Grenfell Tower Inquiry - Studio E Evidence - Wednesday 11 March 2020 (1/2)
00:01:28 good morning everyone welcome to today's hearing at which we're going to hear some more evidence from one of the architects at studio he who was involved
00:01:39 architects at studio he who was involved in the refurbishment of the turf before we do that can I just mention a topic which is on everyone's lips almost and certainly in most people's minds namely
00:01:50 certainly in most people's minds namely the corona virus because one or two people have asked us what we're doing about it well it's not a lot we can do about it in one sense of course but it's
00:02:02 about it in one sense of course but it's something we are monitoring very carefully I think we all need to understand that we have a personal responsibility to try to avoid spreading infection and therefore I will repeat
00:02:13 infection and therefore I will repeat what I said on Monday morning but if anyone has concerns about their own health then please don't come into the inquiry you can watch it remotely and
00:02:24 inquiry you can watch it remotely and take a reasonable part by doing that we are keeping abreast very carefully of the latest advice from the government and the National Health Service hand
00:02:35 and the National Health Service hand sanitizers are available in the public areas we will continue to keep the position under review and we will advise you if and when the time comes it when
00:02:46 you if and when the time comes it when it's necessary to take any further steps but for a moment please just accept that we are watching the situation very carefully and we rely on all of you for your support in the way that I've
00:02:58 your support in the way that I've indicated well having said that we're now going to hear from the next witness mr. Thomas rector the Chairman so could you ask mr. rector come in please
00:03:29 I do solemnly sincerely and trading I do solemnly sincerely and truly declare and affirm declare and affirm that the evidence I shall give that the evidence
00:03:41 evidence I shall give that the evidence I shall give shall be the truth shall be the truth the whole truth and nothing but the truth thank you very much with Tareq sit down make yourself comfortable thank you yes mr. chairman mr. Rhett
00:03:56 thank you yes mr. chairman mr. Rhett good morning can I start please by asking you to give the enquiry your full name when I mr. Thomas wreck thank you very much for coming to the inquiry and helping us with our investigations we appreciate it
00:04:07 with our investigations we appreciate it I'm going to be asking you some questions today if you have any difficulty understanding the questions that I'm asking you or you would like the question put in a different way please just say can I just also ask you
00:04:19 please just say can I just also ask you please to keep your voice up so that the transcribers who are sitting to your right can hear you and get down accurately your answers sure now you've made a witness statement for the inquiry
00:04:30 made a witness statement for the inquiry and it should be in a folder on the desk in front of you there and it will also appear on the screen in front of you and you will also see documents that that I refer to come up on the screen in front
00:04:41 refer to come up on the screen in front of you and we're looking at those together and if you look at the statement please it's se a zero zero zero one four to seven eight and like I asked you to
00:04:55 seven eight and like I asked you to start by going to page 35 please yes and you'll see that it's dated the 9th of November 2018 above which is your name
00:05:06 November 2018 above which is your name Thomas wreck and a signature above that is that your signature yes it is thank you now you've also provided exhibit tr1 can we please bring that up it's se a zero zero zero one four two seven seven
00:05:18 zero zero zero one four two seven seven and that's the front page of it and there are documents which follow that and it's some nine pages long and just scrolling down that please can you
00:05:29 scrolling down that please can you confirm that that is your exhibit to your witness statement yes thank you and have you read this witness statement recently yes can you
00:05:40 witness statement recently yes can you confirm that its contents are true yes and have you discussed the evidence that you're going to give today with anybody before coming here this morning I would be in contact with the Loras IPC and
00:05:55 be in contact with the Loras IPC and yeah who's occasionally email right have you discussed the evidence that you're going to give the answers that you're going to feel may may give to my questions no right now you worked on the
00:06:08 questions no right now you worked on the grenfell tower project from September 2013 to December 2013 so about four months is that right yeah right but I'm
00:06:22 months is that right yeah right but I'm only going to ask you questions about your direct involvement during those months and what you came to know about and do on the project during that time can I start then by asking you some
00:06:34 can I start then by asking you some questions about your qualifications of your experience you were employed I think by Studio E LLP between December 2011 and December 2013 is that right
00:06:47 2011 and December 2013 is that right that's correct and in December 2013 you were made redundant I think that's correct do you know how many people were made redundant at that time a handful you
00:07:03 know work I think as an architect in Copenhagen yes and when you were working for studio LLP were you a registered architect yes you were were you a member
00:07:14 architect yes you were were you a member of our IBA not now in paragraph 7 of your witness statement if we can just have that up on the screen please
00:07:26 you'll find out at page 3 you can you see that you say there that you obtained a degree in architecture from the University of Technology in Bern a v' in the Czech Republic in 2005 and then you
00:07:39 the Czech Republic in 2005 and then you qualified as an engineer architect in architecture and urban planning and that you say I have practiced as an architect for eight years is that is that eight years as at the date of the statement or
00:07:52 years as at the date of the statement or eight years as at the date of the fire or eight years at the date of your involvement in the grant or tower project
00:08:09 must have been at the date of my involvement 2013 right okay looking at the training you had at the University
00:08:22 the training you had at the University of Technology in the Czech Republic did you did you learn did your course cover technical aspects of fire safety in and around buildings do you recall whether
00:08:43 around buildings do you recall whether it covered fire spread internal or external fire spread don't think so say would you follow that you didn't learn anything as part of your formal
00:08:54 learn anything as part of your formal training from facade materials which would be used in an overt adding system no and can I ask perhaps what might
00:09:06 no and can I ask perhaps what might sound a silly question in the light of that that presumably you didn't cover the requirements of the building regulations in England and Wales and the word engineer architect is something you or a phrase you use in
00:09:18 something you or a phrase you use in paragraph seven of your statement is that a specialism within architecture that's how all architects are called in Czech Republic when they finish
00:09:30 Czech Republic when they finish education as an architect it's just a common term I see okay now you say in your witness statement a paragraph age which would also see on page three that
00:09:43 which would also see on page three that you practiced as an architect for eight years we've been through the air years prior to working for studio II where did you work
00:09:55 would have been three different practices in London well one of them was in Enfield I see and in what capacity
00:10:08 in Enfield I see and in what capacity did you work in each of those three practices
00:10:11 practices do you remember well I would start as a architecture assistant right because I didn't do my part three until 2010 right
00:10:24 didn't do my part three until 2010 right so I wouldn't become it was just the architect 2010 which is a year before I started that studio you I see so you're
00:10:38 started that studio you I see so you're an architectural assistant throughout the period you work for those those those three practices I would have been an architect in the in the last practice
00:10:49 an architect in the in the last practice I see because I would have had qualification so after 2010 yes yes I see in any of those practices did you
00:11:00 see in any of those practices did you have any or did you gain any experience on refurbishing an existing high-rise residential tower block no which sectors did you generally work in in those three practices mainly educational and now you
00:11:19 practices mainly educational and now you told us that you completed the RI be a part three in 2010 that was in London was it correct yes and it would I be right in thinking that in doing that you covered the requirements of the building
00:11:31 covered the requirements of the building regulations
00:11:36 yes yes and as an architect and an employee of studio II were you required to undertake continuing professional
00:11:47 to undertake continuing professional development or CPD it was voluntarily and I did did did you keep any records of your CPD I would just keep
00:12:00 of your CPD I would just keep certificates which we would receive after the seminars in a folder like a pro copy I see did you keep those records yourself or did she do you keep
00:12:18 conrick or I might have taken them with me when I finished my employment that's theory but don't have to make more do you specifically recall keeping your CPD records during the years 2012 and 2013
00:12:32 records during the years 2012 and 2013 I don't specifically recall but I think that's what I did because I thought I might use them in the future as a
00:12:45 might use them in the future as a reference if I wanted to be registered there are behaviors right I see now I'm going to turn to your role at Studio E and the briefing that you received on the Grenfell tower project you worked as
00:12:59 the Grenfell tower project you worked as a project architect during your time at Studio a didn't you correct yes and you reported at all times to mr. sones is that right no I was in I was sitting in the other
00:13:12 no I was in I was sitting in the other side of the office so I was reporting to another associate and another partner when I was working on that bolingbroke Academy I see what was your formal job
00:13:26 Academy I see what was your formal job title job status as at 2013 at Studio II I was a project architect project on the on the Academy right when you came into
00:13:39 on the Academy right when you came into the Grenville tower project and would I be right in thinking that you were reporting to mr. Sainz yes so he was can we take you that he was supervising your work on the project yes yes now at this time September 2013
00:13:55 yes yes now at this time September 2013 which is what I think you came into the grant our project am i right in thinking that the project had been developed to our IBA stage D design development yes yes can we turn up the stage can we turn
00:14:10 yes can we turn up the stage can we turn up your report I'm sorry your statement se a 0 0 0 1 4 2 7 8 at page 5 so two pages on 2 women from where we are and
00:14:22 pages on 2 women from where we are and I'd like you please to look at paragraph 14 you say there I was tasked by Bruce with developing the NBS specification and drawings further so that the NBS
00:14:35 and drawings further so that the NBS specification architectural drawings intended documents could be completed and issued as part of the pack of documents for tenderers see that hmm and then you say usually the successful tenderer or specialist subcontractor for
00:14:47 tenderer or specialist subcontractor for the successful tenderer would use these documents as a starting point for their further detailed design development so just to be clear your role at the start
00:14:58 just to be clear your role at the start of your involvement on the ground felt our project was to develop the NBS specification and drawings as you say yes is clear about that yes can I ask you how complete was the NBS
00:15:10 you how complete was the NBS specification at the time when you first started developing it something I had done recall and unfortunately wasn't
00:15:21 done recall and unfortunately wasn't able to retrieve any evidence of the draft statement of the specification when I took it over I I see when you say the draft statement you mean that the
00:15:32 the draft statement you mean that the NBS the NBS fair I see
00:15:38 just doing the best you can to recall it maybe maybe you can't do you remember whether mr. sands or anybody else at studio he had already done some initial work on the NBS specification it was
00:15:50 work on the NBS specification it was completely blank it wasn't completely and again I'm sorry to ask you but doing the best you can do you remember which parts of the NBS specification had already been completed before you started working on it
00:16:05 you know I can't record it okay all right now and can I ask you to go back to that backup page in your statement paragraph ten and you say there if you
00:16:23 paragraph ten and you say there if you look at three lines up from the bottom you say my involvement in the project was for me to my understanding filling the gap until another project came up I
00:16:34 the gap until another project came up I reported to Bruce Ames at se LLP Bruce was my supervisor at se LLP just looking at your evidence there about the gap did
00:16:45 at your evidence there about the gap did you believe that the purpose of your involvement it was to keep you occupied until another project came up yes what caused you to think that a brief chat
00:16:58 caused you to think that a brief chat with Andre and Bruce at the time of the redundancies yes okay and at the time of
00:17:10 redundancies yes okay and at the time of the redundancies that you were made redundant in in December but we know you started working in September 2013 so what does that mean that they were
00:17:21 what does that mean that they were redundancies in September or perhaps earlier in 2013 I don't recall exactly by it's a long process which silver a
00:17:33 by it's a long process which silver a couple of months right just to be a little bit more focused a brief chat with Andre and Bruce which calls you to think that you are getting involved in the Grenfell tower project to keep you
00:17:44 the Grenfell tower project to keep you occupied until another project came up that chat did it occur prior to you working on the NBS spec in September or was it another time
00:18:05 right was the gap that you're talking about a a staffing gap that you were filling or a work gap in other words you didn't have enough work to do so you
00:18:16 didn't have enough work to do so you were given this
00:18:22 well I was finished with my engagement at the academy I don't think there was another assignment other than rental for me right I see
00:18:39 when you started working on the Grenville tower project did you know that you would only be involved in it for three or four months
00:18:50 no I didn't right now if you look at paragraph 12 of your statement please which is at page 4 just a few paragraphs well two paragraphs
00:19:02 a few paragraphs well two paragraphs below 10 which we're looking at you say there I was first briefed on the project on the 18th of September 2013 by Gary Stewart as Bruce stones had been called in to meetings that day and I started by
00:19:13 in to meetings that day and I started by reading the stage D documents and reviewing the draft drawings and sketches
00:19:18 sketches do you remember what mr. Stewart told you to do
00:19:26 exactly what's written below reading the HD report and looking at the drawings available to me at a time right did he
00:19:38 available to me at a time right did he direct you to any particular documents do you remember no just those HD report right now I think it's also right that mr. Sains also relayed further information to the project about the
00:19:50 information to the project about the project to you on an as and when required basis yes yes do you remember in briefing you about the aesthetics of the facade yes do you remember when that
00:20:02 the facade yes do you remember when that was it would have been at the outset at the outset yeah do you remember whether at the outset there was any discussion about fire safety do not required was
00:20:17 about fire safety do not required was there any discussion after the outset about fire safety
00:20:24 [Applause] given during the duration of those all three months yes
00:20:44 I believe we would have been discussing the cavity barriers will come to look at those later can I turn to a different
00:20:55 those later can I turn to a different topic which is your personal and professional knowledge of the building regulations and approved document b now at the time of the project how familiar were you say last quarter of 2013 how
00:21:10 were you say last quarter of 2013 how familiar were you with the requirements of schedule 1 parts B 3 and B 4 of the building regulations I think I'm a
00:21:26 building regulations I think I'm a certain extend that would have been aware of those parts but probably I don't know would have read them back to
00:21:38 don't know would have read them back to back right same question how familiar were you in respect of the provisions of approved document b concerning schedule 1 Part B for subpart 1 of the building
00:21:51 1 Part B for subpart 1 of the building regulations external fast bread
00:21:59 I know I came across that subject in a previous project so I was aware of it
00:22:10 can you tell us what that project was it was a secondary school in East London right so not a high-rise building no and
00:22:26 right so not a high-rise building no and what did you learn about approved document b schedule 1 Part B for on that project I think that project
00:22:45 the building was quite close to an existing terrace houses and we were looking at the relevant boundary and the proximity and I would have one power
00:22:58 proximity and I would have one power facade needed to be class zero I think I see house class naught class area did you have what let me ask you first of
00:23:12 you have what let me ask you first of all that you've just mentioned facade was there a facade on that building I
00:23:18 think it was a that part was a rendered or break I remember there was a rendered and brick building did your involvement
00:23:31 and brick building did your involvement on that project involve input into external wall construction yeah was there any consideration of
00:23:45 was there any consideration of insulation or insulation products in that external wall construction that's something do you remember you say must have been why must there have been
00:23:59 we know that there was a thermal insulation and would have been specified so right you say it was a rendered and
00:24:12 so right you say it was a rendered and brick building so does that mean there were no there were no panels forming the exterior surface no yeah it wasn't a rain screen not a rain screen oh right okay and what did you learn from that
00:24:26 okay and what did you learn from that fraud project about the combust ability requirements contained with AD within a DV section 12 in relation to external
00:24:39 DV section 12 in relation to external walls
00:24:41 walls I think but then we satisfied ourselves with just confirming that the elements the surface of the facade I think was that the render was class 0 and
00:24:53 that the render was class 0 and therefore compliant what did class 0 mean to you like Santos / flame what did it what it bought his class in Syria what was class Syria was
00:25:08 class in Syria what was class Syria was that the surface of the material ID to the facade would didn't encourage spread of flame or it wouldn't burn right on
00:25:24 of flame or it wouldn't burn right on the surface how did you go about satisfying yourself on that project that the surface of the building on that project was class zero
00:25:40 I think we would look up the data sheets of the material be really certificate right okay were you familiar then or did
00:25:59 right okay were you familiar then or did you become familiar as a result of that project with BBA certificates and how to how to read them how to interpret them
00:26:12 I knew they existed and they were certificates explaining the behavior of materials on definite specs justifier
00:26:28 materials on definite specs justifier humor do you remember reading the BBS the relevant BB a certificate for that project do you remember there being discussion within studio II of the need
00:26:39 discussion within studio II of the need to look at that certificate when assessing whether or not the exterior complied with the requirements or guidance in approved document b can we
00:26:56 can i look can I just ask you this were you at the time of your involvement on the grenfell project familiar with the guidance contained in and the CWC T
00:27:07 guidance contained in and the CWC T standard the Center for Windows and tiny technologies standard I don't a guidance existed but I didn't read it
00:27:18 existed but I didn't read it right okay well cut we'll come back to that what about the BCA guidance that was issued from time to time by the BCA the Building Control Alliance
00:27:30 what about other industry standards which issued guidance from time to time about compliance with requirements of schedule 1 Part B 4 of the building
00:27:41 schedule 1 Part B 4 of the building regulations ok can we look at your statement of paragraph 140 please which we'll find on page 34
00:27:58 it's the very end of your statement hmm and you say there after I left se LLP I was involved in the design of a high-rise building where Celotex F R 5000 was also specified on that project
00:28:13 5000 was also specified on that project X / had produced a desktop study comparing the rain screen facade cladding the Celotex is tested sample and they had concluded that it complied with BR 135 you see that yes um at the
00:28:30 with BR 135 you see that yes um at the time of your involvement on the Grenville tower project September to December 2013 were you familiar with the various different available routes to
00:28:41 various different available routes to compliance with ADB 12.5 in relation to external wall construction
00:28:53 no not specifically so looking at paragraph 140 let's just look at that in a bit more detail then you say you were
00:29:04 a bit more detail then you say you were involved in the design of a high-rise building where was that building was it Bromley Bromley what was the name of the project was called Bromley South Central
00:29:17 project was called Bromley South Central there was a mixed-use residential newly built development which organization were you working for when you were involved in the design of that building guy Holloway architects and were you
00:29:32 guy Holloway architects and were you involved in that aspect of the high-rise building which specified products for use in the external wall yes was it's a
00:29:43 use in the external wall yes was it's a Claddagh it was a cladding was it yes was it a tightening of an existing building or a new building new build was a new bill
00:29:54 can you remember the dates of when fr 5,000 was specified in that project
00:30:07 no I wouldn't remember two dates can you remember the date when X overall roughly the date when x over produced a desktop study that you refer to
00:30:23 I kind of wing that guess but no I don't want you to I don't want you to guess if I remember you can remember can you give us some parameters there at least when did you first start working on that
00:30:35 did you first start working on that project I think it would be right at the outset when I got employed which would be straight after I left ciliary like and when when did you involve and come
00:30:46 and when when did you involve and come to an end in that later project that would be May oh yeah May 2017 from May 2017 okay when X overdid the exercise of
00:31:05 2017 okay when X overdid the exercise of producing a dense desktop comparing the rain screen facade on that project with Sara Texas tested sample was that a was that a new approach to you it was it was
00:31:16 that a new approach to you it was it was so that was can I take it that that wasn't an approach that you were familiar with at the time of your involvement on the Grenfell tower I see when you started work on the ground felt
00:31:27 when you started work on the ground felt our project where you told anything either by mr. Sains or or mr. Stewart or or anybody else about what route to compliance with the building regulations with with approved document b Studio II
00:31:39 with with approved document b Studio II had taken in respect of the refurbishment of the facade
00:31:45 I don't recall in discussion bother okay did you yourself give any consideration to studio ease routes to compliance with ADB in that respect I don't think I did
00:32:01 were you familiar with three of the requirement for a guidance I should call it perhaps in a DB or rather in schedule
00:32:14 it perhaps in a DB or rather in schedule Part B for total one part before that the external walls of the building should adequately resist the spread of fire over the walls
00:32:33 I mean my regulation is failing me a little bit I know I was aware like it's a Grenville but in a at a time of my
00:32:44 a Grenville but in a at a time of my involvement on grandfa project simply don't know but let me see if I can help you a bit of your regulation by showing you the relevant provision it's CLG zero
00:32:57 you the relevant provision it's CLG zero zero zero zero 173
00:33:12 and this is the this is approved document b which came into effect in april 2007 which is what you would have looked at at the time if you if you had can I take you to page 94 and page 94
00:33:29 can I take you to page 94 and page 94 you see guidance at the top and halfway down the page introduction and you can see external walls you see that yes
00:33:48 if you gave back a page I think in fact I've taken to the wrong page if you go back a page you'll see external fire spread before you see it there mm-hmm the external walls of the building shall
00:34:00 the external walls of the building shall adequately resist spread a fire over the walls and from one building to another having regard to the height use and position of the building so that was the regulation at the time and my question is did me and were you familiar with
00:34:11 is did me and were you familiar with that at the time of your work on the green field project I mean I assume since I came across as I explained a
00:34:24 since I came across as I explained a similar aspect on a previous project and in previous employment I must have been aware of to a certain extent of external
00:34:36 aware of to a certain extent of external fires by night so can we take it the you are aware of the principle it's not the precise language in the regulation yeah yeah and did you read did you realize
00:34:47 yeah and did you read did you realize that that would require you to consider for studio II to consider the far performance of each of the components of the cladding system including the particular type of cladding panels and
00:34:59 particular type of cladding panels and the insulation specified for the system
00:35:05 I see and if you turn on please two pages in the same document to page 95
00:35:16 pages in the same document to page 95 you can see paragraph 12.5 external wall construction you see that and just read that to yourself if you would the external envelope of a building you see that yes should not provide a medium for
00:35:29 that yes should not provide a medium for fire spread if it is likely to be a risk to health and safety and then you see in the second paragraph underneath that external wall should either meet the guidance given in paragraphs twelve six
00:35:40 guidance given in paragraphs twelve six to twelve nine or meet the performance criteria given in the BR eak report which is bre 135 for cladding systems using full scale test data from BSA for one floor
00:35:52 one floor either the 2002 or 2005 versions were you familiar with those precise alternative routes to compliance contained within paragraph 12.5 itself
00:36:05 contained within paragraph 12.5 itself not at a time of my involvement at cranville right just taking this very quickly then if I can can I just ask you to look at 12.6 at the foot of page 95 external surfaces the external surfaces
00:36:18 external surfaces the external surfaces of walls should meet and then flip the page the provisions in diagram 40 where a mixed-use building includes assembly and recreation purpose groups accommodation the external surfaces of
00:36:30 accommodation the external surfaces of wall should meet the provisions of diagram 40 see were you familiar with that provision or the principle contained in it at the time of your involvement again I think that refers to
00:36:41 involvement again I think that refers to that diagram with six different types of scenarios and it does I remember that one from the previous employment and the
00:36:52 one from the previous employment and the previous project yes I see and looking at 12.6 and the reference to diagram 40 which we can look at if we need to but were you familiar with the fact that it required in that national class naught
00:37:04 required in that national class naught or European class B as the surface component on buildings over 18 meters yeah yes and just looking on a paragraph
00:37:16 yeah yes and just looking on a paragraph 12.7 insulation materials that product and products war product in a building with a story 18 meters or more above ground level any insulation product filler material not including gaskets
00:37:28 filler material not including gaskets sealants and similar etc used in the external wall construction should be of limited combust ability see Appendix A this restriction does not apply to masonry cavity wall construction which would comprise a diagram 34 in section 9
00:37:41 would comprise a diagram 34 in section 9 were you familiar with that principle not at a time my involvement at grandfather came later do you do well
00:37:52 grandfather came later do you do well did you understand at the time that in the case of a cladding system which incorporated material in super insulation which was not of limited combust ability which complied with
00:38:03 combust ability which complied with paragraph 12 point 7 and appendix a the only route compliance of such a system with the building regulations was by demonstrating that it had passed an
00:38:14 demonstrating that it had passed an eight four one four test and met the BR one three five criteria or alternatively had a desktop system such as you came across later no no and and what about a
00:38:26 across later no no and and what about a bespoke fire engineered solution is a root compliance were you aware that that was a possibility again that I learned much later I see
00:38:37 [Applause] as far as you were aware at the time did you aware that the over planning system proposed for grenfell during your time
00:38:49 proposed for grenfell during your time on the project was not tested itself to BSA for one-four in order to meet the BR eak 135 criteria I didn't know it was always like a and similarly no holistic
00:39:03 always like a and similarly no holistic fire engineer report for it no you're shaking your head no no I'm viscosity said no but if you don't know yeah those on the transcript as your evidence thank you can I now
00:39:19 as your evidence thank you can I now turn to the V NBS specification and I'm going to ask you about this generally first of all and ask you a little bit about the CW CT 2008 guidance before we
00:39:31 about the CW CT 2008 guidance before we look at the NBS specification in any detail can you just explain to us what an a specification for a project like this actually is so written document
00:39:46 this actually is so written document either describing or prescribing elements of the buildings and their performance yes and could you just help us what does it
00:39:59 and could you just help us what does it look like it's if I want to fill out an NBA specification what is it what does it look like it's a it's a program like a computer program computer program and
00:40:15 you there's a lot of pre-written classes you can choose to include in your
00:40:24 printout or that the publish document or you can write a spoke closest it allows
00:40:35 you can write a spoke closest it allows both yes and would you agree with me that on a project like grenfell tower the specification which formed part of the employer's requirements was a
00:40:47 the employer's requirements was a particularly important document yes now let's look at the NBS specification for Grenfell tower it's SE a zero zero zero zero zero one
00:40:59 it's SE a zero zero zero zero zero one six nine please now this version is dated the 30th of January 2014 and this is the final version and I appreciate
00:41:10 is the final version and I appreciate that mr. rec that you had left by this point but there were two earlier editions of this document in November 2014 and we can see those but we can
00:41:22 2014 and we can see those but we can work on this one because there's a final final edition generally would you agree that it's on the basis of the content of of this specification that a tendering
00:41:33 of this specification that a tendering company can undertake an assessment or how much it would cost to under to undertake a project yes yes and ultimately whether to put in a bid and
00:41:44 ultimately whether to put in a bid and if so how much yes and it's possible and it sounds like a simple question but it's possible isn't it to have have different types of specifications
00:42:00 yeah if you imply you can prescribe or describe certain elements yes yes and indeed miss Grange explored those with mr. Sains but let me just see if I can get your evidence on it and would you
00:42:12 get your evidence on it and would you agree that there's a specification that you could ask for in this in the NBS spec which indicated a desired outcome
00:42:24 yes and you'd call that a performance specification would you yes yes and do you agree with with me that that would provide the main contractor all the subcontractors with a very large amount
00:42:35 subcontractors with a very large amount of discretion as to the type of products the actual materials to be used in order to achieve the specified outcome correct and then alternatively is it possible to
00:42:48 and then alternatively is it possible to specify in the specification full details and criteria for the product which has got to meet yes and that would be a prescriptive specification yes and that would then give the main contractor
00:43:00 that would then give the main contractor or subcontractors a choice to select between different materials which would meet the criteria of the product type specified
00:43:13 yeah that would have the freedom to suggest an alternative yes and then there's a third type proprietary
00:43:24 there's a third type proprietary specification yes yeah and with that but I'd be right in thinking that that would provide a narrowly defined set of parameters that would not permit contractors to propose
00:43:35 would not permit contractors to propose alternatives to the product specified
00:43:48 don't know about that well but what would you understand by the phrase proprietary specification
00:44:05 to me prescribed and proprietary or small s the same I see what would you call the specification which specified
00:44:17 call the specification which specified products by name in the NBS itself don't be prescribed I see it and would you agree that it's up to the architect for the client to decide how prescriptive the specification is yes
00:44:31 prescriptive the specification is yes and would you also agree that the design has to be developed in accordance with the NBS specification yes yeah so and
00:44:44 the NBS specification yes yeah so and again correct me if I'm wrong about this but it would it be right that the NBS specification would control the precise amount of discretion or flexibility that the contractor would have in developing
00:44:56 the contractor would have in developing the design
00:45:08 I mean to my understanding that the contractor always had a choice to put forward an alternative even even though you described exactly what materials or
00:45:21 you described exactly what materials or components you would like to have involved in the project is your understanding general or is your understanding of is your understanding on this project it was on this project
00:45:34 on this project it was on this project as well right now looking at term if we can please page nine of your statement if we can get back to that which is se a zero zero zero one four to seven eight
00:45:45 zero zero zero one four to seven eight I'd like you to look please a paragraph twenty five point four
00:45:56 and that 25.4 you say studio studio he included the NBS the standard NBS design and performance specification for
00:46:08 and performance specification for rainscreen cladding at clause age 92 stroke 3/10 of the NBS specification you see that yes which required the building
00:46:19 see that yes which required the building contractor to comply with CW safety standard for systemized building envelopes among other criteria including part 6 which relates to fire performance see that yes and then if you look at
00:46:30 see that yes and then if you look at paragraph 1 3/4 of your statement we just go on to that please which you'll find on page 33
00:46:43 you say I included the standard NBS specification precedent age 92 for rainscreen cladding which required the building contractor to comply with the CWC t stand of a systemized building
00:46:54 CWC t stand of a systemized building envelopes I did not specify the spoke design or fire performance requirements for the thermal insulation see that yes and I just want to focus with you on this your prescription of the C WCT
00:47:06 this your prescription of the C WCT standard for systemized building envelopes and can we look at it it's at se a zero zero zero zero one 69 at page
00:47:18 se a zero zero zero zero one 69 at page 68 now this is within the spec itself first of all this is where we see it being specified in the spec and if you
00:47:30 being specified in the spec and if you look at a paragraph or clause 220 there on page 68 it says you see specification compliance standards the Center for window and cladding technology CW CT
00:47:42 window and cladding technology CW CT standard for systemized building envelopes reference information for the duration of the contract keep available at the design office workshop an on-site copies of the center of for window and
00:47:54 copies of the center of for window and tanning technology ce WT t standard for systemized building envelopes publications invoked by the CWC t standard for systemized building envelopes now you told us earlier in
00:48:08 envelopes now you told us earlier in your evidence this morning that you weren't familiar with the contents of the CWC t standard itself is that correct is it that's correct so can you
00:48:22 correct is it that's correct so can you explain how come you first of all start was it you who put the CW TC standard into the specification there at paragraph what 220 as we see
00:48:36 paragraph what 220 as we see I don't recall it could have been me it's a standard pre-written cloth you can take in to be included in
00:48:49 cloth you can take in to be included in the document yes and what when it was included do you remember whether you applied your mind to whether it should be there or shouldn't be there
00:48:59 I think I do recall that I was thinking it should be there right yes can we look
00:49:12 it should be there right yes can we look at page 69 please the next page which is paragraph 310 or clause 310 was still within the spec where you can see design performance requirements CW CT standard
00:49:24 performance requirements CW CT standard for systemized building envelopes and then the different elements of the CW CT standard that they're set out and there are seven of them also in part six is
00:49:35 are seven of them also in part six is far performance do you remember that being part of the NBS spec I wouldn't read it do you think it was there before
00:49:46 read it do you think it was there before you started and developing the speckled or did you put it in can we look please at inq zero zero zero one one three
00:49:57 at inq zero zero zero one one three three nine
00:50:03 and this is an extract from the NBS software package it is familiar I'm sorry to interrupt you but we've got a problem with one of our computers right
00:50:14 problem with one of our computers right been updating itself and now is not scrolling the transcripts right anyway there's someone from the technicians room could come and help us yes mr.
00:50:29 room could come and help us yes mr. chairman we just take a pause but not a break but I don't think this is gonna take very long we went
00:50:41 well the system suggests you carry on and we'll pick it up as we go all right what if you get into difficulties mr. chairman we can always we can always pause or break but before I go to the
00:50:53 pause or break but before I go to the ball I'm about to show you mr. Ayer can I just ask you what was the purpose of placing a the specification or placing in the specification the precise reference to the C WCT standard and the
00:51:08 reference to the C WCT standard and the other details we've just looked at I believe to safeguard compliance with those standards safe code compliance with those standards and safeguard compliance with ADB I don't think
00:51:24 compliance with ADB I don't think there's a reference to ADB okay let's look then please at inq zero zero zero one one three three nine which I think got on the screen there which is
00:51:38 got on the screen there which is paragraph 220 this isn't as you to tell you what this is this is an extract from the NBS software package from the November 2013 version of the NBS and the
00:51:51 November 2013 version of the NBS and the enquiry asked the NBS to provide it with its software including what would have been available at November 2013 mr. Rick so just so you know what it is the first general question is would studio in
00:52:02 general question is would studio in usually do you recall make sure that the software it was using was up-to-date the NBS software yes I believe so yes do you recall whether you were using a version
00:52:13 recall whether you were using a version of the NBS software to develop the NBS specification which had incorporated all the NBS updates I trusted that was her
00:52:25 the NBS updates I trusted that was her right
00:52:27 right does that does that mean you didn't shake yourself no did you do you have any reason now to think that you weren't using the up-to-date NBS software now
00:52:40 using the up-to-date NBS software now looking at this screen this is a screen shot from the NBS the specification and we can see that the CW TC standard is a
00:52:52 we can see that the CW TC standard is a standard NBS clause that's automatically inserted into h92 of the NBS the age 92 section yes yes were you familiar with that at the time yes if you can also
00:53:08 that at the time yes if you can also look just to complete this at inq 0 0 0 1 1 365 we can see that Clause or
00:53:20 1 1 365 we can see that Clause or paragraph 310 CW CT standard for systemized building envelopes and then the different parts including part 6 fire performance were also part of the
00:53:32 fire performance were also part of the standard NBS clause that gets inserted into the h92 section of the NBS at the time yeah it's it's offered for inclusion and you just changed a question mark to a green tick and then I
00:53:45 question mark to a green tick and then I send a document right ok I just go back to the NBS spec itself SC a 0 0 0 0 0 1
00:53:59 to the NBS spec itself SC a 0 0 0 0 0 1 6 9 at page 68 and look at close to 20
00:54:07 you can see there that there's an that the words reference information for the duration of the contract keep available that design office workshop and on-site copies of the standard see WTC standard
00:54:22 copies of the standard see WTC standard and the publications invoked by the CW t - CT standard that does not appear to be part of the standard form do you know who inserted that in or perhaps it was
00:54:36 who inserted that in or perhaps it was part of the standard form do you remember the missing to understand what what's the difference
00:54:47 do you remember whether you made a decision to include that second bullet point under Section 220 which required
00:54:59 point under Section 220 which required the CW CT standard in publications to be kept at the design office workshop and on site
00:55:08 isn't that part of their standard couples well it may be my the question is did you did you focus on that and make a decision to include it
00:55:27 do not recall I might have okay now can we just look at the CW CT standard
00:55:38 we just look at the CW CT standard quoted in the NBS spec I know now you say you weren't familiar with it saved my questions may not take terribly long but let's just look at it it's CW CT
00:55:50 but let's just look at it it's CW CT zero zero zero zero zero one nine I'm so sorry I've just given you a wrong reference this is a CW CT guidance this
00:56:01 reference this is a CW CT guidance this is the Sivir CT guidance and it's dated March 2011 this is technical note 73
00:56:10 which would be one of the pieces of guidance issued by CW CT referred to it the paragraph 220 we've just looked at were you familiar with this document do
00:56:21 were you familiar with this document do you think at the time you were involved in developing the specification No so if I were to ask you detailed questions about its contents would you be able to help me don't know if I was
00:56:47 all right well not not not the guide list let's look then at the standard please this is CWC t 0 0 0 0 0 46 this
00:57:04 please this is CWC t 0 0 0 0 0 46 this is the first page of it and you can see part 6 fire performance on the first page just looking at this document on the screen does it look familiar to you no let me just ask you one or two
00:57:17 no let me just ask you one or two questions then about its contents bearing in mind that it wasn't familiar to you at the time but I wondered I want to know whether the principles in it were familiar to you can I ask you please to go to page 11 of
00:57:28 can I ask you please to go to page 11 of this document and look at paragraph 6.3
00:57:37 under under paragraph 6.3 fire resistance I just want to ask you this about the blue italics at the bottom now
00:57:49 about the blue italics at the bottom now just to be clear this is the standard and the words in ordinary writing in black are the standard and the blue italics are commentary to say you're
00:58:00 italics are commentary to say you're clear about that and the second paragraph from the bottom of page 11 says aluminium envelope systems do not normally have significant resistance to fire most unmodified aluminium building
00:58:11 fire most unmodified aluminium building envelopes will provide only 10 to 20 minutes stability and integrity resistance and negligible insulation resistance were you aware of that as a principle or observation at the time of
00:58:23 principle or observation at the time of your involvement in the ground floor project no no can I ask you to be shown please page 15 of the same document
00:58:35 this is paragraph six point six point one under materials six point six point one refers to the materials in rainscreen cavities and again if you
00:58:46 rainscreen cavities and again if you look at the again if you if you look at the words this time will look at the blue italics in a moment it says the cavity behind a rain screen and in front of the air barrier should not include
00:58:57 of the air barrier should not include materials which can significantly promotes flame spread within the unseen cavity in general this zone may contain a timber aluminium or other medical metal vertical framework an insulation
00:59:08 metal vertical framework an insulation of appropriate resistance to combustion you see that yes okay and then it goes on having that's the background to look at thee and we can look at the blue italics together the use of any combustible material for the supporting
00:59:21 combustible material for the supporting framework and insulation and those are important words and insulation within the cavity may need to be considered as the building height increases were you aware of that as a general principle at
00:59:32 aware of that as a general principle at the time of your involvement
00:59:44 No and if you look at the next paragraph itself six point six point two insulation materials insulation in walls
00:59:55 insulation materials insulation in walls of buildings with a story more than 80 meters above ground level should be of limited combust ability were you aware of that as a general principle at the time of your involvement in the
01:00:06 time of your involvement in the Granville Tower project
01:00:12 a ton Rico I was right we looked at paragraph twelve point seven of a DB earlier on this morning mr. akin you're in your evidence which referred to
01:00:24 in your evidence which referred to materials of limited combust ability can I just be clear then were you aware at the time of your involvement in the Grand Vitara project of the concept of
01:00:35 Grand Vitara project of the concept of materials of limited combust ability
01:00:45 I don't recall I know my awareness came later in my professional career I don't know what I acquired a knowledge prior
01:00:56 know what I acquired a knowledge prior to benefit projects I see so were they followed from that answer that you you were not aware of of the definition of what would constitute a material of
01:01:08 what would constitute a material of limited kousaka's
01:01:15 would you would you say having looked at a little bit of this standard and there's plenty more we could look at that before drafting the elements of the NBS specification dealing with the rain screen system h92
01:01:27 screen system h92 it would have been important for you to familiarize yourself with the relevant requirements of both of the building regulations and the approved guidance
01:01:46 can you repeat the question yes would you agree with me that well now that we've looked at a little bit of the CW CT standard that before drafting the
01:01:58 CT standard that before drafting the elements of the NBS specification relating to the rainscreen cladding under part age 92 it would have been important for you to familiarize yourself with the requirements of the building regulations and the approved
01:02:10 building regulations and the approved guidance or approved document b to be more precise
01:02:25 I mean retrospectively looking at it I think it would help if I had a better understanding of course so lesson learned
01:02:39 but we had a fire consultant on the job and I considered fire related issues
01:02:51 quite a complicated subject outside of my competence
01:03:03 did you say we had a fire consultant on the job was that who's that it would be x over did X over play any part in
01:03:15 x over did X over play any part in helping you formulate the contents of the NBA specification I couldn't recall at a time but I no have any evidence
01:03:27 at a time but I no have any evidence that I was in contact with Terry Ashton with regards to cavity barriers apart from the old discussion with Terry Ashton about cavity barriers the
01:03:39 Ashton about cavity barriers the question was a bit of a broader one do you recall ex ever having any input into the choice of materials or choice of space of of guidance such as the CW CT
01:03:50 space of of guidance such as the CW CT in the NBA specification not to my knowledge I don't know and if you could
01:04:01 knowledge I don't know and if you could look at page 12 please of the CW CT guidance while we're on it
01:04:11 you can see it's quite a long chunk of blue italic text on that page but four paragraphs down it says adb provides guidance on the fire resistance requirements for external walls did you
01:04:24 requirements for external walls did you yourself check adb fire resistance requirements for the external walls when building this specification up don't
01:04:36 building this specification up don't recall that ok is there a reason why you might not have done
01:04:51 men
01:04:55 I believe I assumed that the design of the of the cladding and the materials
01:05:06 the of the cladding and the materials involved had been considered for my engagement and some of the choices of materials I inherited some of them
01:05:24 materials I inherited some of them appeared in the stage D report I read
01:05:30 [Music]
01:05:37 can you repeat the question I forgot did well let me let me take it to slightly differently then if you look at the words I've just shown you on the page it says it says adb provides guidance on
01:05:50 says it says adb provides guidance on the fire resistance requirements for external walls and did you did did you know that the CW CT guidance itself contains a link to ADB and that at least
01:06:03 contains a link to ADB and that at least in that respect and tells you where to look if you want guidance on the fire resistance requirements for external walls no because I wouldn't have worked ok and might but the question I then
01:06:17 ok and might but the question I then asked you was whether you checked the ADB fire resistance requirements for external walls when you were developing the specification I don't recall doing that right we're now going to turn to a
01:06:33 that right we're now going to turn to a different topic and mr. chairman this will take us beyond the break but we can start it certainly it would it probably would be good to do another 10 minutes
01:06:44 would be good to do another 10 minutes or so second are you annual right for another 10 minutes or so mr. it I am then we'll have a reasonable break yeah very good okay to turn to the topic of ACM specifying the ACM the aluminium
01:06:56 ACM specifying the ACM the aluminium composite prior to your involvement on grenfell have you actually ever used or specified a composite panel such as ACM
01:07:08 specified a composite panel such as ACM for use as as a rain screen element
01:07:17 I don't think I did what about for any other purpose have you ever prescribed an ACM panel for any purpose they were
01:07:30 an ACM panel for any purpose they were just going through my previous projects don't think I don't were you aware that composite panels whether aluminium all
01:07:44 composite panels whether aluminium all or indeed zinc for that matter could come with different kinds of core for example fire resistant core can I don't
01:07:57 example fire resistant core can I don't recall but I was aware of it at the time okay
01:08:01 okay is that something you came to learn later yes
01:08:04 later yes later on a project or later it is a result of the Grenville tower fire there was some a different project prior to the fire it was at the Bromley South yes
01:08:19 the fire it was at the Bromley South yes that's the one did you at the time understand at the time of grenfell understand how a cladding panel with a polyethylene core might behave in a fire
01:08:32 sorry lost of beginning of the question yes at the time of the Grendel tower project
01:08:38 project did you understand did you have any understanding of how a cladding panel with a polyethylene core might behave in a fire no were you aware at all at that
01:08:49 a fire no were you aware at all at that time that you have that composite rainscreen panels such as ACM could contribute to external flame spread
01:09:02 did you know what polyethylene actually was some sort of plastic some sort of plastic did you think positively about
01:09:13 plastic did you think positively about how that some sort of plastic might contribute to the spread of fire no at the time of your working on the grenfell project were you aware of previous fires involving external external cladding
01:09:24 involving external external cladding facades on high-rise residential buildings such as for example Mosley Heights in Liverpool in 1991 no what
01:09:35 Heights in Liverpool in 1991 no what about garnet caught in Irving in 1999 no the fire at Lac an old house in Southwark in London in 2009 I learned about it
01:09:48 were you aware of the the spate of fires in high-rise buildings in the UAE in 2012 to 2013 no and what about the well-publicized fires in dubai at the
01:10:01 well-publicized fires in dubai at the address or the torch in 2015 I know that's after your time on the green filter project okay can we then turn to the process of selection of the ACM
01:10:14 the process of selection of the ACM panels can I ask you to go back please to your statement at TSE a zero zero zero one four to seven eight and go to page eight please
01:10:28 and I'd like you to look at paragraph 25.1 and you say they're from what I can
01:10:39 25.1 and you say they're from what I can recall polyethylene core composite panels had already been considered for the planting for the project before my involvement and the project and I do not think my inquiry about these types of
01:10:51 think my inquiry about these types of panel was the first time that they were considered then you go on to consider some drawings we've come to look at that in detail are you are you saying here that you saw those drawings you refer to
01:11:02 that you saw those drawings you refer to at the time and concluded from them at the time that PE composite panels had already been considered I saw those
01:11:15 already been considered I saw those drawings there was part of the documents I studied before I started working on the specification and developing the drawings I see so just to be very clear you're not relying on those drawings now
01:11:27 you're not relying on those drawings now as evidence to support your belief that at the time no okay can I ask you to look at se a zero zero zero zero one five eight six and this is the first of
01:11:41 five eight six and this is the first of the two drawings you refer to in paragraph twenty five point one as those you looked at at the time now
01:11:52 if you look at this drawing which is the studio redrawing of the of September 2012 so before your involvement at the
01:12:03 2012 so before your involvement at the top right hand corner of the drawing you can see it says composite zinc panel and then I think it says pigmented green yes yes and that's on the spandrels
01:12:16 yes and that's on the spandrels you can also see composite zinc panels on the columns on the right hand side lower down and at the bottom of the drawing yes you can see it there and do
01:12:28 drawing yes you can see it there and do you this was one of the drawings that you looked at you say at the time to support your view or knowledge that ACM
01:12:39 support your view or knowledge that ACM had already been selected do you accept that looking at that drawing there is no reference there to a polyethylene core correct or indeed an iminium composite
01:12:50 correct or indeed an iminium composite yeah what were there to your knowledge zinc composite panels on the market that did not have a polyethylene court
01:13:08 how did this drawing when you looked at it at the time lead you to think that ACM had already been considered
01:13:27 well I might have mixed up the zinc and aluminum but what would I meant are composite cladding materials with a metal sheet on them we're considered
01:13:38 metal sheet on them we're considered before my involvement
01:13:45 right so you might have mixed up zinc with it with aluminium that's quite an it's quite a mix up isn't it my question really is how could you confuse zinc for aluminium if as you say in your
01:13:58 aluminium if as you say in your statement you thought ACM aluminium had already been specified before you came into the project by reference to these pre-existing drawings
01:14:13 I mean sometimes you use these abbreviation like a SEM too often you forget what a stands for you just know it's a it's a metal and yeah ACM is only whom and I probably made a mistake
01:14:38 but there's no reference in this drawing to polyethylene as part of was the material in the core composite is there
01:14:50 material in the core composite is there no so my question really is how could destroying have led you to think that polyethylene core composite panels that were prepared in drawings before you
01:15:02 were prepared in drawings before you became involved in the project I think I took the word composite zinc panel or metal composite metal panel as
01:15:17 containing that plastic core because I guess that's what we had samples of in the office and I was just familiar with
01:15:33 program how it looked
01:15:38 if you look then at the second of the two drawings that you refer to at paragraph 25 point one of your statement this is s ei 0 0 0 0 2 1 3 5 and again
01:15:53 this is s ei 0 0 0 0 2 1 3 5 and again if you look at the top right-hand corner you can see that it says composite zinc column cladding not CH to taper to match
01:16:04 column cladding not CH to taper to match you see that and then then 3 up from the bottom on the right hand side composite zinc column cladding quartz and composite zinc spandrel panel quartz yes
01:16:18 composite zinc spandrel panel quartz yes mm-hmm
01:16:18 mm-hmm yes again there's no reference in there to polyethylene so same question again how did you how did those drawings which
01:16:29 how did you how did those drawings which don't refer to polyethylene tell you that polyethylene core composite panels were already had already become involved
01:16:40 were already had already become involved before you got into the project I think the inclusion of the word polyethylene and my statement
01:16:53 came in from my new village at a time when I was providing the statement I see because I've read so much about it
01:17:04 because I've read so much about it probably mixed up I fully say it just to be clear would you agree that it's wrong to say that either of these drawings show that a panel with a polyethylene core had been
01:17:16 panel with a polyethylene core had been considered yet they don't show specifically polyethylene I don't know but there's a fire product was I can't
01:17:28 but there's a fire product was I can't remember but it was a product which then if you looked it up would tell you it had a polyethylene I don't know like mr. chairman just one or two more questions on this and then we can break yes did
01:17:40 on this and then we can break yes did anybody ted studio ii tell you that a the composite zinc panels on these drawings were polyethylene polyethylene had a polyethylene core I don't recall
01:17:54 had a polyethylene core I don't recall explicitly earing word polyethylene right so does that mean that when you
01:18:05 right so does that mean that when you were involved in the project developing the NBS specification you knew that the panels were a composite but didn't know what material the core was having the
01:18:20 what material the core was having the sample in my hands I knew it was some sort of plastic but you didn't investigate further don't say that it mr. chairman is not a convenient moment
01:18:31 mr. chairman is not a convenient moment for a break yes thank you very much well no brainer to ask you please not to talk to anyone right or evidence or anything relating to it well they're out of the
01:18:42 relating to it well they're out of the room yes if we're only having one break this morning so I think you can be a little bit more generous to you than if we were having to so I again say he's be back to resume at 25 to 12
01:18:55 back to resume at 25 to 12 we'd like to go to the ocean yes
01:19:08 25 to 12 years
01:36:07 mr. rector come back in please
01:36:29 Rachel ready to carry on mr. ik yes ma'am thank you very much yes mr. mr. Rick um can I start by going back over a question and answer that we had this
01:36:40 question and answer that we had this morning together where I might have been a fact I probably was a bit unfair to you I just want to set the record straight on that it you don't need to be shown this but for the record it's it's
01:36:51 shown this but for the record it's it's page 97 47 so on page 47 at lines 9 and 10 and the answer at 15 to 20 and I put to you that a cm an iminium composite
01:37:02 to you that a cm an iminium composite had already been specified and when we were looking at the drawings which showed Zink and in fact to be fair to you your paragraph 25 point 1 doesn't
01:37:13 you your paragraph 25 point 1 doesn't say that aluminium polyethylene composite panels had been specified only PE so your answers in respect of that that the mix are potentially between
01:37:25 that the mix are potentially between zinc and aluminium I think I've found it on mine this reading of your witness statements ok thank you folks now moving on can I ask you please to
01:37:36 now moving on can I ask you please to look at se a 0 0 0 1 4 2 7 8 at page 9
01:37:44 this is paragraph 25 point 2 of your statement let's just look at that together we're looking at this is it
01:37:57 together we're looking at this is it should be page 9 of your statement se a 0 0 0 1 4 2 7 8 at page 9 that's it paragraph 25 point 2 you say I do not
01:38:08 paragraph 25 point 2 you say I do not recall discussing the fire rating or fire performance of polyethylene-based composite panels while I worked on the project I also do not recall discussing whether these panels came with fire retardant calls or were there any
01:38:20 retardant calls or were there any investigation on compliance with Part B of the building regulations 2010 building regulations had taken place I may have assumed that compliance with Building Regulations had already been confirmed prior to my involvement since
01:38:33 confirmed prior to my involvement since I it's been simply been asked to obtain samples of these materials and the focus appeared to be on the appearance and cost of the product I just wanted to examine that paragraph with you and break it down into into
01:38:44 with you and break it down into into bits if I can first you say you don't recall discussing the fire rating or performance of PE composite panels so there's no I take it that there was no
01:38:55 there's no I take it that there was no discussion at all with mr. Soames or anybody else's studio area on that topic you had to my knowledge and you also say
01:39:07 you had to my knowledge and you also say that you didn't recall discussing whether the panels came with fire retardant cause again can I take it that it didn't occur to you or anybody else has to do a to your knowledge to
01:39:18 has to do a to your knowledge to investigate whether there was a fire resistant or retardant core available
01:39:27 and you say you don't recall whether compliance with Part B of the building regulations have been confirmed prior to your involvement what did you discuss
01:39:38 your involvement what did you discuss that with anybody at all do you remember whether compliance with Part B yes confirmed prior to my involvement yes
01:39:48 [Music] discussing you go on to say I may have assumed that compliance with Building
01:40:00 assumed that compliance with Building Regulations had already been confirmed prior to my involvement do you remember on what basis you made that assumption or may have made that assumption
01:40:09 well since
01:40:13 there had been some research done on the materials before my involvement and when I was briefed by Bruce he mentioned
01:40:25 I was briefed by Bruce he mentioned composite cladding materials sorry about saying there was a report for strategy
01:40:36 saying there was a report for strategy report written and I was fairly new to the project a project which had been
01:40:47 the project a project which had been running for I don't know how long through 2012 and yeah just looking at
01:40:59 through 2012 and yeah just looking at that answers following that up you say when I was briefed by Bruce he mentioned composite cladding materials did he mention them in the context of fire
01:41:11 mention them in the context of fire safety no what did he tell you if you can recall about the composite cladding materials I mean as I remember back then
01:41:23 materials I mean as I remember back then the focus was some rigidness of the cladding material given that it was going to be mounted on a in a height
01:41:36 going to be mounted on a in a height would have a lot of wind exposure and in fairly large panels you say all say in
01:41:49 fairly large panels you say all say in that last answer but one that there had been some research done on the materials before your involvement what was that research do you know
01:42:01 what was the research I don't know I haven't done that research but Bruce gave me indication what materials had
01:42:12 gave me indication what materials had been considered and and he told me which one to look at which samples to obtain and he also mentioned liaison with
01:42:25 and he also mentioned liaison with planners and that the cladding material evolved from vividly colored hbl panels
01:42:39 evolved from vividly colored hbl panels to zinc
01:42:49 did Bruce Saenz tell you that research had been done on the ACM panels that were being selected it's difficult to
01:43:04 were being selected it's difficult to use the word research I guess but now is the word so I'm just exploring it with you yeah research to what extent is a
01:43:15 you yeah research to what extent is a question I don't know an answer to but he would have selected potential materials which he would discuss I guess
01:43:28 materials which he would discuss I guess with the clients and the planners right in general terms would you expect compliance to have been investigated
01:43:39 compliance to have been investigated prior to stage D or at stage D or in the stage D report
01:43:49 name
01:43:53 was there a project file that you could check if you wanted to to see whether building regulation compliance had been considered in relation to the ACM not
01:44:07 considered in relation to the ACM not that I recall
01:44:10 if ACM had been Ricard considered and its fire safety the subject of discussion or consideration within
01:44:21 discussion or consideration within studio II where would you expect to see those considerations or deliberations recorded
01:44:51 might have been a report of a design review did you do you remember ever seeing a report of the design review
01:45:04 seeing a report of the design review during your few months of involvement on this project no I think I recall them they're reading the stage D report right okay now you say lower down the
01:45:15 okay now you say lower down the paragraph that you simply asked to obtain samples of these materials you see that yes do you mean PE core composite materials as well yes yes and
01:45:28 composite materials as well yes yes and who asked you to obtain those samples Bruce and what stage of your involvement was that early honorable partway through I think was quite early on and if you go
01:45:44 I think was quite early on and if you go back please a page or two to page six of your statement and look at paragraph 18 with me please you can see this is the
01:45:56 with me please you can see this is the top of page six you can see that you say there I understood from Bruce that the client Casey tma-1 to include options in the tender for aluminium composite
01:46:07 the tender for aluminium composite material ACM cladding so we also require tenderers to provide for alternative ACM materials Raina bond a luca bond and call sink and then you refer to the to the NBS spec from page 63 who was it you
01:46:22 the NBS spec from page 63 who was it you remember that identified renault bond as one of the alternative materials
01:46:33 I don't know who identified it but I got the knowledge through Bruce you got the noise through Bruce okay now you
01:46:45 noise through Bruce okay now you referred a minute ago to an x over report I think do you remember receiving a draft of the
01:46:56 do you remember receiving a draft of the x over outline fire safety strategy in early November 2013
01:47:10 I'm not sure I don't recall it now do you remember reading in the stage D report when you were reading into the project seeing a an issue a version of
01:47:25 project seeing a an issue a version of the xover outline of fire strategy can I then take you to a document se a zero zero zero zero nine seven one six of
01:47:38 zero zero zero nine seven one six of page three please this is an email should be an email right
01:47:56 yeah if you look at the bottom of that page and this is one of those I'm afraid which splits over two pages but if you look at the bottom of that page and on to page four here is an email from Terry
01:48:07 to page four here is an email from Terry Ashton at attics over on the 5th of November - you copied - mr. Soames yes yes and if you flip or are flipped to page four please it says Thomas Bruce further to Bruce's
01:48:20 it says Thomas Bruce further to Bruce's earlier email I've revised the report see draft with changes highlighted in yellow attached and have annotated copies of the drawings with the necessary fire ratings using your color scheme see attached hopefully we should
01:48:31 scheme see attached hopefully we should be able to finalize both within this time scale Bruce Bruce identified now I just want to ask you about the timing of that as we see 5th November 2013 was that before or after do you think you
01:48:46 that before or after do you think you had entered the specification for polyethylene called ACM panels on the NBS spec
01:49:10 I guess this would happen after that this email would I believe because I would start working working on the NBS
01:49:22 would start working working on the NBS specification fairly from the outset of my involvement today September time I believe so yes I see okay were you were you ever asked to send x over details of the cladding panels
01:49:34 over details of the cladding panels particularly the alternative cladding panels of Ray no bond ACM PE core 2x over know where you were
01:49:48 ACM PE core 2x over know where you were where of weather x over knew or didn't know of what was being specified for the materials for the proposed rain screen for grenfell but I knew know where the x
01:50:03 for grenfell but I knew know where the x over knew well I didn't nobody knew yeah
01:50:13 so you speak just to be clear you didn't know whether xover knew or didn't know about what was proposed for rainscreen crowd okay
01:50:24 crowd okay now go to paragraph 30 of your statement please at page 10 of se a 2 0 0 0 1 4 2 7 8 and you say there towards the bottom
01:50:42 7 8 and you say there towards the bottom of the page you say as I've stated above I cannot recall discussing the fire rating are all per fire performance of any of the padding panels that I
01:50:54 any of the padding panels that I investigated and source from suppliers and manufacturers while I worked on the project you see that yes and you refer in your statement from paragraph 26 onwards from page 9 to a series of
01:51:10 onwards from page 9 to a series of contacts with different cladding panel to suppliers or distributors in order to obtain quotes in general term can I can
01:51:21 obtain quotes in general term can I can we take it that your focus at that time was on cost and appearance yes and you also say and I'll take this quickly at
01:51:32 also say and I'll take this quickly at paragraph 37 or 38 of your statement that you asked suppliers questions about fixing methods due to the impact that the fixing method may have on the speed of installation and the cost yes yes did
01:51:45 of installation and the cost yes yes did you ever ask any of the and suppliers whether the fixing method would affect its fire performance I don't believe I did did you ever ask suppliers about the
01:51:58 did did you ever ask suppliers about the fire performance of any of the panels that you were investigating with them I don't believe I don't did you ever expect it would follow you didn't check with them whether the
01:52:10 didn't check with them whether the panels that you are considering achieved class naught or the European equivalent equivalent now go back to your statement
01:52:23 equivalent now go back to your statement please at paragraph 26 this is where you deal with a meeting we can just get back to that it's on page 9 you say on the
01:52:35 to that it's on page 9 you say on the 27th of September 2013 I attended a meeting with Bruce Sohn studio a Mark Harris commercial manager of Harley and Ray Bailey managing director of Harley at a coffee shop or restaurant at Hayes
01:52:46 at a coffee shop or restaurant at Hayes Galleria near London Bridge station which Bruce had arranged to discuss the cladding specification and this meeting mr. eckworth will come up again in in
01:52:59 mr. eckworth will come up again in in the evidence of you and other witnesses but we call this the Hays Galleria meeting and can we and just look you say
01:53:15 meeting and can we and just look you say there that you arranged to discuss the cladding specification if we go on to paragraph 29 of your statement you you
01:53:28 paragraph 29 of your statement you you say we just sit in the middle of page 10 I cannot recall the details of the discussion and I did not take a note of the meeting if I received any hard copy
01:53:40 the meeting if I received any hard copy material at the meeting it's probably lost I cannot recall whether or not we discuss the suitability of PR our API our poly I say cyanurate or rigid foam and then you go on to say in the next
01:53:52 and then you go on to say in the next paragraph in the second sentence however I've reviewed my email correspondence at the time and it's clear that we must have discussed the different types of chatting at the meeting with Harley although I think it was meant to do with the appearance and price of the various
01:54:04 the appearance and price of the various materials and not their fire performance or rating you see that yes because that's power of 30 at the end now
01:54:14 does that include at the meeting you didn't think you didn't discuss fire rating or fire performance of any of the cladding panels that you'd investigated at the Hays galleria meeting I don't
01:54:26 at the Hays galleria meeting I don't recall that right now at that stage of the design selection of materials to include within the NBS specification would you normally ask a specialist subcontractor about what materials
01:54:38 subcontractor about what materials should be put in
01:54:55 I don't know announcer Teressa okay well maybe it wasn't a brilliant question I mean let me try it a different way as late as at the date of the Hays galleria meeting 27th of september 2013
01:55:07 galleria meeting 27th of september 2013 and given the state of the specification at that point was it at that time or at that point your normal practice to
01:55:18 that point your normal practice to involve specialist subcontractors in the decision about what materials to put in to an NBS specification such as this
01:55:31 to an NBS specification such as this rhetoric announcer is because for me this kind of meeting was new I never heard previous dealings with
01:55:42 I never heard previous dealings with specialist subcontractors helping out and developing the design right say say this was a meeting such as the Hays galleria meeting was a novel experience
01:55:54 galleria meeting was a novel experience for you as an architect yes did you ask mr. Sains given that it was a novel experience why you were having it before
01:56:08 experience why you were having it before you enter it
01:56:11 I wouldn't question the reasons I think my assumption was to check build ability but especially subcontractor and what
01:56:26 but especially subcontractor and what their standard offer would be right what is achievable for given price you say
01:56:38 is achievable for given price you say check the build ability what do you mean by that again taking it back to the
01:56:49 by that again taking it back to the price check what sort of panels what sort of fixing method we can expect within the budget we have I see so this was essentially a
01:57:04 we have I see so this was essentially a budget issue is that fair or were there other things as I said I really doesn't recall and I regret not being able to
01:57:15 recall and I regret not being able to recall or anything equalization fair all right I guess let's look on it let's look on us some emails before before I
01:57:27 look on us some emails before before I do that just before we leave the got Hays Galleria meeting although we may have to come back to it did you formally impression at that meeting that Harley
01:57:39 impression at that meeting that Harley had a preference for a cm as the material for use on the rain screen
01:57:59 I don't know whether it was a preference it was definitely but in their portfolio of projects they worked on whether they
01:58:13 of projects they worked on whether they advocated it as a preference I don't recall no I appreciate it's a long time ago and I'm asking you a impressionistic question let me try another one did you form the impression
01:58:25 another one did you form the impression at that meeting so far as you can recall that hardly had a particular preference for a particular manufacturer of ACM
01:58:36 don't record that okay can I then take you to se a zero zero zero zero nine two four zero this is an
01:58:50 zero zero nine two four zero this is an email the of the 18th of October 2013 from you to Paul cousins copied to Bruce zones and Paddy Glennon and Paul cousins
01:59:01 zones and Paddy Glennon and Paul cousins was at what do you remember asides siga exactly and you you say to him in that email hi Paul referring back to our
01:59:12 email hi Paul referring back to our phone call today please can you please provide quotation for supply of the zinc Nova composite panels in line with our design intent drawings issued previously we are under pressure from the client
01:59:23 we are under pressure from the client regarding the costs with suggestions flagged of using aluminium we and the planners would much rather see zinc up there I'll be expecting your quote by Tuesday next week as discussed that is
01:59:36 Tuesday next week as discussed that is the reference to the planners there to the our bkc planning department I
01:59:42 believe so did you get the feeling that studio he was under some kind of pressure to to specify cheaper ACM material instead of zinc
01:59:57 from the client yes yes what gave you that impression
02:00:07 Bruce relaying the fact that those ACM alternatives we're to be included in the
02:00:20 alternatives we're to be included in the specification and I think it's right there that as we may see that you continue to pursue zinc as an option yes
02:00:32 continue to pursue zinc as an option yes can I ask you to go to paragraph 59 of your statement please page 16 NCAA triple zero one four two seven eight page 16 and you say there Simon Walker s
02:00:46 page 16 and you say there Simon Walker s IG responded and you you say that they'd made contact with Mark Harris he's Harley and would provide budgets to
02:00:57 Harley and would provide budgets to Harley the following week for the rainscreen cladding you see that mm-hm yes so ultimately you put sig in touch with Harley so that you could get a price essentially for both the supply
02:01:08 price essentially for both the supply and installation of the rain screen yes yes yeah now can I ask you to move on then to se a zero zero zero zero seven and sorry zero zero zero zero nine seven
02:01:21 and sorry zero zero zero zero nine seven three six
02:01:26 this is an email to you from mark Harris on the 7th of November 2013 with a quote for the protease H our panel you see
02:01:39 for the protease H our panel you see that and then he starts good morning Thomas a response has been received at last from kme and do you remember who kme were was the provider of that panel
02:01:58 kme were was the provider of that panel yes and you see the quote below it protease HR composite 282 pounds per square meter and mr. Harris says quite what this finish is based on I have no
02:02:09 what this finish is based on I have no idea due to lack of information and then he says this I have to say from a Harley selfish point of view our preference would be to use ACM it's tried and tested on many Harley projects and we
02:02:20 tested on many Harley projects and we are confident in the cost base that said we are of course an envelope contractor and would be happy to clad the building in the material of choice you see that yes what did you understand when you received this email that Mark Harris
02:02:32 received this email that Mark Harris meant when he said from a heart a Harley selfish point of view
02:02:40 I think that they just had a frustrated experience and dealings what clear me on providing the costs right you use you
02:02:51 providing the costs right you use you say that is that based on any discussion or any other communication you had with mr. Harris or anybody else at Harley or is it based on this email
02:03:10 well I was part to an email chain or more emails and then just as I believe where we were chasing came in for the
02:03:26 where we were chasing came in for the costs did you ask mr. Harris what he meant when he said from a Harley selfish point of view our preference would be to use ACM I don't remember asking him did
02:03:37 use ACM I don't remember asking him did this expression of Harley's selfish point of view and their preference influenced so far as you are concerned the decision to include ACM as an
02:03:50 the decision to include ACM as an alternative in the NBS specification
02:03:57 didn't didn't influence my decision right can I ask you to look at paragraph 65 please on page 17 of your statement you
02:04:12 you set out there your recollection about other projects and you say in the fourth line down I do however seem to
02:04:24 fourth line down I do however seem to recall the Harley had mentioned another high-rise tower project that they'd carried out at the development called Ferry a point in Canning Town at which they had used a cm cladding ACM cladding
02:04:35 they had used a cm cladding ACM cladding was widely used in the industry at the time ie in 2013 and my understanding was that architects at the building industry more generally appeared to be content with its suitability for buildings over
02:04:46 with its suitability for buildings over 18 meters in height now just a number of questions about that do you remember in what context Harlee mentioned the Ferrier Point project when they were showing their
02:04:57 project when they were showing their portfolio was that at the at the Hayes gallery meeting or another time yes yes do you know or do you remember who mentioned the Ferrier Point project you
02:05:13 mentioned the Ferrier Point project you don't know um were you given any details of the Ferrier Point project
02:05:21 I don't recall but yeah they would mention the material used right did they tell you that an iminium composite with
02:05:32 tell you that an iminium composite with a PE core was used on that project don't call that did the fact that they'd mentioned it affect your thinking about the suitability of ACM panels for the grenfell tower project but I showed more
02:05:45 grenfell tower project but I showed more than just this project some of them were high rise buildings quite with this sort of material or product so they showed
02:05:57 of material or product so they showed you other projects as well yes but you see you recall you recall the Ferrier Point project do you recall any others specifically that they showed you know
02:06:09 I just remembered an image seeing it again right to come back to my question did the fact that they had mentioned the
02:06:21 did the fact that they had mentioned the use of ACM on the ferry a point project effect you're thinking about the suitability of ACM panels for use on the grünfeld tower project I believe it did
02:06:34 grünfeld tower project I believe it did yeah in what way that's a it's a fried material which has been used installed on many buildings yes now you go on to
02:06:47 on many buildings yes now you go on to say that the ACM cladding was widely used in the industry at the time 2013 as we've seen in your in your paragraph 65
02:07:00 we've seen in your in your paragraph 65 and I've just read that to you how did you know that ACM was widely used in the industry at the time
02:07:16 just general knowledge seeing it around right and you say that your understanding and this is power of 65 your understanding was that architects and the building industry more generally
02:07:27 and the building industry more generally appeared to be content with the suitability but architects are you including studio II in that yeah I think my stepmothers general okay so you mean
02:07:39 my stepmothers general okay so you mean the architects profession did you have
02:07:50 the architects profession did you have any do you have any recollection of having any thinking at the time as to whether Studio II as an architect itself was content with the use of ACM well let
02:08:06 was content with the use of ACM well let me try a different getting out at a different way at the time what experience to your knowledge did to do we have of the use of ACM in an overt adding project
02:08:22 I don't know specifically do you know how you came to the understanding that architects generally appeared to be
02:08:33 architects generally appeared to be content with the suitability of ACM over 18 meters just seeing the evidence of
02:08:44 18 meters just seeing the evidence of being and is installed on other projects yes
02:08:57 would you agree with the general proposition that the fact that a product is widely used provides no indication of its suitability for any individual project correct and would you also agree
02:09:09 project correct and would you also agree that it's for the design team to establish the suitability of the material for each project as it arises yes and then it would be wrong to assume the suitability of a product purely based on its wide use or its popularity
02:09:23 based on its wide use or its popularity yes do you know the reason why studio II specified the Proteus H our panel in the NBS specification and ACM as one of the
02:09:35 NBS specification and ACM as one of the alternatives the Proteus was the preferred option yes and then I remember
02:09:50 preferred option yes and then I remember quite late there was the request of including the ACM materials
02:10:01 ACM materials and the specification as well indeed my question was what why do you know why studio we specified the Proteus HR as the preferred option
02:10:22 I think back then it would be probably based just on the aesthetics I see if
02:10:34 based just on the aesthetics I see if you can turn the page please in your statement at page 18 and go to paragraph 69 of your statement you say there that you do not recall and discussing the did
02:10:49 you do not recall and discussing the did not recall us discussing the Reina bond and a Lucca bond products you see that yes and you go on to say all which type of ACM core we should use ie polyethylene PE fire-resistant fr or a2 ie a non combustible core while I worked
02:11:03 ie a non combustible core while I worked on the project see that and then you go on to say we and I emphasize the word we included Reynaud bond and I Luca bondas alternative cladding materials in the NBS specification but I cannot recall
02:11:15 NBS specification but I cannot recall exactly how this decision was made I think it may have been made before I became involved in the project or following Bruce's conversation with the planner as referred to a paragraph 67 a bar know when you say we included Rayna
02:11:30 bar know when you say we included Rayna Bond in the third line of that paragraph as you do who did you mean by we
02:11:37 Veon birth for like the team jittery right do you think it was your decision backed up by Bruce or was it Bruce's
02:11:50 backed up by Bruce or was it Bruce's decision backed up by you who made the primary decision here ever come to me from Bruce do you remember Bruce telling
02:12:04 from Bruce do you remember Bruce telling you or in some way communicating with you the nurse decision when was that do you think
02:12:16 I really do not recall right can we next turn to the NBS specification and look
02:12:27 turn to the NBS specification and look at it where we'll see the specification of the cladding panels in that document so that's what we're going mr. rec page 65 this is se a zero zero zero zero zero
02:12:38 65 this is se a zero zero zero zero zero one sixty nine page 65 and you can see
02:12:50 one sixty nine page 65 and you can see that at 65 we have types of rainscreen cladding at the top of the page and this
02:13:01 cladding at the top of the page and this is within H 92 which you can see from the bottom of the page at the top we get paragraph 120 and then if you turn the page to 123 to page 66 you can see 123
02:13:16 page to 123 to page 66 you can see 123 you see that mm-hmm yes and you can see there that proteus HR honeycomb rain screen panel has been
02:13:27 HR honeycomb rain screen panel has been specified who actually inputted the data into the NBS specification so that the Proteas HR honeycomb will appear I
02:13:38 Proteas HR honeycomb will appear I believe that would have been me do you agree with me that that is an example of a proprietary specification in this part of the NBS in other words specification of a particular product by
02:13:50 specification of a particular product by name yes yes and that the contractor is required to supply it and install protease h our subject only to the discretion to propose equal similar or
02:14:01 discretion to propose equal similar or equal products yes yes and just to make that good oh and can I ask you to get back to page 64 please and look at the top of the page just to make sure you have those words in clearly in front of
02:14:12 have those words in clearly in front of you
02:14:15 we probably need to go to the bottom of page six no that's all right 60 64 to be read with preliminaries general conditions and you can see it says
02:14:26 conditions and you can see it says notwithstanding the description of workmanship described in various parts of this NBS nes the contents etc and then second bullet point the manufacturer has noted within the specification are indicative and may be
02:14:38 specification are indicative and may be substituted with similar or equal alternatives so that's what that was clear to you was it that the rest of contractor was required if they were going to going to deviate from Pro to
02:14:50 going to going to deviate from Pro to use HR only to propose similar or equal products currently yes can you explain why that approach was adopted in the NBS
02:15:01 why that approach was adopted in the NBS specification I believe there are two aspects to it one decision on the
02:15:17 aspects to it one decision on the specific material certainly reached to get a bit of planus and the client and second the specialist subcontractor would be developing the detail design
02:15:30 would be developing the detail design and they might have some objections to the selected materials and they should be should have the freedom to suggest
02:15:44 be should have the freedom to suggest alternative to why was Harley is especially well why would any specialist subcontractor because it wouldn't necessarily be Harley at that stage of course why would any specialist
02:15:55 course why would any specialist subcontractor object to the use of protease HR honeycomb as the rainscreen material
02:16:05 could be on several grounds complexity of build ability costs a variable see
02:16:21 did the flexibility that you were building into the NBS specification by the ability for the subcontractor to propose alternative materials
02:16:38 did that flexibility extend to anything other than aesthetics or cost and any
02:16:59 other than aesthetics or cost and any concern they might have I wouldn't foresee
02:17:06 can I ask you to go to page 64 please of your statement and look at paragraph I'm sorry paragraph 64 of the SE of this
02:17:17 I'm sorry paragraph 64 of the SE of this NBS spec se a 0 0 0 0 0 1 69 page 64 at paragraph 11 so it was still on it
02:17:28 paragraph 11 so it was still on it information to be provided with tender you can see that it says there in addition to the cladding specified in the below clause is 120 and 123 submit comparative supply and install costs per
02:17:39 comparative supply and install costs per square meter of the whole tanning system for the following alternative materials and then there are three set out that rain upon durig lost five thousand with three different finishes a Lucca bond with a splitter which is spectra secured
02:17:52 with a splitter which is spectra secured nine one seven and then zinc quartz in composite polymer panel by VM zinc no-face fast and solutions permitted see that yes so the requirement there was to
02:18:03 that yes so the requirement there was to provide quotations yes yes did you draft that in there do you think yeah would be me type didn't yeah is it your
02:18:14 me type didn't yeah is it your understanding that as drafted this wasn't supposed to entitle the contractor to to choose those products that the contractor had to use Proteus HR or a similar or equal alternative
02:18:29 I'm sorry said again but was it your understanding that as it was drafted this didn't entitle the contractor to choose those products just if it wanted
02:18:41 choose those products just if it wanted to it would have to provide a quotation but had to use Proteus HR as a prescribed product or any product that was similar or equal as an alternative
02:18:54 was similar or equal as an alternative yes yes now we don't see any explanation in the NBS specification of what's similar or equal as an alternative is
02:19:07 similar or equal as an alternative is why is there no definition of that phrase
02:19:16 that's a good question I don't have an answer for okay it's similar or equal in what respects did you intend all
02:19:31 what respects did you intend all different aspects of the performance of the material yeah it's probably not clearly defined you're fine
02:19:41 yes I see did studio he consider that rain a bond or a leuco bond that the two out of the three materials we see in paragraph 11 on page 64 there were products which
02:19:54 on page 64 there were products which were similar or equal as alternatives to protease HR
02:20:03 I don't know even a
02:20:10 did you ever go through the thought processes of how it could be that you would be saying produce HR or something
02:20:22 would be saying produce HR or something that's similar or equal but also ask for quotations of Reina bond and a Luca bond I remember being tasked with putting
02:20:34 I remember being tasked with putting this clause in and accept this wording it wasn't my decision on the wording would you agree that studio II by using
02:20:46 would you agree that studio II by using this wording and under eleven had given the contractor a choice to use a product that was perhaps visually similar to produce a jar honeycomb but actually
02:21:02 produce a jar honeycomb but actually might be a less safe product in terms of fire performance
02:21:09 oh yeah I guess the focus for some visual aspect and pitched yes can I ask you to just focus on clause 11 for the
02:21:20 you to just focus on clause 11 for the moment and we could see the alternative product rain Obon dura gloss 5000 and then three different options I showed you those before a moment ago but I just
02:21:31 you those before a moment ago but I just want to focus in a little bit more detail on the first bullet point metallic standard and non-standard satin gloss
02:21:38 gloss what did standard and non-standard mean or denote
02:21:51 you don't know could I just be clear it was it was you who put this into the NBS bag wasn't it well we put it in there to
02:22:04 bag wasn't it well we put it in there to get a bit bruised and I don't know whether I received a list which I was supposed to include I don't know whether
02:22:15 supposed to include I don't know whether the selection of the materials where it originated right if you can't help us identify where standard and non-standard comes from is that what you're saying I
02:22:26 comes from is that what you're saying I can't recall looking at it now no right
02:22:36 okay can I then take you to a document inq 0 0 0 1 1 3 3 6 I'm what this is
02:22:48 inq 0 0 0 1 1 3 3 6 I'm what this is I'll just explain when we see it I in Q 0 0 0 1 1 3 3 6 this is a list of manufacturers of rainscreen cladding
02:22:59 manufacturers of rainscreen cladding panels which was available on the NBS plus product database as at November 2013 do you know what I'm talking about when I refer to the NBS plus product
02:23:12 when I refer to the NBS plus product database yes yes ok just have a look at that list if you would it is actually the first of two pages I want to show you but this is the first page if you
02:23:25 you but this is the first page if you look down it you can see that there is a list of logos of our manufacturers and then the manufacturers identified and then the products that they make you see that yes and we can cast our eye down
02:23:37 that yes and we can cast our eye down there and then you can look at the next one just on this one do you agree that there's no reference to rain a bond or a leuco bond or indeed Proteus a char in
02:23:48 leuco bond or indeed Proteus a char in that list no I can't see it no can I ask you then to look at the second page of the list or second list inq 0 0 0 1 1 3 4 5 and you can see
02:24:08 inq 0 0 0 1 1 3 4 5 and you can see again this is a list of products it comes from the same source the NBS product NBS plus product database as at November 2013 and looking down that list again do you agree again there's no
02:24:19 again do you agree again there's no reference there to Rayna bond a Lucca bond or Proteus a jar yeah I can sued there is a reference there to VM zinc and the very bottom of that page you see
02:24:30 and the very bottom of that page you see notice yes and you could see VM Z or Zed composite do you remember looking at these lists at the time that you drafted paragraph 11 on page 64 of the and the
02:24:44 paragraph 11 on page 64 of the and the specification no you don't write did you check those lists at the time in
02:24:55 did you check those lists at the time in order to make sure that what you were proposing expressly as alternatives to the Proteus HR whirring at least included on the manufacturers lists no why is that I was in direct contact with
02:25:09 why is that I was in direct contact with the manufacturer kami and I saw the product right and what about Reina bond a luca bond and but what about those two
02:25:22 a luca bond and but what about those two rana bandha Deluca bond my recollection is that i was told that these products should be included for the costing purposes told by who
02:25:35 purposes told by who hi Bruce hi Bruce do you remember when you were told by Bruce that you should include those products Randy bonded Alika bond for costing purposes I might be wrong but I think the inclusion of
02:25:47 be wrong but I think the inclusion of the alternatives came into a specification quite late quite late okay just to be clear quite late in your in
02:25:58 just to be clear quite late in your in November right okay I'm going to change topic now mister reckoned go to the
02:26:09 topic now mister reckoned go to the subject of the crown when I say the crown I mean the architectural feature at the head of the building it's right isn't it that by the time Studio II got
02:26:20 isn't it that by the time Studio II got to the tender stage which was late 2013 and then after you left early 2014 but at the time you left no detailed design
02:26:31 at the time you left no detailed design work had been carried out on the crown
02:26:36 yeah not to my recollection I remember working on alternative well let's look
02:26:47 working on alternative well let's look at the NBS specification if you can go to se a zero zero zero zero zero 169 and turn to page 67 please and just to focus
02:27:01 turn to page 67 please and just to focus on the date of this document as we did before this is 30th of January 2014 so this is after you left and at the bottom of page 67 you can see it says paragraph
02:27:12 of page 67 you can see it says paragraph 130 major non standard components crown manufacturer TVC product reference TBC material TBC finished TBC
02:27:23 material TBC finished TBC fixing as recommended by panel manufacturer to suit environmental conditions and there are some details under that and we can see where the last bullet point other requirements include
02:27:35 bullet point other requirements include products fixing interfaces necessary to complete the fabrication and installation you see that yes is its right then isn't it that in effect
02:27:47 right then isn't it that in effect questions about the design the material are finished the fixing we're all left over until after the NBS specification had been completed and sent out to tenderers yeah that's the manifest
02:28:00 tenderers yeah that's the manifest now if we look at an earlier version of the NBS specification this is se a zero zero zero zero zero one five two
02:28:16 this is the version dated the 21st of November 2013 which you get from the very top of page two if I could just ask
02:28:29 very top of page two if I could just ask you to be shown that thank you you could see that so this is at a time of your involvement in the development of the specifications and just to orientate you in the chronology this was the draft
02:28:41 in the chronology this was the draft that was the draft before the 29th of November version a week later or so which was eventually issued to tenderers does that make sense to you yeah okay
02:28:52 does that make sense to you yeah okay now do you you remember who was sent this first draft of the NBS specification
02:29:15 I do not recall can I ask you to look at page 81 please in the first draft of the NBS specification and I want you to look at paragraph 130 when we get to it
02:29:27 at paragraph 130 when we get to it it says major non-standard components crown you see that yes now it looks for we just look at it together as if vm's Inc had been
02:29:40 together as if vm's Inc had been specified as the manufacturer and a specific product there vm zinc composite and material two sheets of zinc half a millimeter thick thermo glued on either
02:29:51 millimeter thick thermo glued on either side of a mineral rich polyethylene core see that yes and thickness four millimeters finished quart zinc pre weathered did you draft that detail do
02:30:04 weathered did you draft that detail do you remember into this earlier version of the NBS specification that don't remember you don't remember well who else would it have been at this stage
02:30:16 else would it have been at this stage third we can never both if not you mr. reg might have been whoever was working on that specification before me oh I see say the are you saying that it's
02:30:30 say the are you saying that it's possible but don't speculate that this was already in the draft specification before you came to it to develop it from September onwards
02:30:41 I dunno when you came to develop the n-b-a specification did you look at this part of it under
02:30:55 did you look at this part of it under the crown paragraph 130 sure did you appreciate at that time and perhaps even this time 21st of November 2013 that it
02:31:07 this time 21st of November 2013 that it contained a reference to a mineral-rich PE core yeah I considered yes could you did it did it ring a bell with you at the time
02:31:26 I can't recollect do you do you have a recollection of what mineral-rich might have meant to you what are some sort of additive - yeah - the boy I think or
02:31:41 probably something to do with better fire performance right I don't know whether that's my assumption now or my knowledge now or what right I haven't
02:31:54 knowledge now or what right I haven't known assumption victim okay just to be clear do you have a recollection of yourself proposing that the crown should comprise a material which had a mineral
02:32:07 comprise a material which had a mineral rich in other words fire retardant core
02:32:13 if it was me typing in in I probably would have taken the wording word by word from the manufacturers website do you remember just building on that
02:32:25 you remember just building on that answer and I appreciate you said probably who would have suggested to you that in the crown you should be using a panel which had a mineral rich
02:32:36 panel which had a mineral rich polyethylene core or was it something you would have you came up with yourself
02:33:00 I mean if you can't know this right you can't remember and I do appreciate this is a long time again then you can't I
02:33:11 is a long time again then you can't I just want to explore what you do remember of that let's just have a look if we can very briefly this might trigger a recollection at inq zero zero
02:33:23 trigger a recollection at inq zero zero zero one one three four nine please that's zero zero zero one one three four nine this is the vmz composite product
02:33:34 nine this is the vmz composite product information which was available in the NBS plus section of the NBS database in november 2013 can I ask you please just to look in the
02:33:45 can I ask you please just to look in the first paragraph VM said composite is a multi-layered panel made up of two sheets of zinc that a half a millimeter thick and thermo glued on either side of a three millimeter thick mineral rich polyethylene core for optimum reaction
02:33:58 polyethylene core for optimum reaction to fire it is manufactured used using tested Alcoa architecture products technology and then it says in the third paragraph in the second sentence can be installed in
02:34:10 the second sentence can be installed in cassettes all riveted stroke screwed down sheets and then under advantages fifth bullet point down fire retardant core you see that yes does that trigger
02:34:23 core you see that yes does that trigger a recollection was that something that you saw at the time when preparing the NBS specification do you think it doesn't trigger okay now let's move all
02:34:35 doesn't trigger okay now let's move all in time a week or so and look at the next version of the NBS specification that's SE a zero zero zero zero zero one five three and I'd ask you to look at
02:34:50 five three and I'd ask you to look at page 66 please of that document sorry I should just be clear with you top of page two we see the date again from 29th of November 2013 looking at page 66 at
02:35:03 of November 2013 looking at page 66 at the bottom Clause 130 major non standard components crown and here we see this is now been changed
02:35:14 and here we see this is now been changed and is like the version we saw at the start the version of the 30th of January and if we now see it says manufacturer TBC product reference TBC material TBC
02:35:25 TBC product reference TBC material TBC finish TBC fixing etc now as I say we've looked at the third and final version of this document on in January 2014 at this plot this point Clause 130 and it's the
02:35:37 plot this point Clause 130 and it's the same my question is can you explain why the vmz product with the mineral-rich court appeared in the 21st of november
02:35:49 court appeared in the 21st of november 2013 version of the NBS specification under clause 130 but by the 29th of november 2013 the contents of clause 130
02:36:03 november 2013 the contents of clause 130 just said TBC for the crown and left the details blank
02:36:14 but I remember that design of the count went through many iterations of different proposals mainly based on
02:36:26 different proposals mainly based on looks we then select it in Proteus product for the main elements of the facade and I don't know whether we
02:36:37 facade and I don't know whether we considered Pateros not potentially be suitable for a crown and maybe didn't want to mix VM zinc product with the
02:36:49 want to mix VM zinc product with the Proteus and therefore left it to be confirmed because at the time we were
02:37:02 confirmed because at the time we were not sure how the crown was gonna look like but it's gonna be folded panels or just flat panels do you remember being
02:37:16 just flat panels do you remember being involved in any discussion within studio ii about changing the specification of vm zinc with the mineral-rich core for
02:37:27 vm zinc with the mineral-rich core for the crown to the blanks that we see in the 29th of november version i do not recall what I've just said is my assumption right off how Devon's
02:37:40 assumption right off how Devon's occurred right okay I'm not going to turn to a different topic which is cavity barriers and I get to ask you about the design of the cavity barriers in the in the facade that is something
02:37:52 in the in the facade that is something that you cover yourself in your witness statement at a section G mr. ray yeah from paragraph 30 onwards now can i page
02:38:03 from paragraph 30 onwards now can i page 30 onwards can I just ask you generally were you aware of the functional requirement b3 of the building regulations at the time you started the design for Grenfell tower
02:38:16 myself was aware of its existence right were you in particular aware of the guidance contained an approved document b at paragraph nine and diagram 33 about
02:38:27 b at paragraph nine and diagram 33 about cavity barriers took the section through the building I did yes okay well I would if you want you can
02:38:38 okay well I would if you want you can have we can have it up on the screen if you like but I think you you say you were okay now perhaps we ought to go to diagram 33
02:38:51 perhaps we ought to go to diagram 33 please that is at CLG
02:39:02 zerah zerah zerah zerah zerah two to four please and if we go if we go to page 83
02:39:18 well that certainly contains some of it
02:39:25 if you look the page I think it's on page 84 in fact no it's not it's a page
02:39:43 page 84 in fact no it's not it's a page 82 I'm so sorry where yes moving around if you go to page 82 you can see the diagram that we were referring to provisions for cavity barriers and
02:39:57 provisions for cavity barriers and starting at the top of the page the top of the diagram close top of cavity you see that yes and you can see that you're supposed to put a cavity barrier at the
02:40:09 supposed to put a cavity barrier at the top of cavity where it says close top of cavity yes yes is that what you understood at the time I would have seen this diagram I guess yeah do you think
02:40:22 this diagram I guess yeah do you think you actually looked at it at the time
02:40:30 OPA I can't recall if you also look down below clothes top of cavity at the compartment floor with the arrow there
02:40:42 compartment floor with the arrow there you could see that you're supposed to put a cavity barrier where it's indicated yes yes yes and then also closed around openings where the window is indicated yes I can see yes and if
02:40:54 is indicated yes I can see yes and if you go to paragraph nine point three which is on page 83 you can see that the guidance says you just turn the page cavity barriers should be provided to
02:41:05 cavity barriers should be provided to close the edges of cavities including around openings you see that yes and do you agree or did you think at the time that the guidance was sufficiently clear
02:41:17 that the guidance was sufficiently clear to you that you needed cavity barriers around openings as indicated on diagram 33
02:41:32 when I read it now that looks clear yeah when you read it if you read it at the time was it clear to you then I
02:41:43 don't recall reading or how much I read do you remember having the thought process at the time that Windows and
02:41:56 process at the time that Windows and specifically the windows in the cladding system at Grenville Tower would constitute openings in the external wall which would require cavity barriers
02:42:07 which would require cavity barriers around them
02:42:18 I don't recall my thought processes right
02:42:26 when you started your work on the design work at Grenfell on the ground fault our project do you remember thinking about whether you needed to put cavity
02:42:37 whether you needed to put cavity barriers around the windows in the proposed over cladding structure
02:42:56 don't like all right let me try two things then on approved document b well we've got it here can i ask you please to look at page 96 of this document
02:43:10 to look at page 96 of this document which is 12.8 of approved document b cavity barriers and it says if you just read with me cavity barriers should be provided in accordance with section 9
02:43:24 provided in accordance with section 9 and if you look at section I we've just looked at the start of it you plus we can get back to section 9 on page 83 [Applause]
02:43:35 [Applause] that's 9 3 perhaps get back one page 282 again which has got the diagram 33 on it looking at nine one concealed spaces or
02:43:46 looking at nine one concealed spaces or cavities in the construction of a building provide a ready route for smoke and flames spread this is particularly so in the case of voids in above and below the construction of a building for example walls floors ceilings and roots
02:43:59 example walls floors ceilings and roots as any spread is concealed it presents a greater danger than would a more obvious weakness in the fabric of the building was that a principle with which you were familiar at the time of your involvement
02:44:12 familiar at the time of your involvement on the design of the grant will tower over structure they've a cladding structure I don't know what a my familiarity coincided with the time
02:44:24 familiarity coincided with the time right in general terms would you agree that cavity barriers were required to prevent path of the fire within a cavity and also to inhibit fire spread into the
02:44:36 and also to inhibit fire spread into the cavity
02:44:42 whether that was my understanding back then yes exactly that's the question
02:44:51 I don't know was it part of your role to consider and update the drawings to show
02:45:02 consider and update the drawings to show the location of cavity barriers
02:45:11 yes what did you do to update the drawings to show the location of cavity barriers do you remember in general terms
02:45:28 so this apart which puzzles me because I think looted cavity barriers in line with the compartment walls and floors and I remember being told that they need
02:45:44 and I remember being told that they need to be certain fire resistance problem aside I remember who taught me right can
02:45:55 aside I remember who taught me right can he go to the page but let's look at let's look at mr. Sains his witness statement and he's already he's already put this into evidence so I can show
02:46:06 put this into evidence so I can show this to you this is se a zero zero zero one for 273 page 112 paragraph 267 and
02:46:16 this is his recollection I'm going to show you he says I have no recollection of how the judgment as to the placement of cavity barriers on the typical Bay drawing was arrived at you see that and
02:46:32 drawing was arrived at you see that and he says I note that cavity barriers who just go over the page I'm not shown on the draft typical Bay drawing dated 24th September 2013 which states provision of cavity barrier for a cavity fire barrier
02:46:44 cavity barrier for a cavity fire barrier TBC but they are present on the version dated 25th of September 2013 and then he goes on to say what he says and says in
02:46:58 goes on to say what he says and says in the last part of that last sentence I believe that the location of the cavity barriers must have been determined with specialist input that's his recollection now can I just show you what you say in
02:47:11 now can I just show you what you say in your statement if you go to paragraph 124 on page 30 as se a yes thank you under the heading cavity barriers at part G you say they're in the NBI
02:47:25 part G you say they're in the NBI specification we specified lama therm cavity barriers which were manufactured by down at cladding systems limited I do not recall how studio II sort these cavity barriers but my drawings show cavity barriers at the floor and party
02:47:37 cavity barriers at the floor and party walls I think I discussed cavity barriers with Harley that they may have been into
02:47:41 been into in our drawings before Harley and CDI we were in contact in autumn 2013 say that's your recollection
02:47:52 do you recall space are discussing cavity barriers with Harley where they should go around the windows no I don't
02:48:06 should go around the windows no I don't recall that so when you say I think I discussed cavity burrows with Harley wrong that they were under choice I send
02:48:18 wrong that they were under choice I send them right I see now if you go then to paragraph 125 you say I do not recall discussing
02:48:31 125 you say I do not recall discussing the fire performance of the cavity barriers and where they should be located
02:48:37 can you remember why you had to have a discussion at all with them instead of just reading and applying approved document b discussion with Harley of yes
02:48:48 document b discussion with Harley of yes or indeed with anybody
02:49:01 adil ooh how did I arrive to the need of investigating with someone else what sort of cavity barrier needed to go into the construction by if I discussed
02:49:13 into the construction by if I discussed it later at a meeting with Harley I think back then we would just bring it
02:49:25 think back then we would just bring it to their attention that there are some and then there's a difference between the vertical and the horizontal cavity barriers one of them touched the back of
02:49:36 barriers one of them touched the back of the brain skin cladding one of them don't I think but it's not my clear recollection and just to get back to the question before T do you recall having a
02:49:49 question before T do you recall having a discussion with Harley or indeed with anybody else about whether there should be cavity barriers around the window I'd
02:50:00 be cavity barriers around the window I'd done the corn grain floor project but I had a an experience after Grenville where discussion was held about fire
02:50:17 where discussion was held about fire cavity cavity barriers around windows and whether they'd be or shouldn't it was on that Bromley South Central okay can I ask you them to go to e^x zero
02:50:30 can I ask you them to go to e^x zero zero zero zero zero zero five eight six
02:50:41 this is an email from you to mr. Ashton on the 4th of November at the head of an email string and I just want to look at the bottom of page 1 of that email
02:50:55 the bottom of page 1 of that email string where you sent him an email on the 1st of November 2013 regretful drawings in progress evening Terry can you please confirm that the rain screen cavity barriers are
02:51:07 that the rain screen cavity barriers are to be 60 minutes FR to match the compartment ation you see that yes before you sent that email how do you checked approved document b i don't
02:51:23 checked approved document b i don't recall specifically see what i'm interested in is why you asked the question yeah was it was it not clear to you at the time that cavity barriers
02:51:34 you at the time that cavity barriers themselves only required 30 minutes fire resistance and 15 minutes integrity that would make sense yes it would make sense that I probably referred back to the
02:51:48 that I probably referred back to the approved document Batman I can't recall
02:51:53 there must have been a conflict between what I was advised which I don't know by whom it might have been actually now looking at it llama therm themselves giving me advice I I have no idea
02:52:06 giving me advice I I have no idea but there must have been a conflict since I approached Terry
02:52:14 a conflict between what do you remember between the fire systems requirement I was told these should have and another
02:52:25 was told these should have and another source which was telling me which might have been approved document that the fair assistance doesn't have to be at all I see okay we will may come we may come to unlock that conundrum in a
02:52:36 come to unlock that conundrum in a moment let me just see how we get on with that email there and he comes back to you on the 4th of November at 9:05 Thomas cavity barriers need only have a
02:52:48 Thomas cavity barriers need only have a 30 minute standard of fire resistance you see that yes and that is in fact what you ended up specifying in the end bet and BS specification wasn't it yes yes did you record that you had taken
02:53:02 yes did you record that you had taken advice from xover on this issue anywhere on the project file no and yeah this email came to my attention quite recently actually right do you know why
02:53:14 recently actually right do you know why you wouldn't have recorded on the project file the fact that you had taken specialist external advice from xover on this issue I don't recall exactly how did we file
02:53:30 I don't recall exactly how did we file emails but they might have been our mission in my side of filing this email right where would you normally file it
02:53:39 as I as I said I worked in other practices and every practice as a different filing system studio acres yeah yeah that's true where would you have filed it when you were at studio e
02:53:50 have filed it when you were at studio e where would you have filed this so that other people looking at the advice taken by this to do aid team would know what advice had been taken from external advisors but external team or internal
02:54:02 advisors but external team or internal team wouldn't still read I'd know should I understand the difference but if it was just I don't know where this Bruce copied in no no
02:54:15 I think it would be filed on a studio II server sir that email could be retrieved to later my question is a broader one I mean did deed studio he keep a project
02:54:26 mean did deed studio he keep a project file where you would specifically file this email so that anybody looking at it would know that studio he had taken expert advice from an external specialist any email concerned the
02:54:39 specialist any email concerned the project would be filed right now we can see your question about 60 minutes and you didn't ask mr. Ashton where cavity barriers should be located
02:54:50 barriers should be located did you suite as we can see and my question is why is that
02:55:09 I can assume I had a conversation with him over forum before I don't know right
02:55:20 do you remember you say I assume but I'm not necessarily putting to you that you ever did ask him I'm just asking why you didn't in this email do you remember as you sit there today actually having a
02:55:32 you sit there today actually having a conversation with mr. Ashton about where cavity barriers should go at this time don't recall and that's why this email came to me as a bit of a subtext all
02:55:43 came to me as a bit of a subtext all right
02:55:43 right can I ask you then to move on to paragraph 125 of your statement which is at page 30
02:55:57 you say there I do not recall discussing the fire performance of the cavity barriers and where they should be located and then you go on to say the
02:56:09 located and then you go on to say the name this is four lines down the name of the Lamb affirm product that we specified namely cwr sh-60 suggests that it has a 60 minute fire resistance RSV 60 but in the NBS specification we only
02:56:23 60 but in the NBS specification we only required 30 minutes fire resistance 30 30 two Bs for 76 part 20 1987 and BSA en 30 66 4 2006 I cannot explain the reason
02:56:34 30 66 4 2006 I cannot explain the reason for this discrepancy I do not recall discussing the fire resistance of cavity barriers with Harley the SEL key design team or anyone else that of course does not mean it didn't take place now um do
02:56:47 not mean it didn't take place now um do you remember whether a conscious decision was made to specify a cavity barrier product with a greater fire resistance than the minimum fire resistance given by approved document b
02:56:58 resistance given by approved document b do you remember that yeah I was acting on a on an advice from someone right did mr. well who told you or instructed
02:57:10 did mr. well who told you or instructed you to do that
02:57:15 to put cavity bearers in there at all yes would you say I was actually on advice from someone whose advice that's what I can't recall I mean I made a speculation maybe in my statement
02:57:26 speculation maybe in my statement somewhere it could have been built in control but I don't know what I was in contact with them right I I made a speculation could have been x over but now I'm thinking maybe it could
02:57:37 over but now I'm thinking maybe it could have been diminisher themselves yes I see okay now can I ask you to go to paragraph 126 of your statement just
02:57:52 paragraph 126 of your statement just below you refer there to a drawing of a typical bay window you see that and you
02:58:01 say it suggests cavity barriers at the window revealed you see that yes was it your intention when inputting into these
02:58:13 your intention when inputting into these drawings or updating them to include cavity barriers around the windows namely at the head the jamb and at the sill that I don't recall I mean this paragraph is an assumption of what I
02:58:29 paragraph is an assumption of what I supported but it's not based on specific recollection well let's see how we go with it with some specific goings can I just show you two versions of the
02:58:42 just show you two versions of the drawing you refer to in this paragraph
02:58:46 I'm going to show you first of all and we can have them up on the screen at the same time please that would be very will be very helpful I see a zero zero zero zero two one five five and also se a 0 0
02:59:00 zero two one five five and also se a 0 0 0 0 2 1 6 3 so 2 1 5 5 and 2 1 6 3 please now you can see but on the left
02:59:11 please now you can see but on the left hand side we've got 2 1 5 5 and the left hand and the right hand side 2 1 6 3 looking at 2 1 5 5 to start with on the left you could see that on the right hand side of that drawing which may have
02:59:23 hand side of that drawing which may have to be expanded it says cavity barrier TBC you see that yes just the second entry done and if you look at
02:59:36 the second entry done and if you look at the drawing on the right-hand side of the screen 263 we can see there that there is now a cavity barrier in line with the compartment floor mhm yes yes
02:59:49 with the compartment floor mhm yes yes yes so is it fair to say that the second drawing is a more advanced version of the first yes yes is it likely that you were the one who updated the drawing yes yes
03:00:00 yes okay did you discuss your work with anyone did you discuss that amendment or audition with anybody I believe we reviewed the drawings with Bruce
03:00:12 reviewed the drawings with Bruce whenever any material change has been done yeah I see and we can see that cavity barriers are labeled on the drawing and the one on the right hand
03:00:24 drawing and the one on the right hand side it says as we see in line with the compartment floor structure yes it does we can also see the one on the left hand drawings
03:00:39 we don't I think see any cavity barriers around the windows and again was there any discussion about that when these drawings were updated I've done recall
03:00:51 drawings were updated I've done recall discussions right now you say in your statement that there are you think there are also cavity barriers below the
03:01:03 are also cavity barriers below the window in the so-called spandrel I don't think we see that on the drawing do we it'll be under plan detail and on the
03:01:15 it'll be under plan detail and on the plan detail yes I see so say not the typical Bay then I thought the the whole drawing was called typical day but we're looking at this section all right so
03:01:27 looking at this section all right so let's pan out and perhaps look at that whole drawing it's on the screen I'm afraid in any typical Bay but we need to pan out and see the whole thing the trouble with that is that it becomes somewhat invisible but perhaps if we
03:01:38 somewhat invisible but perhaps if we look at 263 the one on the right mm have that alone up on the screen and have it in plan then we can see I think perhaps what you want to refer us to there can
03:01:49 what you want to refer us to there can you show us where you think there was a cavity barrier below the window in the so-called spandrel
03:02:06 sorry can you repeat the question yes could you can you identify and it's difficult because you don't have a pointer and Adeem order I know we're in on that drawing there was a cavity barrier below the window in the so
03:02:18 barrier below the window in the so called spandrel panel I would be referring to the detail number two proposed plan same level there would be
03:02:32 proposed plan same level there would be where the column cladding meets the flat clearing of the cell panel that that part where there's that little notch
03:02:43 part where there's that little notch it's fully filled with insulation or some some something it's not annotated I see but that would be a that would be a would that be a vertical panel a vertical cavity barrier as opposed to
03:02:55 vertical cavity barrier as opposed to horizontal cavity back yes I see
03:03:02 but I don't know what it I said all the intention was that to buy her a cavity barrier mr. chairman we're not gonna
03:03:18 barrier mr. chairman we're not gonna finish this topic before the break because there's a little bit more detail to go and I'm conscious of the time and he now may be a convenient moment for a break and we aren't just how much fun would you expect looking at my notes I don't think no
03:03:29 looking at my notes I don't think no more than another 40 minutes or so yes
03:03:40 more than another 40 minutes or so yes all right well we all have the right now mister recht will we'll break now so we can all get some lunch okay please remember not to talk about the your evidence or anything to relate it
03:03:52 your evidence or anything to relate it to it well I had hoped that you'd finish this morning but I'm afraid counsels still have a few more questions for us but to judge by what mr. minutes just said that's not too many right so could
03:04:05 said that's not too many right so could you leave us now and come back at 5:00 pass - thank you
03:04:20 five thoughts to