Evidence of Gerry Vines, Liebherr regional service manager

 

P – Mr Vines you were southern regional service manager for Liebherr in 1998?

GV – Yes.

P – Liebherr supply and service equipment including the excavator R984?

GV – Yes.

P – The Liebherr was supplied to Euromin with the attachments?

GV – Yes.

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?

GV – Yes

P – Euromin bought the excavator on 9 January 1992?

GV – Yes.

P – Did you service the machine?

GV – Yes.

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?

GV – No.

P – What was the working pressure in the cylinders?   

GV – 300 bar maximum.

P – Was there a manual supplied with the machine?

GV – Yes.

P – Does part of it deal with prevention of accidents?

GV – Yes.

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?

GV – Yes

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?

GV – No.

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?

GV – Yes.

P – Are you aware of anyone else at Liebherr having being asked that question?

GV – No.

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?

GV – Yes.

 

P – Did you go on the 29 th of April to Euromin?

GV – Yes.

P – With Chris Ingram the service engineer?

GV – Yes.

P – Was this at the request of the HSE with Mr Hinks?

GV – Yes.

P – Did you examine the excavator R984?

GV – I did.

P – Was the grab attached?

GV – Yes.

P – Did you notice unexpected hooks welded to the grab?

GV – Yes.

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?

GV – No.

P – Was anyone from Euromin present at this inspection?

GV – I don't recall anyone.

P – Did you understand what the hooks were for?

GV – Yes.

P – Did anyone at Euromin explain?

GV – No.

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?

GV – Yes.

P – How long does this take?

GV – If all goes well roughly an hour.

P – Was the excavator in good working order?

GV – Yes.

P – Were Euromin good at calling out the service engineer?

GV – Yes.

P – Did you go into the cab?

GV – Yes.

P – Did you test the joystick?

GV – Yes.

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?

GV – Yes.

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?

GV – No.

P – What about with Euromin, did a demonstrator go there?

GV – Yes.

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?

GV – Normally.

P – Does it have any other purpose?

GV – No.

P – You don't need oil for the hook attachment so the oil can be turned off?

GV – Yes.

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?

GV – Yes.

 

D – A gate valve is a shut off valve?

GV – Yes.

Mainly to stop oil leaks but it can also isolate the grab?

GV – Yes.

D - The driver knows about this?

GV – Yes.

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?

GV – Yes.

D – Is it a roomy cab?

GV – Yes.

D – The attachment range is the range of whatever attachment is fitted?

GV – Yes.

D– So it is not possible for no person to be within the range of the hook when it is stationary?

GV – No.

D – The driver must pull the joystick towards him?

GV – Yes.

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?

GV – No.

D – You got to know Euromin well?

GV – Yes.

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?

GV – No.

D – When you saw the welded hooks you assumed they were for chains?

GV – No.

D – You have visited Euromin over what period of time?

GV - 7 years.

D – You have been there when unloading has been going on?

GV – Sometimes.

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?

GV – No.

 

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?

GV – Yes.

P - The grab can trap things. Can the hook do that?

GV – No.

P – Can the grab swivel open or closed?

GV – Yes if powered rotation.

P – The hook can't rotate?

GV – No.

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?

GV – No.

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.