMO under its collateral warranty give the warranties that it did in respect of past performance under the collateral warranty in circumstances where studio

03:02:33 warranty in circumstances where studio he had not been present at every site meeting but right and was that well I don't think is for me to answer that question but what we'd say is that the

03:02:46 question but what we'd say is that the notion that because you're not at every site meeting this is quite not a means quite normal in any project you think you in is not to be and every time meeting people I mean there's this

03:03:00 meeting people I mean there's this depending the skill of project there's a raft of specialists in the raft of construct consultants and you'd never in any project be all meetings or you never

03:03:12 any project be all meetings or you never on any projects be involved nestled in all decisions or be copied into all email so that's not that's not mutually exclusive to this project and are you

03:03:25 exclusive to this project and are you able to explain how it came about that studio II was able to warrant to the TMO under the collateral warranty will give the collateral warranty and respect of all the subtle design decisions in

03:03:37 all the subtle design decisions in circumstances where studio he had not been involved in all design decisions I can't comment on that I see thank you very much mr. Crawford mr. chairman is that a convenient little bit void right

03:03:48 that a convenient little bit void right yes thank you very much well we'll have a break now mr. Crawford so we can all get some lunch and we'll resume at five past two please okay and as I said to earlier please don't talk to anyone

03:03:59 earlier please don't talk to anyone about your evidence or anything related to it okay thank you very much you like to give the Asha

03:04:13 five fast to please