P – You are the director of Pyecroft Engineering?

SW – I was at the time of the incident.

P – You worked as a welder and fabricator next to Euromin Ltd?

SW – Yes.

P – You did lots of welding jobs for Euromin including repairing machinery and damage to ships?

SW – Yes.

P – Do you have a copy of an invoice dated 11 th February 1998 for welding 2 lifting hooks to the excavator grab?

SW – Yes.

P – You issued the invoice shortly after you had completed the work?

SW – Yes.

P – Do you remember being asked to do the work by Roger Grant?

SW – Yes.

P – How did you know where to weld the hooks?

SW – I was shown by Roger Grant.

P – Were you worried about anything?

SW – Yes I was worried that the chains could be damaged.

P – How?

SW – If the grab closed on them.

P – What else?

SW – That it wouldn't be as effective.

P – What was the reply?

SW – He said it would be O.K.

P – You arranged a welder to do the job?

SW – Yes.

P – What did you think the hooks would be used for?

SW – Lifting equipment.

P – Does the welding have to be tested?

SW – Yes.

P – Can a firm test its own welding?

SW – No. I told him the weld had to be tested by someone else.

P – Did you deal with anyone but Roger Grant?

SW – No.

P – Do you know if the testing was done?

SW – I have no idea?

P – How important is the testing?

SW – Very important: it has been known for welds to fail if they have not been tested by a competent person. The law states that the welding must be tested.

D – Is the testing done to a load greater than the safe working load of the machine?

SW – Yes.