Grenfell Tower: the genesis of a lie
Theresa May declining to say whether the ACM cladding was compliant with regulations, House of Commons, 22 June 2017, 10:30:30 (https://www.parliamentlive.tv/Event/Index/18b1ea2c-c8a9-4314-a9cc-efbb81cc2b38)

Grenfell Tower: the genesis of a lie

Early reporting on the Grenfell fire of 14 June 2017 established the facts about the compliance of the PE Reynobond ACM panels with reasonable accuracy. The Daily Telegraph reported midday 16 June that they 'had to meet 'Class O' regulations', but did not have to be non-combustible:

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It also pointed out, probably referring particularly to the evidence given to the 1999 ETRA Committee cladding inquiry, that concern had been expressed about the Class 0 requirement over a long period:

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Later the same day in the Guardian, Phil Barry of CWB Fire Safety Consultants drew attention to the inadequacy of fire classifications based on tests that attack the surface of the product only, potentially allowing the use of ACM with a plastic core. He called for a ban on combustible materials over 18 metres:

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providing the heading for the article:

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The very same article, however, contained a claim by DCLG that PE ACM cladding used on buildings over 18 metres in height would be already be non-compliant with Building Regulations guidance:

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But this was not true. The only fire safety requirement for high rise cladding panels in the Approved Document guidance was that they achieve either national Class 0 or Euro Class B (AD B2 2013, 12.6, Diagram 40e):

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Several PE ACM products had been tested successfully to one or both of these classifications:

National Class 0

To achieve Class 0 by testing (AD B2 2013, A13.b), a product must achieve Class 1 to BS 476-7, and, when tested to BS 476-6, Fire Propagation Index I ≤ 12, and sub-index i? ≤ 6.

  • Larson (Alucoil). Warrington Certificate of Approval CF 5223. 22 January 2014, valid until 21 January 2019. Class 0. I = 0.5, i? = 0.0.
  • Larson (Alucoil). BBA 08/4551. 22 April 2008. Current until 30 August 2017. Class 0. (I = 0.1, no value given for i?.)
  • Alucobond (3A Composites). BBA 05/4214. 24 July 2013. Current until 30 August 2017. Class 0. I = 0, i? = 0.
  • Etalbond. BBA 07/4664. 26 March 2012. Class 0. I = 0.3, i? = 0.83. (Duration uncertain, but Etalbond PE Technical Data Sheet, Version: 29 July 2016, still shows Class 0 classification.)
  • Reynobond RB 160 PE (now Arconic). Warrington Fire Classification Report 70707/70708. 9 May 1997. Class 0. I = 0.3, i? = 0.0.
  • Reynobond 33 PE (now Arconic). Warrington Fire Classification Report 157530/157537. 14 September 2006. Class 0. I = 0.9, i? = 0.2.
  • Vitrabond (Valcan). Information on BBA web-site, August 2017 Certificate listings. Vitrabond PE achieved Class 0 in 'a test' [sic (2 tests requisite)] carried out on 2 January 2018:

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Euro Class B

  • Vitrabond (Valcan). BBA 12/4901. 23 March 2012. Current until 4 August 2017. B-s1, d0.
  • Etalbond (Elval). BBA 07/4464. 27 March 2018. When tested (to EN 13823) by Safran, the French testing and certification body, the panels achieved B-s1, d0.
  • Reynobond (now Arconic). BBA 08/4510. 4 August 2017. B-s2, d0.

The list is almost certainly not comprehensive, being limited to PE ACM products for which I personally have been able to find documentary evidence of a Class 0 or Class B classification or certification. In all cases (Reynobond, Alucobond, Vitrabond, Larson, Etalbond), use of the PE ACM product would have been in compliance with the Approved Document guidance on residential high rise buildings in England, Wales and Northern Ireland at the time of the Grenfell refurbishment, and in at least four cases (proof for Etalbond being lacking) would still have been compliant on 16 June 2017, the date of DCLG's false claim.

Expert Group Meeting at DCLG, 17 June 2017

An 'Expert Group', chaired by Housing Minister Alok Sharma MP, met in the Ministerial Conference Room in the DCLG at noon on Saturday 17 June 2017:

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Also in attendance were Professor Luke Bisby of the BRE Centre for Fire Safety Engineering at Edinburgh University, Dr Debbie Smith, Managing Director of BRE, Martin Shipp, Fire Safety Technical Development Director at BRE and apparently not yet inaugurated as President of the IFE (according to this BRE article, but recently retired from BRE according to this IFE article), Sir Ken Knight, Ex-Commissioner of London Fire Brigade, Colin Todd of C S Todd Associates, and others:

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The group referred to three grades of ACM on the market and claimed that for use on high rise only one of them would comply with AD B guidance:

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There were indeed three grades of ACM on the market, commonly termed PE (polyethylene core), FR (fire retardant core) and A2. An A2 panel had the best fire qualities having, by definition, been classified to EN 13501-1 as A2, and therefore being of 'limited combustibility' as defined in AD B2. Thus the Expert Group were claiming that only A2 panels were compliant with the guidance.

Apparently, they were taking the view that ACM panels were subject to the limited combustibility requirement of 12.7. But how could this be, since 12.7 applies to insulation products and filler materials (etc) only? The Expert Group does not explain.

It may be added that even if ACM panels had been subject to 12. 7 - which they were not - it would still not have been the case that only A2 panels could be compliant with the Approved Document guidance. At least two cladding systems, both incorporating Alucobond FR ACM panels with mineral wool insulation, had already been tested by the BRE, one to BS 8414-1 and one to BS 8414-2 and, although the classification reports were not issued until 29 June 2017, the BRE can hardly have been unaware by 17 June that the BR 135 criteria had been met in the tests (the drawings for which are dated 12 July 2016), making both systems compliant with AD B2 12.5:

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DCLG letter, 18 June 2017

A DCLG letter sent the next day, Sunday 18 June, to Local Authority and Housing Association Chief Executives, took the same position that only A2 ACM panels would be compliant with the guidance. It claimed explicitly that there was a limited combustibility requirement, but specifically for the core of the panel, rather than for the whole product:

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yet still without any explanation as to where this requirement was to be found in the guidance. The MHCLG Building Safety Timeline, submitted to the Grenfell Inquiry, confirmed that the advice given by the DCLG in this letter had been informed by the previous day's Expert Group meeting:

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Phil Hammond on the Andrew Marr Show, 18 June 2018

That morning, Philip Hammond, the Chancellor,?told?Andrew Marr that the Grenfell tower cladding was banned in the UK:

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A Treasury spokesman reportedly clarified later in the day that Hammond had meant that it was banned for use on high rise buildings:

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John Cowley, managing director of CEP Architectural Facades, which fabricated the Grenfell ACM panels, rejected even the clarified version of the Chancellor's claim, insisting that building regulations permitted their use on high rise:

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Nevertheless by Wednesday 21 June Robert Booth in the Guardian, the same paper which on Friday had reported calls for a ban, was reporting as fact that PE ACM was already 'effectively banned' for use on high rise:

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and 'not compliant with building regulations on taller buildings in the UK', reciting the DCLG statement of 16 June, but now without any dissenting opinion:

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The Prime Minister in the Commons, 22 June 2017

The next day, however, in the House of Commons, the Prime Minister declined to say whether the ACM panels used at Grenfell had been compliant with regulations or not:

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The BRE 'are testing' the Grenfell cladding, she said at around 10am. But, according to MHCLG's Position Statement to the Grenfell Inquiry, test results from ACM samples from other buildings had been coming in since the previous evening:

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and it is hardly credible that the BRE would not have tested the Grenfell cladding first. In any case, CEP had confirmed on Friday that the product was PE Reynobond:

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the Expert Group knew on Saturday that it was PE ACM:

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and the Chancellor had appeared to know on Sunday which product was used. So why did Mrs May give the appearance of not even being sure what type the panels were? It seems to me that if she had acknowledged that they were Reynobond PE ACM then she could hardly have refused to say whether they were compliant or not. After all, if she had not been able to say one way or the other, then how could an architect or builder have been expected to know? But then she would have been forced either to admit that they had been compliant, making the government largely responsible for the disaster, or lie to the House of Commons.

'For the avoidance of doubt', DCLG footnote, 22 June 2017

The same day, Thursday 22 June, in a footnote to another letter to the Chief Executives, the DCLG attempted to justify their contention that ACM panels on high rise were required to be of limited combustibility:

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Relying on AD B2 12.7 only, the DCLG proffered three rationales for the application of the limited combustibility requirement of that paragraph to ACM cladding panels. Remarkably, however, the DCLG were uncertain of the validity of either of the first two rationales! How could it be that the DCLG were unsure of the meaning of guidance which it had itself issued, or uncertain whether the terms used within it applied to this commonly used building product? Even more remarkable is that these two rationales were connected grammatically by 'and/or', meaning that while there was uncertainty about each, the DCLG was certain nevertheless that at least one of the two was valid! The three rationales were as follows:

  1. The ACM core might be an insulation material or product;
  2. The ACM core might be a filler material;
  3. Paragraph 12.7 applies to every element of a high rise cladding system.

In Appendix F of her Expert Report to the Grenfell Inquiry, Dr Barbara Lane analysed the DCLG's reasoning, which appeared in identical form as footnote 4 in an Explanatory Note issued on 30 June 2017.

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She addressed all three DCLG rationales and concluded:

1) Rain screen panels have negligible insulation function:

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and therefore ACM panels are not an insulation material product (ACP = Aluminium Composite Product):

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2) A filler material is a joint or a surface filler:

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The ACM core fulfils none of the functions of a joint or surface filler:

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She therefore disagreed with the view that the ACM core is filler:

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3) As to whether AD B2 applies to 'any element of the cladding system', as the DCLG had claimed, Lane observed that the heading to the paragraph was 'Insulation Materials/Products'. She had

no understanding why it applies to anything else.
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Andrew Chapman



Richard Chubb

Lead Principal Environmental Health Officer , Joint Inspection Team , Local Government Association

6 个月

Commenting for reach...excellent work ??

Guillermo Rein

Professor of Fire Science | Science, Heat Transfer, Engineering

3 年

Exhaustive recompilation. Thanks for sharing.

Aaron Nicholson

Technical Director at RED Fire Engineers - Fire Engineer & Expert Witness. All views and opinions are my own and not that of my employer.

3 年

Andrew Chapman , im late to this but what a well laid out article. Thank you

William Parlor

Retired at Bill Parlor Consulting

3 年

Just to point out that Class 0 was a contrivance from the Regulator to allow paper faced plasterboard to be first used as ‘minimal’ threat but the gates once open have allowed more hazardous products as well. Not thought through by the incumbents then or ‘allowed’ to change since.

Iain Sanderson

Retired Lecturer

4 年

Well presented and researched Andrew - Thanks.

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