Evidence of Chris Ingram


P You were a service engineer for Liebherr in April 1998?

CI I was.

P How long had you been visiting Euromin at that time?

CI Since June 1997.

P When you serviced excavator R984 did it have a grab?

CI Yes.

P Were there ever any other attachments?

CI No.

P Did you visit every 5 weeks?

CI The machine had to be serviced at intervals of 250 hours. I was there regularly.

P You were last there on July 17 th 1998?

CI Yes.

P Before 24 th April 1998 were you aware of extra hooks on the stem?

CI I had noticed the hooks welded but I had never seen them used. It had always been used as a grab. On many occasions when I visited the machine wasn't working because I was working on it.

P Did other machines at Euromin need more servicing than the R984?

CI It was about the same.

P While you were servicing the other two machines, had you seen the R984 in action?

CI Yes.

P What work was it doing?

CI Unloading ships; used as a grab.

P Did anyone at Euromin ever ask you about the hooks; would Liebherr approve of them?

CI No.

P Did anyone at Euromin phone Liebherr about the hooks?

CI Not to my knowledge but they wouldn't necessarily tell me.

P You were at Euromin on the 24 th April?

CI Yes.

P You were in the workshop working on the loading shovel?

CI Yes I arrived at 8 am.

P Did you see any unloading?

CI I was in the workshop but I was aware that the R984 was working.

P Were you aware that the hooks and chains were being used?

CI Not until after the incident. I heard the ambulance and looked outside.

P If you had seen the excavator being used dangerously, what would you have done?

CI I would mention it to someone in authority if it was detrimental to the machine or health and safety.

P Would you mention it to someone at Euromin or at Liebherr?

CI Both.

P If you had seen the grab being used as it was on the 24 th April, would you have considered it to be dangerous practice?

CI I'm not certain I'd have needed to bring it to their attention. I don't know how to answer that question.

P Did you see the system in operation?

CI No.

P Were you familiar with the manual?

CI Yes but I couldn't tell you the contents.

P Did you attend after the incident?

CI Yes.

P Was there anything mechanically wrong with the excavator?

CI No.


D Are you sure you never saw the chains being used?

CI As sure as I can be.

D If you had seen the chains, would you have been interested?

CI Not really.

D You serviced R984 on 17 March 1998. How long did that take?

CI That depends on what servicing was needed. A minor service would take 3 hours; a major one would take nearly all day.

D On 19 February 1998, you were on a site visit that took eight and a half hours.

CI I don't know which machine I was working on.

D Seeing the hooks excited no curiosity: you never asked anyone about them?

CI It's not really my brief: I wouldn't know if Liebherr would be interested or not.

D A modification done by Euromin and not by Liebherr was no concern of yours?

CI Not particularly.


J Did you service a number of R984's?

CI Yes.

J Did you ever see hooks in that position?

CI No. I've never seen a machine with hooks welded to the centre column.