P Mr Vines you were southern regional service manager for Liebherr in 1998?
P Liebherr supply and service equipment including the excavator R984?
P The Liebherr was supplied to Euromin with the attachments?
P Could you look at the diagrams in the Liebherr manual?
GV It shows the reach of the equipment.
P It could dig level with the front of the excavator or even underneath it?
P Euromin bought the excavator on 9 January 1992?
P Did you service the machine?
P How often?
GV - 4 or 5 times a year until 1995.
P As service manager did you visit Euromin?
GV Yes, occasionally.
P - What was the function of the clamshell grab?
GV To move material. It closes on it and picks it up in the clamshell. It was used mainly for loose aggregate.
P Did it need anyone working near it?
P What was the working pressure in the cylinders?
GV 300 bar maximum.
P Was there a manual supplied with the machine?
P Does part of it deal with prevention of accidents?
P It says, Do not allow any person within the attachment range of the machine. Why is that?
GV The machine can slew through 360 degrees. It means nobody must be anywhere in that range.
P - Can the excavator be used to lift bags?
P - What should be used to attach the bags?
GV A hook.
P - If a customer asked you, Can I lift items by using a chain hanging down within the open jaws of the grab? would you approve of that?
P Why not?
GV - In the book it says, Do not go within the working range of the machine.
P To your knowledge did anyone at Euromin ask you that question?
GV I don't think so.
P You have already told us what your answer would be?
P Are you aware of anyone else at Liebherr having being asked that question?
P If a customer rang Liebherr for information on the equipment, could you give guidance?
GV Only using the stated guidelines.
P If the Liebherr demonstrator was asked questions on safety, could he answer them?
GV I can't answer that. I'm not a demonstrator.
J The demonstrator would refer the customer to the book?
P Did you go on the 29 th of April to Euromin?
P With Chris Ingram the service engineer?
P Was this at the request of the HSE with Mr Hinks?
P Did you examine the excavator R984?
GV I did.
P Was the grab attached?
P Did you notice unexpected hooks welded to the grab?
P These were not fitted by Liebherr and you had not seen them before?
GV That's right.
P - Would Liebherr have approved of working with chains and the grab?
P Was anyone from Euromin present at this inspection?
GV I don't recall anyone.
P Did you understand what the hooks were for?
P Did anyone at Euromin explain?
P So how did you know?
GV I had heard about what had happened.
P If you were using chains, what attachment would you use?
GV A special; lifting hook.
P If a customer wants to change the attachment, can they do that themselves?
P How long does this take?
GV If all goes well roughly an hour.
P Was the excavator in good working order?
P Were Euromin good at calling out the service engineer?
P Did you go into the cab?
P Did you test the joystick?
P How sensitive was the joystick?
GV Fairly sensitive.
P Did it take much force to close the grab?
GV Not a lot of force.
P Why is that?
GV The operator has to sit for a long time and make that movement very often.
P How long does the grab take to close?
GV Under three seconds.
P Was there any special noise that would alert you to the grab closing?
GV Only if the engine note changes when the grab is completely closed.
P Did you find the instruction manual?
P Was it complete?
GV As far as I could tell.
P Were you aware that there had been a modification to the grab before you saw the hooks on the 29 th of April?
GV I wasn't aware of anything.
P On purchasing an excavator would a demonstrator always go to the customer?
P What about with Euromin, did a demonstrator go there?
P Do you know anything about check valves on this machine?
GV Yes, it had check valves fitted.
P What is the purpose of the check valve?
GV If you break off a pipe and oil escapes, the check valve keeps the pressure up.
P Does this play a part when changing .. Sorry this is the wrong question. Can you tell me what a gate valve does?
GV It stops oil escaping.
P Is that its sole purpose?
P Does it have any other purpose?
P You don't need oil for the hook attachment so the oil can be turned off?
P That is done by a switch under the left arm rest?
GV Yes there is a safety switch and that turns off the controls. If you lift the arm rest the levers are inoperative. The controls for travel and the attachment become inoperative.
P So there is one switch to ensure that machine can't travel and the attachments can't move?
D A gate valve is a shut off valve?
Mainly to stop oil leaks but it can also isolate the grab?
D - The driver knows about this?
If the valves were closed he could operate the lever but the grab can't close?
GV It can't be powered shut.
D Harris could shut off the valve?
D Is it a roomy cab?
D The attachment range is the range of whatever attachment is fitted?
D So it is not possible for no person to be within the range of the hook when it is stationary?
D The driver must pull the joystick towards him?
D You don't take your hands off the lever if you're using it and you don't put your hands on if you're not using it?
D You got to know Euromin well?
D Were they very safety conscious?
GV Well their machines were kept in perfect condition.
D It was the best maintained fleet you came across?
GV Well, possibly.
D Liebherr don't offer a safety consultancy?
D When you saw the welded hooks you assumed they were for chains?
D You have visited Euromin over what period of time?
GV - 7 years.
D You have been there when unloading has been going on?
D You never saw chains around the grab?
GV I don't remember it being used, mostly I'd be working on broken machines. I never saw the grab in operation.
D If you were going to weld on a hook, where would be the obvious place to put it?
GV I don't understand your question.
D You couldn't put it anywhere other than it was, it couldn't sensibly be any higher?
P If the grab is open and you then shut off the gate valve, the grab can't close?
GV It can't be powered shut but if there was a leakage it could fall shut.
P Barring a mechanical fault it would stay open?
P - The grab can trap things. Can the hook do that?
P Can the grab swivel open or closed?
GV Yes if powered rotation.
P The hook can't rotate?
P When you are doing repairs do you work in the shed or in the open?
GV With the L984 always in the open because of its size.
P What about the other machines?
GV Always in the shed.
J Referring to the manual, what is meant by During actual work
GV When moving material.
J When the hook is stationary, is this actual work?
J After loading a bag on the hook, what should happen?
GV The men should get out of the working range.
J If the grab is used is it more difficult to get out of the working range?
GV Yes, because it's a lot bigger but the hold is big enough for people to be out of its range.