Dear Ms Hassell Prevention of Future Death Report Richard Laco Response from CMF Limited CMF Limited is in receipt of the prevention of Future Death Report dated 22nd October 2015. CMF Limited is required to respond to you by 21st December 2015. The company has considered the matters of concern raised in the report and responds as follows: The Project Lifting Plan produced by CMF on 25th May 2013 for lifts within the cores was revised on the August 2013 (Revision C) to include photographs of trial lifts conducted by CMF at its factory: The revisions were made in anticipation of lifts to be conducted within Cores F and D. The lifting plan in this revised format was intended for use in Core D, despite the irregular shape of the landings on one side of the core: The shape of the landing was not considered by CMF to be of sufficient significance to necessitate a change to the lift plan. Further factory trials on the level balance of the trapezoidal shaped landings carried out prior to commencing the installations in Core D had not raised any concerns that change to the lifting plan was necessary. The additional lifting procedure of re-slinging the landing at the bottom of Core D and lifting landings into position with a winch through a hole in the ground level slab above was similar to the methods contained in the lift plan revisions for the top sections of Core A and F that had utilised almost identical procedures. The method avoided the need for any operative to be underneath the load other than final bolting once the landing had been positioned over the supporting fin plates; Continued: Tel: 0z0 8844 0940 Fax: 020 5793

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2 M E Hassell 14th December 2015 Post Incident Method Following the Incident and after intensive investigations into best practice for an alternative method of lifting, it was determined to proceed with a lift plan that involved tilting the landing past the fin plates An additional lifting frame was designed to be fixed to the landing with bolts that would facilitate the use of lifting eyes: The use of slings for lifting was substituted by chains attached to the eyes: A second winch was introduced and another hole made in the slab so the tilt of the landing could be carried out by raising and lowering of separate winches rather than taglines: The trapezoidal landings above the ground floor slab were installed in accordance with the original lift plan methodology as this was still considered to be the best practice although the use of slings was again substituted for chains attached to directly anchored lifting eyes. Future Methods for Site Lifting 1_ All members to be lifted will either have adequately sized holes that allow for the fixing of positive anchorages for lifting accessories or for alternative bespoke carriages; These will be identified during the design stage and advice obtained from the appointed person. 2_ The lifting operations are to be planned by a qualified appointed person for and not by site managers who may not have formal qualifications for lifting operations despite having extensive experience of lifting: A lift plan is to be completed using the CMF native lift plan procedure to ensure consistency and content: 3 Lifting plans together with any temporary works requirement or relevant design considerations are to be submitted to and approved by the Principal Contractor for projects before lifting commences:
4. All approved lifting plans be explained to the lift team by the appointed person to ensure the plan is fully understood and that all members of the Iift team are fully conversant with their respective duties or responsibilities: This is also to include any temporary work associated with the lift and/or important design considerations: 5_ After delegation of the lift plan to the lift supervisor, absence of this person through illness or other reason will require a re-briefing by the appointed person to the replacement and entire lift team before lifting resumes: In any event if the lift plan is in force for more than 90 days, a re-briefing of the lift team will be a requirement; Continued__ Ms lifting lifting lifting will

3 Ms M E Hassell 14th December 2015
6. If at ay stage the lifting operation becomes circumstances Or changes OpetneoocaeenvieoncoenrortisgcV bill Uefoeesseo as it is safe to do SO. The appointed lifting will cease as soon implement the person will then assess the changes and modification within the lift plan before resumes_ Stracariethe slinger signaller must not deviate fromresing geepreseribed i@Ftachments and accessories defined in the lift pian andgchedlesribermon lifts. Any deviation will cause lifting to cease until the assessed the implications. approved person has hope thls addresses your concerns in relation to CMF Limited; If further Information please do not hesitate to contact me' you require any

Dear Madam, INQUEST CONCERNING THE DEATH OF RICHARD LACO ON 6 NOVEMBER 2013 write this letter in response to the Prevention of Future Deaths ("PFD") report issued on 22 October
2015. In the PFD report, reference was made to the planning of two lifts of staircase landings at basement level in Core D at the Francis Crick Institute ("the Crick") by the specialist contractor, CMF Limited ("CMF"), and the review of those lifts by the principal contractor, Laing 0'Rourke_ This letter addresses the concerns raised and sets out the actions that have been taken by Laing 0'Rourke since the accident_ First and foremost, Laing 0'Rourke would like to make clear from the outset that nothing said in this letter should be taken as in any way diminishing our distress at the death of Richard Laco in the incident on 6 November 2013. It is our paramount objective to formulate and implement a safe work place for all. Laing 0'Rourke deeply regrets the incident in which Mr Laco lost his life Such incidents serve to strengthen our resolve to maintain a safe working environment for everyone on our projects The Directors insist that safety is at the forefront ofthe business To that end, Laing O'Rourke launched Mission Zero in October 2010,a campaign which built on previous initiatives with the ultimate aim of eliminating all work related accidents from our operations by 2020. The Core D basement lifts at the Crick CMF was employed by Laing 0'Rourke to be the architectural metalwork subcontractors at the Crick CMF had the responsibility for designing, planning and executing its works, including the of landings and staircases in the cores_ CMF and their Appointed Person for Lifting were responsible for producing relevant risk assessments and method statements for its works and a Lift Plan for its operations. In accordance with Laing 0'Rourke' s Construction Phase Health, Safety and Environmental Plan for the Crick, CMF' $ Risk Assessment and Method Statement "RAMS") for the staircase works was reviewed by the Laing 0'Rourke Package Manager, Andy Fright; whilst CMF's lift plan was initially issued to Andy Fright; who referred it to the 0'Rourke Appointed Person for Lifting at the Crick, Mike Mungroosingh. Paul Hughes took over from Mike Mungroosingh as Laing 0'Rourke's Appointed Person for lifting on 25 July 2013 and reviewed revisions B and C of the CMF Lift Plan: As the Package Manager Andy Fright's responsibilities included checking that CMF'$ documentation was complete and correct: This included ensuring that the scope of works was correct, that it was properly defined and that the sequence of works was correct_ Andy Fright also checked to see how the work interfaced with other trades on site and checked that the CMF employees had the satisfactory competence, certificates and qualifications for the work: He also looked at the equipment CMF would use, the resources available on site and any emergency provisions necessary to complete work: He ensured that the client's quality specification for the landings and staircases had been met: Bridge Place, Arichor Boulevard, Admirals Park, Crossways. Dartford, Kent, DA? 6SN tel: ,44 (011322 296200 fax: +4 (0) 1322 296262 wcb: wwvw laingorourke com Runstemx] Oxicu: As ftovo Foestrativ} Murtbor 4222545 Rngeeeu {ntana lifting lifting Laing

Lamddnduna As part of his Package Manager function, Andy Fright referred specialist documentation involving CMF's lifting operations to the Appointed Person for Lifting at 0'Rourke to review_ As will be appreciated, giving evidence can be difficult, particularly in the context of an inquest: This is not a forum which employees of Laing 0'Rourke are used to, but the witnesses called at the hearing endeavoured to assist and were transparently straightforward. 0'Rourke trains its employees rigorously and is confident that its people have suitable skills and expertise for their respective roles The CMF Lift Plan, as reviewed by Laing 0'Rourke's Appointed Person for Lifting, utilised positive attachments on landings and staircases when installing these sections into the stair cores_ Photographs in the CMF Lift Plan, added at Laing O'Rourke's request; showed that landings would be stropped through eye bolts, which are positively fixed to the landing and choked. Staircase sections were fixed with a lifting jig: These sections, once positively attached, would be installed into the stair cores using a block and tackle to manipulate into place onto the fin plates in the case of 'landings, or onto the installed landings in the case ofthe stair flight sections. The use ofpositive attachments provides for a safe system of work when a load is lifted up and manipulated into place above the ground regardless of any variation in the shape of the component: Paul Hughes, 0'Rourke's specialist Appointed Person for Lifting, asked CMF to add some clarifications to its Lift Plan in August 2013 He asked that CMF uprate its winch to 2 tonnes to increase the factor of safety. In particular, at the request of Paul Hughes, photographs were added to the Lift Plan Rev C demonstrating the positive attachments and the chain block/block and tackle for adjusting the position of the staircases and the landings for their installation in cores A to F As he made clear at the inquest, Paul Hughes's view, supported by Mark Shearon (HM Inspector Health & Safety Executive), was that the lift plan is a working document and the use of photographs improves the understanding of the crew when briefing them on the work Laing 0'Rourke approved the CMF Lift Plan on the basis that positive lifting attachments would be used for the and installation of the landings (and staircases): As stated Paul Hughes at the inquest, if CMF felt that it needed to deviate from the lift plan in force, for any reason, during the installation of landings or staircase sections, the operation should have stopped immediately and further planning undertaken. Although the PFD report states that "there Was no instruction to stop the procedure if positive fixings_could not be achieved"_ 0' Rourke only approved CMF' s lifts on the basis that positive attachments were in use as had been the case in all the previous stair cores. No approval has ever been given by 0'Rourke to CMF to lift without positive attachments. 0'Rourke was not told about CMF's departure from the agreed safe system of work No approval was given to CMF by Laing 0'Rourke to deviate from the agreed lift plan. If principles in the lift plan could not be complied with by CMF, then the plan needed to be re-addressed, re-written and re- submitted to 0'Rourke. This was anticipated by CMF'$ lift plan itself, which at page 16 of Revision states, "This document must be regularly reviewed by the CMF site team/AP" , that is the CMF Appointed Person for lifting, "and as required the LOR appointed person. Should any changes be required WORKS WILL NOT BE CONTINUED UNTIL APPROVAL OF ALL AUTHORISED PERSONS IS OBTAINED IN WRITING, THIS DOCUMENT WILL REQUIRE UPDATING TO REFLECT ANY CHANGES AGREED TO" . Laing Laing lifting lifting Laing lifting lifting by lifting Laing had lifting Laing lifting Laing ' the Laing

Drorouarn As stated by Paul Hughes, the absence ofa positive lifting connection is a stop point; when units and manipulating a load in the air rotating into place, there must be a positive connection in order to ensure safe lifting: This principle remains the same with all lifts and shapes_ With hindsight, as the landings in the basement of core D were a different shape and were to be lifted upwards past the fin plates, before lowered downwards onto the fin plates in the core, CMF should have considered an additional note in the plan for this lift: It is relevant, however, that the principle behind the method of lifting agreed by Laing 0'Rourke in November 2013 required positive lifting attachments to be applied to a load lifted into the air and manipulated into place. This approved method provided a safe system of work, notwithstanding that; with hindsight, additional clarifications could have been, and eventually were, made to the plan by CMF, to account for the shape of the landing and the upward lift. The design of the method and lift plan was the specialist contractor's responsibility. As the principal contractor Laing 0'Rourke ensured that any such plan was safe by insisting on the use of the positive attachments Action taken by Laing 0'Rourke following the accident to prevent future deaths On 8 November 2013 the Laing 0'Rourke Project Leader at the Crick, Bob Williams, circulated an email reminder that, following the Project Director Jonathan Abbott's team talk, all packages were to undergo a full review of all method statements and lifting plans to ensure that they were current and reflected the actual install methods. This email also indicated that all Contractor Managing Directors were required to visit the site, in order to undertake a personal presentation to their respective teams on what was required of them at the Crick: All lift plans were suspended until they had been reviewed and approved by 0'Rourke_ briefing of the accident and a health and safety briefing were conducted on 11 November 2013. Work recommenced at the Crick on 11 November 2013, save for the fact that core D remained closed for the official investigation: In November 2013 0'Rourke requested that CMF provide a detailed RAMS for the removal of the damaged landings in core D. Laing O'Rourke stressed to CMF that all landings and staircases must be rigged with positive attachments. In December 2013 CMF started work on the revised RAMS and Lift Plan for the remaining stair installation, as well as testing its positive lifting attachments_ Approval was granted by the HSE for the removal of the damaged landings from core D on 17 January
2014. On 23 January 2014 CMF were instructed to undertake a safe start workshop and to explain their method of installation for the next phase_ The revised CMF Lift Plan, dated 9 April 2014,is tailored for the installation in the basement in core D and has been reviewed by the HSE: This revised plan again requires positive lifting attachments to be rigged to the steel landings and the staircases_ The basement landings and stairs under the ground floor slab in core D were successfully installed by CMF in May 2014_ Following this tragic accident Laing 0'Rourke and the client have insisted on even greater use of health and safety measures_ The CDM (Construction Design and Management) Co-ordinator has been required to be on site twice a month instead of once a month since 6 December 2013. On 21 January 2014 Dean Pettinger of Laing 0'Rourke was appointed as an additional Appointed Person for Lifting and was specifically directed to focus on all lifts carried out by CMF, even though all those lifts were the primary responsibility of CMF_ As an additional safeguard, Laing 0'Rourke now requires that activity within a RAMS, is formally signed off on the RAMS and Lift Plan by the 0'Rourke Appointed Person for lifting: The same formal acknowledgement is now required by the 0'Rourke Temporary Works Co-ordinator, for any temporary works. Authorisation the appropriate specialist person has always been required lifting lifting being lifting again Laing Laing lifting lifting Laing Laing from

Latnd onouma during the review process, for example, where the contractor' $ work involves However, this step has now been committed to writing and the specialist person's acceptance, whether it is the Temporary Works Co-Ordinator or the Appointed Person for Lifting, is evidenced on the documentation. Safety Alert was issued to all Laing 0' Rourke workplaces, through both the Management and Health and Safety functions, for implementation on 28 November 2013 emphasising the requirement that lifting operations on a project must include the sign off by the 0' Rourke Appointed Person for as set out on the Revised Method Statement Approval Sheet T6-D. This Safety Alert emphasises that all contractors' Lifting Plans written by specialist contractors, such as CMF, must, as well as having been risk assessed, planned and approved by the sub-contractor's Appointed Person for Lifting, be approved in writing by the 0'Rourke Appointed Person for Lifting: Furthermore, each project team is now required to review activities carrying increased risk on monthly basis and schedule a 'Planned vs Actual' assessment for these activities. As part of the 'Planned vs Actual' assessment a manager will review the accepted method statement for an activity on a more formal basis and will then review with the team carrying out the work whether there has been any change in circumstance which may have an impact on the plan, or whether improvements could be made to the method in order to make the operation safer. As stated above, O'Rourke strives to learn lessons from continuous review of all its operations and, especially, from distressing incidents involving personal injury. Many steps have been taken at the Crick designed to ensure that tasks are subjected to heightened scrutiny and control to minimise the risk that safety considerations could be overlooked in planning and executing work on the site. O'Rourke reiterates its deep regret at the death of Richard Laco in this accident The company takes this fatal accident very seriously and personally, and is driven to re-double its efforts to maintain a safe working environment throughout its operations: