The statements of Mr Russell (Jim) Harris were read out in court. The essence of their content is given here. The first statement was made on May 6th 1998.
I have been a lorry driver for 25 years and have also operated heavy plant and smaller machines for example fork lift trucks. I have had CITB training in plant operation.
I joined Euromin in 1989 as a forklift driver. I started using the loading shovel and they asked me if I'd learn to operate a crane. A trainer came and taught me how to use the Priestman. I used it to unload aggregate from ships.
Around 1991 we started to get bulk bags of paving blocks coming in and we used a hired crane to unload them. Then Euromin got the Liebherr R984. We started using it with chains attached to the hinge bars inside the grab with chains attached to lift he bags from the hold. When we did this the workforce consisted of a crane operator, a forklift driver, a banksman, two men hooking on in the hold, and two men hooking off on the quay. We used to have the same people coming in to do the job.
A few months ago, some hooks were fitted to the centre stem of the grab and the chains were put straight on the hook. I was trained to use the Liebherr 984 when Euromin first got it.
On 24 April I came to work about 7 am. I knew I'd be operating the Liebherr so I went through the routine checks. I carried on with general yard duties until the ship came in then I started the Liebherr to warm it up. I saw Sean and Jody and said I wanted Sean in the hold and Jody on the quay because nobody seemed to have organised them. Roger told me there would be a couple of crew members helping. One of them went and stood next to the hold for banksman duties and the other joined Jody on the quay. I saw someone else arrive with a high-vis jacket and assumed he was the casual. He went straight on to the ship and into the hold. The grab was already in the hold and I waited for the banksman to give the signal to lift. The banksman wasn't using standard signals, but I could understand him. After about 45 minutes I swung the grab back into the hold and the banksman signalled me to go down, then across to the far side then lower again and stop. I then got the stop signal again, and didn't understand because I wasn't doing anything. The banksman started waving his arms around. I saw Sean appear on top of the heap of cargo, signalling to open the grab and shut the engine off. Then he was shouting “ambulance” and I realised there was a problem. I called to Roger who was standing on the quay and he immediately phoned for an ambulance.
The second statement was made on 10 May 1999.
I previously made a statement to the HSE on 6 May 1998 relating to the events on 24 April 1998, which led to the death of Simon Jones while he was unloading the ship MV Cambrook. This took place at Euromin, Turberville Wharf, Shoreham. I was interviewed under caution on 20 August 1998 at Hove Police Station. Since then I have been informed that I am no longer suspected of involvement in any criminal investigation into the death of Simon Jones. I have been asked if there is any information I may have which might be connected to the death of Mr Jones, which would not have been included in my previous statement or interview.
My belief is this was a bad day for circumstances, which added together resulted in Mr Jones's death. On the day in question the driver of the loading shovel was working elsewhere. I only know him as Taffy. Due to this, Trevor Ford, who is usually the banksman, that is the signaller between the hold and the crane, had to drive the shovel. This left me as the crane driver without my normal banksman. A crew member from the MV Cambrook stood in as banksman and gave signals that I understood but were not as I usually receive from a banksman. I felt a difference in the point where the crane took the strain of loading that made me even more aware that things were different that day. The banksman usually plays a lead part in unloading a ship. The next level is the man in the hold. I knew on this day that it was Sean Currey, who I had worked with before and I was satisfied that he had done the job before. He'd assume control in the absence of the banksman, and give signals to the stand-in banksman. Because of the difference in the point at which the crane was taking the strain, I was unsure whether Sean Currey was signalling to the banksman as he should be. In the position of crane driver, the only guidance is from the banksman. The crane driver can see nothing so must take instructions from the banksman. I felt the action of unloading was wrong, but could only be guided by the banksman.
The other unusual happening that day was that our casual labour would normally join us about 7 am in the mess room where we'd talk through the work of the day and anyone new would be told not to go near the machinery until it had stopped. This was a briefing, but not a policy of the company. It was an informal thing that had developed as a result of commonsense and the fact that we were working with different and sometimes inexperienced casual labour. On this particular day, Simon Jones arrived after the unloading had started.
I'd like to clarify a point about the type of equipment used on the day. The crane was fitted with a clamshell grab. Roger Grant said to me about half an hour before starting work, “do you think we should change the grab for the hook?” or words to that effect. I answered, “Have you had permission from James?” (meaning James Martell the manager). Roger Grant replied, “no”. I said, “you can't change the grab then or you'll get a right rollicking”. I believe Roger Grant suggested he couldn't contact James Martell. Nothing more was said. I knew the grab had never caused a problem in the past so I continued with the work of the day.