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.