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First witness statement of: T Rek Filed on behalf of: Studio E Architects Limited Statement date: 9 November 2018 Exhibit no: TRl IN THE MATTER OF THE INQUIRIES ACT 2005 AND IN THE MATTER OF THE INQUIRY RULES 2006 THE GRENFELL TOWER INQUIRY FIRST WITNESS STATEMENT OF TOMAS REK ON BEHALF OF STUDIO E ARCHITECTS LIMITED I, Tomas Rek, formerly architect at Studio E LLP (dissolved), WILL SAY AS FOLLOWS: 1. This witness statement is divided into the following areas: Tomas REK A Introduction B My experience and qualifications C Overview of my work on the Project D Rainscreen cladding E Fire strategy report F Windows, smoke vent and kitchen extract G Cavity barriers H Building Research Establishment Environmental Assessment Method (BREEAM) I Insulation - 1 - SEA00014278_0001 SEA00014278/1
Transcript
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First witness statement of: T Rek Filed on behalf of: Studio E Architects Limited

Statement date: 9 November 2018 Exhibit no: TRl

IN THE MATTER OF THE INQUIRIES ACT 2005

AND IN THE MATTER OF THE INQUIRY RULES 2006

THE GRENFELL TOWER INQUIRY

FIRST WITNESS STATEMENT OF TOMAS REK ON BEHALF OF STUDIO E ARCHITECTS LIMITED

I, Tomas Rek, formerly architect at Studio E LLP (dissolved), WILL SAY AS FOLLOWS:

1. This witness statement is divided into the following areas:

Tomas REK

A Introduction

B My experience and qualifications

C Overview of my work on the Project

D Rainscreen cladding

E Fire strategy report

F Windows, smoke vent and kitchen extract

G Cavity barriers

H Building Research Establishment Environmental Assessment

Method (BREEAM) I Insulation

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A INTRODUCTION

2. I am currently an architect at Vilhelm Lauritzen Arkitekter A/S, Pakhus 48, Sundkaj

9, l.tv. Copenhagen, Denmark (VLA). I have provided this information for

completeness only, as to the best of my knowledge VLA has absolutely nothing to do

with the refurbishment of Grenfell Tower (the Tower) in London between 2011 and

2016 (the Project) or the circumstances surrounding the fire at the Tower on 14 June

2017 (the Fire).

3. This is the first witness statement that I have made to the Grenfell Tower Inquiry (the

Inquiry). I understand I was asked to make it by the Inquiry, in its request for

evidence from Studio E Architects Ltd (SEAL) under rule 9 of the Inquiry Rules 2006

dated 5 June 2018 (the Request). I have not seen the Request itself

4. During my work on the Project, I was not an employee of SEAL. I was an architect at

Studio E LLP (SELLP) between December 2011 and December 2013, when I was

made redundant. I understand that in summer 2014, which was after I left SELLP,

SELLP entered insolvency and its work on the Project was continued by SEAL.

5. I have been provided copies of a selection of SEAL's contemporaneous documents,

including the emails that I sent and received that SEAL has disclosed to the Inquiry.

In this witness statement, I refer to various documents primarily in two ways. Where I

understand the document will be made available on the Inquiry's electronic platform, I

have referred to it by its "Unique ID" on the platform, in bold curled brackets in the

format {XXXOOOOOOOO}. For other documents, I have annexed them at exhibit TRI.

References to pages in this exhibit are given in bold curled brackets, in the format

{TR1/pagenumbers}. In the preparation of this witness statement, including annexed

documents, I have been assisted by SEAL's solicitors.

6. English is not my first language, however I confirm that I am confident making this

statement in English.

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B EXPERIENCE AND QUALIFICATIONS

7. I obtained a degree in architecture from the University of Technology, Brno, The

Czech Republic, in 2005 and qualified as an engineer architect in architecture and

urban planning. I have practiced as an architect for 8 years.

8. During my time at SELLP, I was a project architect. An example of the sort of

projects I worked on was a school project, known as Ormiston Bolingbroke Academy.

That concerned a predominantly render and brick building with Metsec walls.

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C OVERVIEW OF MY WORK ON THE PROJECT

9. I worked on the Project for a short period of time, for about three months, between

September 2013 and December 2013. I recall visiting the Tower during my time

working on the Project, and note for the purpose of this witness statement that it was

essentially divided into two parts, a lower podium of four floors including a nursery

and boxing club, which was being reconfigured as part of the Project (the Podium)

and an upper 20 floors of existing residential flats (the Existing Floors).

10. I was available to work on the Project as the project I was previously working on had

been completed and handed over. I believe SELLP appreciated my work and wanted

to keep me on should another project come up, so I could work on that. In that sense,

my involvement in the Project was for me, to my understanding, filling the gap until

another project came up. I reported to Bruce Sounes at SELLP. Bruce was my

supervisor at SELLP.

11. During this time I assisted with the preparation of SELLP's NBS Specification

{SEA00000169} (the NBS Specification) and architectural drawings for the Project.

The NBS (National Building Specification) is a standardised system of specification

published by the Royal Institute of British Architects (RIBA). It is used by designers

to describe the materials, standards and workmanship that the client requires and it

forms part of the tender documents along with the architectural drawings for the

building contractor to price the Employer's Requirements. It then usually forms part of

the building contract.

12. I was first briefed on the Project on 18 September 2013 by Garry Stewart, as Bruce

Sounes had been called into meetings that day, and I started by reading the Stage D

documents and reviewing the draft drawings and sketches {SEA00008470}. The

design was at the pre-tender stage and the drawings and documents had been

developed up to RIBA stageD (Design Development).

13. In addition, Bruce introduced me to the Project and relayed further information about

it to me as and when required. For example, when I started on the Project in

September 2013, I remember Bruce briefing me on how the fa<;ade would look and

that the planning authorities would prefer a zinc cladding scheme over a colourful

cladding scheme which used High Pressure Laminate (HPL) cladding.

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14. I was tasked by Bruce with developing the NBS Specification and drawings further so

that the NBS Specification, architectural drawings and the tender documents could be

completed and issued as part of the pack of documents for tenderers. Usually, the

successful tenderer (or specialist subcontractor for the successful tenderer) would use

these documents as a starting point for their further detailed design development.

15. In this witness statement I explain, by reference to my contemporaneous email

correspondence, how I assisted in sourcing and specifying some of the materials in the

NBS Specification from various manufacturers and suppliers; in particular:

15 .1.1 The rainscreen cladding;

15 .1.2 Cavity barriers;

15 .1. 3 Smoke vents; and

15 .1.4 Windows.

16. Some of the materials and products had been selected prior to my involvement, and I

would add that this was a team effort, rather than me making decisions individually.

Smoke detectors, for example, would have been specified by a specialist engineer, and

the thermal insulation was specified prior to my involvement, as discussed in further

detail below.

17. At the time of my involvement I recall that the internal SELLP team consisted of

Bruce and me. Another employee at SELLP, Paddy Glennon, who had been working

on the Project, was involved only in returning matters that he had been involved with

prior to my involvement.

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D RAINSCREEN CLADDING

18. In the NBS Specification, Studio E specified Proteus HR honeycomb ramscreen

panels for the columns and external envelope of the main entrance canopy, and for the

spandrel panels. I understood from Bruce that the client, KCTMO, wanted to include

options in the tender for Aluminium Composite Material (ACM) cladding, so we also

required tenderers to provide for alternative ACM materials (Reynobond, Alucobond

and Quartz Zinc) (see from {SEA00000169 _ 0063} ).

19. My recollection is that the Proteus HR cladding panels were the most expensive

cladding option we looked at. I remember that the focus at the time was on the

stiffness and robustness of the cladding panels and the avoidance of oil-canning

(moderate deformation or buckling of sheet material, particularly common with flat

sheet metal surfaces - it is seen as waviness in the flat areas of the metal roof or wall

material) on the pillars, which is why we deemed single sheet interlocking zinc panels

inappropriate for the Project. I set out the materials I was involved in considering

below.

20. On 24 September 2013 Bruce Sounes (Studio E) emailed me a list of actions on the

Project that he wanted me to follow up, which included obtaining samples of a zinc

fa<;ade cladding material he referred to as "Nedzinc" and issuing drawings to, and

meeting with, two specialist curtain walling contractors, Paneltec Services Limited

(Paneltec) and Harley Curtain Wall Limited (Barley) {SEA00008637}.

21. The same day, I spoke with Paul Cousins, the Business Development Manager at SIG

Roofing Supplies Limited (SIG), a specialist distributor of roofing and cladding

related products. SIG is a supplier of hard metal products for roof and fa<;ade cladding

such as the NedZink proprietary range of zinc cladding. I had no previous dealings

with Paul or SIG, and recall that either Bruce mentioned SIG to me, or I found them

as a result of a "Google" search.

22. Following that initial conversation, I emailed Paul Cousins (SIG) and confirmed that

we were looking at using titanium zinc fa<;ade cladding, and that I would therefore

like to see some samples of SIG's products, specifically NedZink Naturel, NedZink

NOVA and NedZink NOVA STRUCTURE. I asked him to send me samples of these

Tomas REK -6-

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products {SEA00008644}. My email states I attached two drawings to my email to

Paul:

22.1 A drawing showing the elevation measures for the Tower, called "SK 019" (I

believe it may have been either this drawing or similar {SEA00001578}); and

22.2 A drawing showing the plan, elevation and section of a typical bay of cladding

on the east and west elevations, showing draft details of the rainscreen

cladding to the cills of the ribbon windows and to the pillars (the Typical Bay

Drawing) (I believe it may have been either this drawing or similar

{SEA00002155}).

23. The following day, 25 September 2013, I sent a newer version of the Typical Bay

Drawing that I had prepared to another cladding specialist, Paneltec, and I asked it

about its rainscreen cladding products {SEA00008683}. In addition to some minor

changes the drawing included the addition of cavity fire barriers in line with the

compartment structures. A colleague of mine at SELLP, Paddy Glennon, had already

had a meeting with Paneltec the previous week and he had provided them with draft

elevation drawings and details showing windows and cladding, wind load calculations

and U-value targets.

24. On or about 26 September 2013, I had a meeting with Paul Cousins (SIG) about SIG's

cladding products. I do not recall the details of our conversation and I do not believe I

took a written note of the meeting. However, on 27 September 2013 I sent Paul a brief

email summarising the matters that we had discussed at the meeting as follows:

Tomas REK

"Current detail design?

1 am looking forward to receive your advice on feasibility of our detailing

depicted on the Typical Bay drawing we supplied

Visual appearance?

Can you please advise on the most appropriate product for this job bearing in

mind that for us there is no issue with oil canning effect especially on the

spandrel panels between the window strips. The column cladding may actually

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look better if it is of crispier appearance and therefore some sort of backing I

stiffening to the panel might be appropriate.

Fixing system?

How would a hook-on cassette system (speedy installation vs. expensive

fabrication) compete in practicality/ affordability with interlocking (secret fix)

screw-fixed panels?

Panel material?

How severe the oil canning would be on the currently designed under-window

panel size if we were to use 1.5mm single sheet ofTiZn?

Can you please send us a bigger sample of the NOVA COMPOS1TE panel?

The colour/ texture on the 'bendy' sample you gave me seems lighter/

smoother than the flat prepatinated sample which seems to have rougher

texture. Does the NOVA finish come in two different 'styles', one slightly more

polished than the other?

1 am also curious about price comparison between your Polyethylene based

composite vs. KME 's aluminium honeycomb mesh based one! As discussed

you will be getting some design feedback from KME and their quotation."

{SEA00008806}

25. Regarding polyethylene based composite panels:

25.1 From what I can recall, polyethylene core composite panels had already been

considered for the cladding for the Project before my involvement on the

Project and I do not think my enquiry about these types of panel was the first

time that they were considered. For example, polyethylene core composite

panels appear in drawings that were prepared before I became involved in the

Project, for example, Studio E's drawing RE 140 dated 11 September 2012

{SEA00001586} and SK085 dated 17 September 2013 {SEA00002135} both

show the cladding annotated as "composite zinc".

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25.2 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 cores or whether 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 I had simply been asked to obtain samples of these

materials and the focus appeared to be on the appearance and cost of the

product.

25.3 In any case, I note that the NBS Specification contained certain fire

performance requirements for the rainscreen cladding {SEA00000169 _ 0071},

including that:

(i) The fire resistance of the backing wall of the rainscreen cladding to

achieve BS476-21, and a minimum period of fire resistance of 60

minutes (clause H92/480);

(ii) The internal surface spread of flame of the backing wall to BS476-7

was to achieve fire rating Class 0 (clause H92/485); and

(iii) The cavity fire barriers in the rainscreen cladding were to resist the

passage of flame and smoke for not less than 30 minutes (clause

H92/490).

25.4 Furthermore, Studio E included the standard NBS design and performance

specification for rainscreen cladding at clause H92/310 of the NBS

Specification {SEA00000169 _ 0069}, which required the building contractor to

comply with the "CWCT Standard for Systemised Building Envelopes", among

other criteria, including Part 6, which related to fire performance.

26. On 27 September 2013 I attended a meeting with Bruce Sounes (Studio E), Mark

Harris (Commercial Manager at Harley) and Ray Bailey (Managing Director of

Harley), at a coffee shop or restaurant at Hays Galleria near London Bridge station,

which Bruce had arranged to discuss the cladding specification {SEA00008685}.

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27. In preparation for the meeting, I sent Mark Harris (Harley) {SEA00008692} copies of

our scope elevation drawings series (05), a draft proposal of the design intent for the

cladding of a typical bay {SEA00002163}, wind load calculations, and an excerpt

from the mechanical and electrical engineer's report specifying targeted U values

{SEA00002096}.

28. The extract was from Part 4 of Max Fordham LLP's (Max Fordham) "Sustainability

and Energy Statement report" dated 5 September 2012, titled "Refurbishment

response to existing energy and environmental issues", which contained proposed U­

values for the Tower. The extract states that improving the insulation levels of the

walls was the "top priority of this refurbishment" and the "chosen strategy is to wrap

the building in a thick layer of insulation and then over-clad with a rain screen to

protect the insulation from the weather and from physical damage". In tables 4.2 and

4.3 in the report, Max Fordham listed the build-ups of the proposed spandrel wall

panels and columns, and stated that the spandrel wall panels and columns would be

covered with 3mm thick "Zink" rainscreen cladding, the spandrel wall panels would

be covered with 150mm thick Celotex FR5000 insulation, and the columns would be

covered with 1 OOmm thick Celotex FR5000 insulation.

29. I cannot recall the details of the discussion and I did not take a note of the meeting. If

I received any hard copy material at the meeting it is probably lost. I cannot recall

whether or not we discussed the suitability of PIR (polyisocyanurate) or rigid foam

insulation.

30. As I have stated above, I cannot recall discussing the fire rating or fire performance of

any of the cladding panels that I investigated and sourced from suppliers and

manufacturers while I worked on the Project. However, I have reviewed my email

correspondence at the time and it is clear that we must have discussed the different

types of cladding at the meeting with Harley; although I think it was more to do with

the appearance and price of the various materials and not their fire performance or fire

rating.

31. After the meeting, Bruce Sounes (Studio E) sent an email to Mark Harris (Harley) and

said:

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"We will follow up early next week with a quantity take-off from our model.

I've communicated your "back of a fag packet" figure to the QS and it is over

budget- which is to be expected- but some firmer budgets will help focus

everyone 's minds. We 're looking seriously at Nedzinc 's composite panel. The

small sample we have in the office looks like Alucobond but is apparently

zinc." {SEA00008809}

32. The next day, on 28 September 2018, Mark Harris (Harley) copied me into his email

reply to Bruce Sounes (Studio E):

"I have already started putting a budget cost spreadsheet together, and will

insert the quants from your measure as soon as received, and will return along

with our notes and observations." {SEA00008811}

33. On 9 October 2013 I received an email from Paul Cousins (SIG) saying he had spoken

to KME Architectural, which I believed was a supplier of this type of panel, about the

Proteus HR cladding panel {SEA00009019} and he believed that it was the most

suitable for this application as this panel construction would offer a very high level of

flatness and stability. Paul told me there were two other options: NedZink NOVA

Composite and Interlocking panels. He said a wind loading study would however

have to be carried out to confirm suitability of these panels, but he believed the

Interlocking panel would not provide the flatness required. Paul also told me he could

only provide me with 'supply only' prices for the panels and that I would have to

obtain an installed price from a specialist fa<;ade contractor.

34. Paul Cousins (SIG) provided me with prices for three types of cladding (although they

would vary depending on the external finish and detail levels):

Proteus HR NedZink Panel

NedZink NOVA Composite

NedZink Interlocking Panel

£130-180/m2;

£90-150/m2; and

£70-120/m2.

35. Paul Cousins (SIG) attached to his email an axonometric drawing of the panel

showing the construction method for the panel featuring the NedZink product (which

may have been these drawings: {SEA00001981} {SEA00001982}).

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36. On 9 October 2013, I emailed Paul and told him that I would discuss his feedback

with the SELLP design team {SEA00009019}. I also asked him whether the sample

made of the composite sheets had been dispatched and how big it was, to confirm that

the detailing depicted on the drawings that I had sent him was appropriate for both

single 1.5mm sheets and composite material, and whether, in principle, the fixing

method, bending radiuses, etc. were appropriate. I asked him about the visual

appearance of the interlocking panels and whether he had a photograph of an

installation where interlocking panels had been used of a similar size under window

panels (900x1150mm), as we would like to judge the severity of oil canning in this

size when 1.5mm thick sheets were used.

37. I also asked Paul Cousins (SIG) what experience he had had with cassette systems,

('speedy installation vs. expensive fabrication') compared with interlocking systems

('secret fix') screw-fixed panels which are easier to fabricate but more laborious to

install. I asked him which one, in his opinion, turned out to be more economic

{SEA00009019}.

38. I do not believe that Paul Cousins (SIG) was considering or commenting on the fire

rating or fire performance of the Proteus HR panel, or whether or not it was suitable to

use above 18m, when he told me, on 9 October 2013, that he believed that the Proteus

HR Panel was the most suitable for this application {SEA00009240}. I imagine that

his concern at the time was whether the panel was flat and rigid enough. I think Paul

wanted to avoid, as a supplier, negotiations with us, the architect, and I or the client on

the level of acceptable 'oil canning' effect, as this could be rather subjective and

contentious.

39. On 15 October 2013, Paul Cousins (SIG) contacted me concerning the samples of

cladding material that I had requested from him {SEA00009240}. He apologised for

the delay in coming back to me and said the sample of the Proteus HR cladding

material that I had requested would be with me towards the end of the week (i.e. by

Friday, 18 October 2013). However, he told me that no samples of the NedZink Nova

Composite panels were currently available as they were waiting for a new batch to

arrive from Holland. He said SIG had samples of the NedZink Interlocking panels in

l.OOmm only and that they were approximately 600x600mm in size. He said SIG

could manufacture panels from thicker material but this could not be profiled and had

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to be brake pressed which would increase the costs from approximately £45Im2 to

approximately £65Im2 for the supply of the panel only. He said a thicker material

would decrease the 'oil canning' effect but the additional 50% material cost would

reduce the cost effectiveness. He said he would organise images of the l.OOmm panels

to be forwarded to me under separate cover {SEA00009144}.

40. In his email to me, Paul Cousins (SIG) said:

"In theory you can use all three products, subject to wind loadings, this would

have to be established by a suitably qualified engineer".

41. Paul said the speed of installation was in direct relation to the panel size, "the larger

the panel the quicker the installation".

42. I forwarded Paul's email to Bruce Sounes (Studio E) {SEA00009144} and commented

that "1 had always understood that we would be getting the polymer-core composite

sample panel-but below states that we are getting the most expensive one ... "

43. I asked Bruce Sounes (Studio E) whether I should ask Paul Cousins (SIG) when

polymer-core composite sample panels would be available. Although I have no

recollection of the details, we likely had a verbal discussion about it.

44. Again, I do not recall any discussion regarding the fire rating or fire performance of

polymer-core composite cladding panels or any discussion regarding any potential fire

safety issues that might arise from the use of such a panel.

45. I also do not recall whether the NedZink Composite product's reaction to fire was

discussed.

46. I thought Paul Cousins (SIG) was trying to put forward a more expensive cladding

option (perhaps the oil-canning-safe Proteus HR instead of the NedZink NOVA

Composite) so I emailed him {SEA00009240} and said:

Tomas REK

"Strange, I always thought we talked about the Nova Composite sample panel,

as this is the one we would like to pursue the most. A lot based on

affordability. Can you please advise when you would be able to supply a

sample panel made of Nova Composite sheet?"

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47. On 18 October 2015, I emailed Paul again and asked him to provide a quotation for

the supply of the Zinc NOVA Composite panels "in line with our design intent

drawings issued previously" {SEA00009240}.

48. I added that:

"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 -

Arrange for a sample of the NO V A Composite sheet? A 4 size as minimum for

the beginning although full under window spandrel size panel with returns will

be preferable in near future. Please let me know if I should give call to

Netherlands and ask for A 4 size sample to be put in the envelope. We need it

asap as a tool for negotiations. - Ask KME about the honeycomb sample

arrival. Though as it seems at the moment the cost of this product might

prohibit it from being specified" {SEA00009240}

49. I am not able to recall the details behind this correspondence but I think that I

requested the sample primarily for aesthetic reasons since the email correspondence at

the time was about the appropriate size of the sample.

50. On 22 October 2013 I received a telephone call from a person promoting a

honeycomb composite cladding panel solution. This person, who I later found out,

was Simon Walker, a director at SIG, said Paul Cousins had asked him to

communicate with me directly.

51. I contacted Paul Cousins (SIG) by em ail on 23 October 2013 (picking up on my em ail

to Paul of 18 October 2013, which I understand Paul sent to Simon that day), and

asked him to advise me about this person and give me his details. I also asked Paul to

check whether he had received my request for more information and whether

somebody was looking into the Nova Composite solution {SEA00009352}.

52. On 24 October 2013 I had a telephone conversation with Simon Walker (SIG) and I

sent him an emaillater the same day {SEA00009414} in which I provided him with a

brief summary of the points that we had discussed, including:

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"(new) NOVA composite sample was unavailable due to NedZink's decision

not to produce new panels before current (old) NOVA panels were out of

stock.

KME 's sample panel should arrive in w le 28 October 2013

Simon expressed concerns about the stability of interlocking panels (Jmm

thick single sheet) at the heights (66m tall building)";

53. I asked Simon to consider surface fixed NOVA Composite panels for cost and

structural suitability reasons; and whether we should abandon the interlocking panel

idea {SEA00009414}.

54. I attached to my email the information that he had requested, namely wind loads and

an updated detail design intent for the rainscreen 1279 _SEA _(06) 110 _Typical Bay­

DRAFT 131024 {SEA00002323}.

55. I told Simon that in the latest cost plan I had included a full ramscreen (incl.

insulation) supply and install figure of £835,900.00, which was arrived at by applying

a rate of £260 to 3,215m2, and I asked him to advise on the costs for the whole job

{SEA00009414}.

56. Simon had suggested a different width Proteus panel (15mm instead of 25mm) and I

told him I would be interested to hear about this panel, subject to the budget

allowance stated above {SEA00009414}.

57. I also confirmed to Simon that I had received from Paul Cousins (SIG) a sample of a

new weathered zinc sheet (llOxllOmm) as part of the 'big brochure'. I said this

looked a bit duller and more textured than the (old) NOVA Composite sample but it

would still be visually acceptable. I asked him whether he could supply a bigger

sample, say A4 size {SEA00009414}.

58. On 25 October 2013 I emailed Simon Walker at SIG, and copied in Mark Harris

(Harley). I told him that we were liaising with Mark Harris at Harley regarding

rainscreen cladding, and that they were envelope installers. I gave Simon Mark's

contact details and I told him that Mark was putting together a quote for the whole

envelope element of the Project (including windows, curtain, wall, etc.) and that he

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would like to ''precise their quote" (by which I think he meant 'refine') based on SIG's

rates. I asked him to copy Mark into his response {SEA00009435}.

59. Simon Walker at SIG responded, copying in Mark Harris (Harley) and Matthew

Irving at KME Architectural. Simon said Matthew Irving had made contact with Mark

Harris and would provide budgets to Harley the following week for the rainscreen

cladding {SEA00009437}.

60. On 1 November 2013 I emailed Bruce Sounes (Studio E) the information that I had

obtained from another cladding specialist CGL Facades regarding the impact results

for the proposed cladding for the base of the Tower {SEA00009567}. The information

concerned zinc panels, not aluminium panels, which was what we were at the time

considering using for the proposal for the Podium. {SEA00009567}.

61. On 4 November 2013 I emailed the sales department ofBCM GRC Limited, which is

a leading supplier of high grade Glass fibre Reinforced Concrete (GRC), and sought

its advice on the feasibility of using GRC cladding for 14 lower level columns, up to

2x2600mm in height (i.e. ground to first floor) {SEA00009636}.

62. On 4 November 2013 I also emailed Mark Harris at Harley and asked him whether he

had had any luck contacting Matthew Irving at KME Architectural regarding budgets

for rainscreen cladding {SEA00009648}. Mark said he hadn't.

63. I therefore emailed Bruce Sounes (Studio E) and told him that, "as you said", Harley

had confirmed that they could not get hold of KME Architectural who did not appear

to want the business {SEA00009658}.

64. On 7 November 2013 Mark Harris (Harley) emailed me, copying in Ray Bailey and

Mike Albiston at Harley, and Bruce Sounes (Studio E), and he said:

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"A re:-,ponse has been received at last from KMH, although I'm not sure it tells

us a great deal. All that has been provided is a base m2 rate for panel only, ex­

works. That must have taken all of I 0 minutes to think about, so quite why it's

taken them 2 weeks to provide it, is a mystery to me! All I have been able to do

with this extremely limited information, is take a best guess at wastage,

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transport, and support rail costs (in additional to design, installation etc.), and

input into our spreadsheet to give an end figure, on the wall. The result was:

Proteus HR Composite - £282m2.

Quite what finish this is based on, I have no idea (due to lack of information). I

have to say, from a Harley selfish point of view, our preference would be to

use AC'M It's tried & 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 build in the material of choice." {SEA00009736}

65. As I have already said, I do not recall any discussion about the fire rating or fire

performance of the different types of cladding, or the cores or the use of ACM

cladding specifically, or having any discussion about whether they complied with

Building Regulations. I do, however, seem to recall that Harley had mentioned

another high-rise tower project that they had carried out at a development called

Ferrier Point in Canning Town, at which they had used ACM cladding. ACM

cladding was widely used in the industry at the time (i.e. in 2013), and my

understanding was that architects, and the building industry more generally, appeared

to be content with its suitability for buildings over 18m in height.

66. Later that same day, 7 November 2013, Bruce Sounes (Studio E) told Mark Harris

(Harley) that we shared his concerns about the reliability of KME Architectural as a

supplier but "we set out to do zinc and budget permitting it will be a fantastic result".

Bruce, however, said we were "challenged to achieve a 'natural' non-coated cladding

look" and he asked Mark about various different types of cladding and how they

would affect costs {SEA00009764}.

67. Bruce told Mark that our client "is going to want to include options in the tender for

ACM', but that "the standard finish [of ACM] is unfortunate". Bruce said a planner

had told him that the ACM that had been used on a building in Croydon looked like

plastic. Bruce asked Mark to provide rates in his spreadsheet for various different

types of ACM finishes {SEA00009764}:

"(Reynobond- I 'm assuming Duragloss 5 000)

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o Metallic std & non-std (Satin gloss)

o Brushed aluminium

o Chameleon

o Anodised Look

( Alucobond)

o Spectra, Sakura 917.

We needn 't consider concealed fixings. More important is achieving the shadow gaps we've detailed

VMQUARTZ KME

EASURE: RATE: VMQUARTZ RATE TOTAL 266 £105.00 £27,930 0 omitted

316 £296.00 £93,536 282 £89,112

1822 £315 £573,930 282 £513,804

832 £160 £133,120 160 £133,120

2367 £425 £1,005,975 425 £1,005,975

968 £390 £377,520 390 £377,520

2144 £315 £675,360 282 £604,608

64 £200 £12,800 200 £12,800

8500 £30 £255,000 30 £255,000

NIA NIA £95,000 £95,000

£3,250,171 £3,086,939

68. These ACM materials, together with Quartz Lime composite polyethylene panels

manufactured by VM Zinc, were included in the NBS Specification as alternative

materials in addition to the Proteus HR panels that were specified in clauses 120 and

123 of the NBS Specification.

69. I do not recall us discussing the Reynobond and Alucobond products, or which type of

ACM core we should use (i.e. polyethylene (PE), Fire Resistant (FR) or A2 (i.e. a

non-combustible core) while I worked on the Project. We included Reynobond and

Alucobond as alternative cladding materials in the 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 at paragraph 67 above.

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70. I understand from Bruce that our client, KCTMO, wanted to see a comparison with

potentially cheaper ACMs. Mark Harris (Harley) responded that he would contact

Reynobond and Alucobond and obtain rates for the colour choices that Bruce had

selected {SEA00009776}.

71. I received a sample of the Proteus HR panel from Matthew Irving at KME

Architectural, who, according to his email signoff, worked in partnership with

Proteus, in or about 11 November 2013 {SEA00009837}. I don't think I ever actually

met Matthew Irving and I think he merely sent me a sample of the Proteus HR panel

in the post. I remember seeing a physical sample of the Proteus HR panel and I think

this must have been the sample that I received from Matthew.

72. On 15 November 2013 I forwarded Bruce Sounes (Studio E) a copy of the email

correspondence that I had had with BCM GRC Limited regarding the cladding for the

bottom part of the existing reinforced concrete columns using GRC. {SEA00009943}

and he asked me to obtain samples of GRC cladding {SEA00009953}.

73. On 21 November 2013 I forwarded Bruce Sounes (Studio E) the email

correspondence that I had had with Mark Harris at Harley regarding the robustness of

cladding panels and fixing methods and I told him that "I guess this would be further

developed with the contractor later when preferred material is chosen"

{SEA00009996}.

74. In November 2013 I was aware of the looming deadline for the finalisation and issue

of the tender documents which we were preparing and I wanted to get agreement from

Harley that the level of detail currently shown in the design intent was sufficient for

the tender submission.

75. The building contract for the Project was going to be a design and build contract so

there was always a possibility that the building contractor would choose a different

cladding product to the Proteus HR material that we specified for the rainscreen

cladding and the contractor may have decided to use one of the alternative materials

(i.e. Reynobond or Alucobond). I thought that the building contractor was ultimately

responsible for the development of the detailed design and we I SELLP would then

have been able to comment on the building contractor's design proposals.

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E FIRE STRATEGY REPORT

76. I was not copied into this email (although I was later copied into the chain), but I note

that on 15 October 2013, Bruce Sounes (Studio E) copied, the fire engineer, Terry

Ashton (Exova) into an email attaching Studio E's latest drawings for the floor plans

of the Podium and asked him if he had any comments on them {SEA00009134}.

77. Part of the fire strategy for the Podium included a smoke ventilation system using

automatic opening vents (AOVs). I understand this was separate to the smoke

ventilation system for the Existing Floors, as set out in Exova's Outline Fire Safety

Strategy. Studio E's drawings {SEA00002497} and {SEA00002603} show the logic of

the AOV ventilation for the Podium, and the location of the four AOV vents it

required, as during the period I was working on the Project.

78. We specified those four AOVs at clause 691 of the NBS Specification, titled

"Automated Opening Vents for Hot Smoke Release" {SEA00000169_0148}. I

understand Bruce Sounes (Studio E) was liaising with Terry Ashton (Exova)

regarding the AOVs, and I also contacted him with some queries as part of our

product investigations:

78.1 On 22 October 2013, I asked Terry Ashton whether the AOVs were required

to discharge hot or cold smoke- he replied either {SEA00009436}; and

78.2 On 25 October 2013, I asked Terry Ashton how the free area requirement for

AOVs should be measured- he replied "compliance with ADB would suffice,

in my view" {SEA00000130}.

79. On 5 November 2013 Bruce Sounes (Studio E) emailed me and asked me to follow up

with Terry at Exova a query which he had raised with him regarding the fire strategy

drawings.

80. Terry emailed me the amended draft fire strategy report with changes highlighted and

with annotated copies of the drawings with fire ratings colour coded {SEA00000134},

{SEA00000135}, {TRl/1} and {TRl/2}.

81. Bruce Sounes (Studio E) provided Terry Ashton (Exova) with his comments on

Exova's fire strategy and pointed out that there were some discrepancies on travel

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distances. Bruce also pointed out to Terry that he needed his final run through on the

fire strategy drawings. Bruce told Terry that time was running out and we needed to

finalise the fire strategy within a week {SEA00009716}.

82. Terry responded that he was amending the fire strategy report "to marry up with the

fire strategy drawings that you attached to your email" and he needed clarification on

two points in order to be able to complete this task:

82.1.1 "Are the drawings the latest ones?; and

82.1.2 Are the apartments at mezzanine level new or existing apartments?"

{SEA00000133}.

83. I emailed Terry Ashton (Exova) copies of the latest drawings and confirmed that the

apartments at mezzanine level were new. I also confirmed that the nursery resided

there now {SEA00009716}.

84. Terry queried the information which I had sent him ("The drawings are significantly

different to the ones Bruce sent me earlier today but I assume these are the correct

ones!") and I confirmed that the drawings had been discussed and submitted to RBKC

Building Control on 25 October 2013 {SEA00009682}.

85. Also on 5 November 2013 Terry Ashton (Exova) sent the revised fire strategy report

and annotated copies of the drawings with the necessary fire ratings. Later that day, 5

November, Bruce sent Terry further comments on the fire strategy, in particular

including comments on the separating wall and AOV {SEA00009716}.

86. On 6 November 2013 Terry Ashton (Exova) responded with further comments,

including on the AOVs. On the same day I also provided Terry with my comments on

his fire strategy proposal and said:

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"Thank you for the revised proposal. We prefer this one. Can you please

advise:- Whether steel structure supporting the gallery connecting the Boxing

club stair and the existing lift lobbies on Mezzanine and Walkway level need

fire protection. And if yes, then how many minutes. - Can the door connecting

the Community meeting room and the Boxing Club stair be retained when the

meeting room has AOV's and the door is fire rated? -Does the ground floor

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office corridor need to be smoke ventilated? Or an AOV for the stair only

would suffice?" {SEA00009716}

87. Terry responded to my queries on the 7th November 2013 {SEA00000143}.

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F WINDOWS, SMOKE VENT AND KITCHEN EXTRACT

88. I also assisted with the sourcing of materials and the preparation of the NBS

Specification and drawings for windows. I also obtained input from specialist smoke

vent manufacturers and contractors on integrated ventilation systems and kitchen

extract ventilation products.

89. On 2 October 2013 I sent Matt Smith at Max Fordham, the building services

engineering consultants on the Project, a copy of a brochure for a kitchen extract

system and asked him to advise me whether he thought it would be a satisfactory

alternative to the fan that they had proposed. I also asked him to advise on price

comparability {SEA00008858}. Matt Smith emailed me back on the 4 October 2013

and said the system appeared to be a "neat solution" for the kitchen extract, although

he queried how noisy it would be and how easy it would be to repair I replace in 5-10

years' time {SEA00008991}.

90. On 3 October 2013 I emailed a company which specialised in smoke and climate

control and external louvres, the Colt Group, and asked them about one of their

products, a Kameleon Natural Facade Ventilator. I explained that as result of a

reconfiguration we needed to smoke ventilate some of the new lobbies and rooms to

the external space of the building through new openings in the fa<;ade. I told them

that we would like to specify their Kameleon Natural Facade Ventilator because of its

unobtrusive facade appearance and its ability to provide daylight when glazed. I also

asked them a number of questions and for a cost comparison with another of their

products, Coltlite Louvre windows {SEA00008961}.

91. On 15 October 2013 I sent Bruce Sounes (Studio E) a CAD (Computer Aided Design)

file with an elevation drawing marked up with the AOV based on the Colt's system's

tilting outward opening flaps {TRl/3}.

92. In October 2013 I started drawing up the window design using Schueco products. On

18 October 2013, I emailed Gavin Snowdon at Schueco UK Limited (Schueco)

regarding curtain walling for the Podium. I told him that I wanted to start drawing up

the design using their products and needed his assistance in selecting the right

solutions {SEA00009245}. I also told him that I would leave the windows which he

had started looking into with my colleague Paddy Glennon for another day, and I

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asked him whether the Kameleon Natural Facade Ventilator and Coltlite Louvre

window were compatible with Schueco products.

93. At this time I was also obtaining further information and quotes from the Colt Group

regarding smoke vents and Schueco windows, and from Smoke Control Solutions

regarding AOVs which were to be located in the curtain walling for the Podium.

94. On 22 October 2013 Gavin Snowdon (Shueco) provided me with more information,

including preliminary static calculations for the fa<;ade, with recommendations for

high traffic doors, access control solutions, and smoke and heat exhaust ventilation

systems (SHEVS) vents. He said that Schueco had their own range of SHEVS vents

and he asked me whether my query was about a hot smoke, cold smoke or purely

ventilation set up. I told him that the vents would need to be able to vent hot smoke

out of the Tower and I attached a draft mark-up of the elevation drawing number

1279-SK094 {SEA00002314} showing the AOV on elevations showing the

distribution of the smoke vents. I included some dimensions on the drawing,

including:

94.1 530mm xl985mm, which were the dimensions of the vent set between

mullions and transoms of the curtain wall.

94.2 905mm x 580mm & lOOOm x 1325mm, which were the dimensions of the

window vent outer frame.

95. I also asked Gavin Snowdon (Shueco) to confirm the maximum opemng angle

considering the actuator capability and the size of the vent. I thought chain actuators

would be preferable as linear ones would take up too much space internally. I asked

Gavin whether the indicated required free areas (0.4m2) were achievable with the

current design {SEA00009342}.

96. On 23 October 2013 Peter Lawrence from the Colt Group contacted me and he

confirmed that the Kameleon Natural Facade Ventilator was not available anymore.

He recommended the Coltlite Louvre instead. I asked him for the 'free' area and cost

calculations for seven vents {SEA00009353}.

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97. On 25 October 2013 I emailed Stuart Pollard, the specification manager at Hydro

Building Systems Limited (Hydro) and asked him about the dimensions and hanging

options for a proprietary window called "Technal EVO 65". Technal is a Hydro brand.

I also asked him for brochures, samples and options for the window with ironmongery

and whether he would be able to advise on "the feasibility of our smoke vents

proposal" and provide us with further input on a range of technical questions, and for

a quote {SEA00009429}.

98. On 28 October 2013 Bruce Sounes (Studio E) forwarded me a copy of the following

email query that Claire Williams, Project Manager at KCTMO had sent to Chweechen

Lim (Senior Cost Consultant) at Artelia UK, and he asked me to respond:

"We met Carillion yesterday, talking about grant funding for various energy

efficient schemes. It seems to be that you need to have the insulation and

windows higher than building regs rating to get grant. I am clear that our

cladding is an enhancement to attract grant, but the windows need to be 'B' or

'A ' rated to get the additional funding. Can you please confirm this is in the

performance spec?" {SEA00009465}.

99. The following day, 29 October 2013 after I had checked the detail with the window

manufacturer, Schueco, I emailed Chweechen Lim at Artelia UK and confirmed that I

would include BREEAM Domestic rated B windows in the NBS Specification.

{SEA000094 7 4}.

100. On 30 October 2013 I also emailed Stuart Pollard (Hydro), and asked him for advice

on AOV vents and mullion sizes for curtain walls, and for a NBS specification for the

windows and for the curtain wall {SEA00009495}.

101. On 30 October 2013 I emailed Bruce Sounes (Studio E) and circulated a summary of

the comments that I had received from window and AOV manufacturers. I suggested

we abandon Schueco windows and instead go with Technal openable windows. I also

confirmed that I had corresponded with the Smoke Ventilation (SHEV) Company,

AOV Systems and Colt Info regarding smoke vents {SEA00009493}.

102. On 4 November 2013 I also contacted Matt Smith at Max Fordham about the

BREEAM rating at the Project. I told him that smoke detectors were not due to be

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fitted to the flats on the Existing Floors and queried whether this was contrary to

BREEAM Hea 06 Safety {SEA00009659}.

103. On 5 November 2013, Matt Smith at Max Fordham, responded to various queries I

had raised regarding ventilation and smoke detectors for BREEAM ratings and he

provided me with his comments on certain of the queries that I had raised. Matt stated

that the flats on the Existing Floors would obtain a first credit under BREEAM Hea

05 Ventilation if a kitchen extract was installed (the existing bathroom extract system

for the Existing Floors was being retained). He said new smoke detectors were a

requirement under Hea 06 Safety, and as this wasn't currently allowed for the credit

would not be achieved {SEA00009684}.

104. On 6 November 2013 I emailed Bruce Sounes (Studio E) a short summary of the

progress I had made with Hydro and I set out when they were due to provide further

information regarding a window sample, curtain wall details and a NBS specification

for the windows and for the curtain wall {SEA00009689}.

105. On 6 November 2013 I also emailed Laurence Ward, an architectural advisor at

Renson Fabrications Limited, a manufacturer of louvre panels, ventilation and solar

shading products, and asked him about the specification of Loggia louvre panels fixed

over the openable window vents {SEA00009690}.

106. I also sent Arthur Lewis Nunes at Max Fordham a drawing (drawing 1279 _SEA_(06)

113 _Plan Detail) showing windows and asked him:

"You will see that the position of the adjacent windows limits the length of the

wall. I have returned the insulation. Would this be satisfactory in lieu of your

recommendation?" {SEA00009717}.

107. Later that day, 6 November 2013, Arthur Lewis Nunes (Max Fordham) confirmed that

the proposed detail would be suitable {SEA00009719}.

108. On 6 November 2011, Stuart Pollard (Hydro) sent me an NBS specification for

windows and curtain walling {SEA00002422} and further information on curtain wall

solutions {SEA00001952}. He suggested the curtain walling material should be

"WICONA WICTEC 50 Capped curtain walling" and he attached a brochure for this

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material to his email {SEA00009815}. He also suggested that the aluminium windows

should either be "WICLINE 65 evo" or "WICLINE 75 evo". I included Stuart

Pollard's draft specification for windows and curtain walling into our draft NBS

Specification and on 11 November I asked him to double-check that the curtain wall

mullions sizes.

109. On 7 November 2013 Bruce Sounes (Studio E) copied me into his email to Bruce

Inker at Specialised Panels, who were suppliers of plywood and timber. Bruce asked

Mr Inker to forward him the specification and indicative costs for "15&18 mm Birch­

faced ply, pressure impregnated Class 0" {SEA00009768}, which he said we were

considering using for the window reveals and cills (see P20/240A Plywood Window

Reveals and Cills).

110. On 8 November 2013 Bruce Inker (Specialised Panels) responded:

"Thank you for the enquiry for Birch Plywood FR Treated, I have assumed the

panels will long grain.

Birch Throughout WBP Plywood BlEB FSC or PEFC, FR treated with

Osmose FirePro to Euro Class B to EN ISO 11925 (Ignitability Test) & BS EN

13823:2002 (Single Burning item Test).

The above specification will cover both the ply and the FR treatment, I am not

sure what finish you require on the face, but would 1 would suggest it is

lacquered in the factory with a water based coating, so you could also add;

Coated to one side with a water based clear (Or if shade is needed please add)

Lacquer, to achieve a (Matt, Satin or Gloss) finish. As a price indication based

on a 2440 x 1220 panel treated to Huro Class B 15mm@ £65.00 Each 18mm

@ £78.00 Each Add £20.00 mt2 for Lacquering" {SEA00009790}.

111. I included the plywood panelling in NBS Specification {SEA00009894}. We

ultimately ended up specifying a Class 1 (using the UK testing methods) or Class C­

s3, d2 (using the European testing methods) 15 mm thick Birch faced plywood for the

window reveals and cills.

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112. On 11 November 2013 I emailed Stuart Pollard at Hydro and thanked him for the

NBS specification for windows and curtain walling. I confirmed that I had included

his suggestion in our specifications {SEA00009815} and I asked him to 'double check'

the size of the curtain wall mullions.

113. The same day, I also discussed the details of the smoke vents with Stuart Pollard at

Hydro and I sent him a number of drawings and I referred him to a number of

outstanding queries. I told Stuart that we were looking at issuing tender

documentation by the end of that week (i.e. Friday, 15 November 2013) and I needed

"a coordinated solution by then". I asked Stuart whether he would be able to come in

with a sample during the week {SEA00009810}.

114. On 12 November 2013 I told Bruce Inker (Specialised Panels) that "We are thinking

of specifYing treated plywood for the window cill and reveal cladding". I sent him a

draft drawing 1279 SEA (06) 110 Typical Bay DRAFT 131112 and told him that we

intended to retain the existing timber cladding and fix the new one over it. I also

asked Bruce about the thickness of the birch plywood:

"- 12mm -do you reckon this would be sufficient? - can the boards be factory

finished (with lacquer on top surface and edges)? - can the edges be 2mm

chamfered ? - would brad head nails be sufficient way of fixing? - The surface

will need pass Class I (using the UK testing methods) or Class C-s3, d2 (using

the European testing methods)" {SEA00009876}.

115. On 13 November 2013 I also emailed Bruce Sounes (Studio E) and I confirmed that I

had included plywood panelling in NBS Specification clause K13/120A for the

window reveals and cills {SEA00009894}.

116. On 14 November 2013 I emailed Bruce Sounes and Paddy Glennon (both Studio E)

regarding a window mock-up for the resident presentation in the NBS Specification,

saying that Stuart Pollard (Hydro) was able to bring along a sample of the window by

the following Tuesday {SEA00009916}.

117. On 27 November 2013 I also contacted Ben Campbell at Armstrong World Materials

about using their ceiling system for the external ceilings of the undercroft and I

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included these materials in our draft NBS Specification at clause 116, K40

demountable suspended ceilings {TRl/4-5}.

118. Stuart Pollard (Hydro) also advised me that it was possible to have a hole in the glass

panel to take an extract vent but that both panes would need to be toughened glass.

Stuart told me the position of the hole would be important and that the best option was

to put it further into the glass and not near the edge. He said Hydro would however

need to know the position and size of hole and get it checked fully by the glass

supplier. If the glass was insulated on the back face then this would be cut to allow the

extractor to fit with necessary clearances {SEA00010080}.

119. On 29 November 2013 I sent the internal team at SELLP copies of my chain of email

correspondence regarding the window dimensions, U-values and smoke vents

{SEA00010079}.

120. On 11 December 2013 Mark Harris at Harley told us that it had started receiving

formal tender enquiries from the main contractors tendering on the Project.

121. Mark said he had noticed that in our NBS Specification we had specified Wicona

windows and curtain walling. He said Harley was happy to supply a Wicona system

but that it was not a system it was particularly familiar with. He said over the past

few years Harley had used Schueco or Metal Technology windows and that it had

used Metal Technology windows on the Ferrier Point development.

122. Mark asked whether we would have any objections to it pricing an alternative to

Wicona. He said he appreciated that he should request this information via the main

contractor but he thought a quick email to us would be much quicker as he needed to

start sending out pricing enquiries before Christmas {SEA00010147}.

123. On 11 December 2013 Bruce Sounes (Studio E) explained that "It's a straightforward

question and answer but it will need to be circulated via the standard channels. I

might not be able to respond direct" {SEA00010148}. Mark Harris (Harley) said this

wasn't a problem {SEA00010149}.

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G CAVITY BARRIERS

124. In the NBS Specification we specified Lamatherm CW-RSH60 cavity barriers, which

were manufactured by Downer Cladding Systems Limited. I do not recall how Studio

E sourced these cavity barriers but my drawings show cavity barriers at the floor and

party walls. I think I discussed cavity barriers with Harley but they may have been

included in our drawings before Harley and Studio E were in contact in autumn 2013.

125. I do not recall discussing the fire performance of the cavity barriers and where they

should be located. I also do not remember whether the fire engineer informed us that

the cavity barriers at the lines of compartment walls and floors should have the same

fire resistance as the compartment element itself The name of the Lamatherm product

that we specified, namely CW-RSH60, suggests that it has 60min fire resistance

('RSV60') but in the NBS Specification we only required 30 min fire resistance

('30/30 to BS476, Part 20:1987 and BS EN 1366-4:2006'). I cannot explain the reason

for this discrepancy. I do not recall discussing the fire resistance of cavity barriers

with Harley, the SELLP design team or anyone else. That, of course, does not mean it

didn't take place.

126. My drawing of a typical bay window {SEA00008683} suggests cavity barriers at the

windows reveals. I am however not entirely sure whether I was specifying cavity

barriers as they are not annotated on the drawing and they seem to be filling the gap in

the same manner also below the window, in the so called spandrel panel. I also do not

recall whether a continuous steel angle supporting the cill of the windows was deemed

as a cavity barrier. I have had a look at my drawings and this detail may have been an

inherited geometry from drawing RE 140 dated 11 September 2012 {SEA00001586}

and SK085 dated 17 September2013 {SEA00002135}.

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H BREEAM I INSULATION

127. BREEAM is an established method of assessmg, rating, and certifying the

sustainabili ty of buildings.

128. Before I was involved in the Project, Syntegra Limited (Syntegra) had produced a

BREEAM pre-assessment report and Max Fordham had produced a Sustainability and

Energy Statement. During my involvement in the Project, I liaised with Syntegra and

Max Fordham to obtain further information to assist Studio E in preparing the NBS

Specification (eg. to ensure the BREEAM requirements were met) and also to ask

them to update any materials we needed to issue with the tender documentation ( eg.

the BREEAM pre-assessment document).

129. Before I contacted Syntegra, on 25 October 2013, I familiarised myself with some of

the BREEAM draft pre-assessment scoring comments, and emailed Bruce Sounes

(Studio E) a number of comments to check my understanding given his experience

with the BREEAM considerations for the Project {TRl/6-7}. One of my comments

was "Are we challenging (reducing) amount of insulation?" as it seemed "MF went

for 'ott' U values to achieve maximum credits available for Thermal Performance

Criteria". I assume that I discussed this with Bruce, but I do not recall what we

discussed specifically.

130. Later that day, I contacted Neelam Paranjpe (Syntegra) and asked him about

Syntegra's existing BREEAM pre-assessment and whether they had assumed that

"twice as much new insulation than existing" would be installed {SEA00009440}.

131. Neelam Paranjpe (Syntegra) responded on 29 October 2013, and said regarding the

insulation "if we can make sure that all new insulation in the build (insulation in

walls, roofs etc. as well as the building services insulation is A+ rated we will achieve

the required credits)". He also asked to see the tender documents being created, so he

could have a quick skim through "to make sure all BREEAM requirements are

included' as "we are very much at the brink of the GOOD rating and so we need to

make sure we do not lose any credits" {SEA00009475}.

132. On 17 November 2013 Bruce Sounes (Studio E) asked me to chase Neelam Paranjpe

at Syntegra for an update for the tender {SEA00009955}. On 19 November 2013

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{SEA00010012} I sent Neelam a summary of BREEAM categories and scoring as

shown in the draft NBS Specification at that time and asked him for comments. At

that time my summary of the NBS Specification for the external wall was as follows:

Tomas REK

Mat 01 Environmental Impact o[Materials

Roof"

No alterations are proposed to the existing roof

External Walls - rainscreen cladding:

Type: drained and back ventilated

Backing wall: Reinforced concrete, brickwork, SFS

Thermal Insulation: Zero ODP rigid polyisocyanurate insulation board

ERE Green Guide rating A+. Celotex FR5000 aluminium foil faced both

sides. Conductivity: 0.021WimK. 100mm thick for columns. 150mm thick

for walls/ spandrel panels.

Secondary support/framing system: Aluminium vertical rails with fixing

brackets on thermal break spacers.

RAINSCREEN CLADDING: TO COLUMNS & EXTERNAL ENVELOPE

OF MAIN ENTRANCE C'ANOPY:

PROTEUS HR honeycomb rainscreen panel by KME Architectural

Solutions

RAINSCREEN CLADDING: [GENERALLY FIRST FOUR FLOORS

ELEVATIONS & INTERNAL ENVELOPE OF MAIN ENTRANCE

C'ANOPY & C'ANOPIES IN GENERAL:

Pvdf paint finish coil-coated aluminium CGL Wallplank System

rainscreen cladding Alternatives to be considered:

Reynobond- Duragloss 5000:

o Metallic std & non-std (Satin gloss)

o Brushed aluminium

o Chameleon

o Anodised Look

Alucobond:

0 Spectra, Sakura 917

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133. On 25 November 2013, Neelam Paranjpe (Syntegra) responded that he would get an

updated assessment report sheet to us by the next day {SEA00010012}.

134. I included the standard NBS specification precedent H92 for rainscreen cladding

which required the building contractor to comply with the "CWCT Standard for

Systemised Building Envelopes". I did not specify bespoke design or fire performance

requirements for the thermal insulation.

135. Paragraph 6.6.2 (Insulation materials) of the CWCT Standard provides:

"Insulation in walls of buildings with a storey more than 18m above ground

level should be of limited combustibility."

136. Therefore, I would have expected tenderers to have ensured that insulation in walls

above 18m complied with the specified CWCT performance requirements (i.e. were

material of limited combustibility), before submitting their tender returns.

137. As far as I can recall, the decision to use Celotex FR5000 product was made before

my involvement on the Project. For example, the Max Fordham Sustainability and

Energy Statement, submitted to planning and dated August 2012, refers to Celotex

FR5000 in tables 2-2, 2-3 and 2-4 {SEA00006006}. The build-ups shown in these

tables are similar to the final NBS Specification that we issued for thermal insulation

which was 150mm thick Celotex FR 5000 insulation foil faced both sides and 80mm

Celotex FR 5000 insulation for the columns (see Clause 776 of NBS Specification

{SEA00000169}).

138. I do not recall any conversations or discussions with SIG, Celotex, Wicona or anyone

else in the office on the fire performance of Celotex FR5000 insulation or about

whether it complied with Part B of the Building Regulations and should be used

above 18m. That does not of course mean I did not discuss this with them but, if I

did, then I simply cannot remember having this discussion.

139. As I have said, I think the decision to specify Celotex FR5000 insulation had been

made prior to my involvement since it figured in Max Fordham's Sustainability and

Energy Statement which was prepared in 2012.

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140. After I left SELLP I was involved in the design of a high-rise building where Celotex

FR5000 was also specified. On that project Exova had produced a desktop study

comparing the rainscreen fa<;ade cladding with Celotex' s tested sample and they had

concluded that it complied with BR135.

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Statement of truth

I believe that the facts stated in this witness statement are true. I am willing for this witness

statement to form part of the evidence before the Inquiry and to be published on the Inquiry's

website .

Signature ............... \..::: ................... ~ ............... ........................................ . Name TomasRek

Date

Tom as Rek

SEA00014278_0035 SEA00014278/35


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