Samuel Clarke

Response to the Coroner’s Report

Following the inquest relating into the death of Samuel Clarke, which occurred on the
construction site at 1 Bank Street, Canary Wharf , three issues were raised by the Coroner
and set out in the ‘Prevention of Future Deaths report’ received on 22™June 2018.

The purpose of this document is to provide an overview of the security arrangements
employed across Canary Wharf's construction projects to explain measures taken to prevent
unauthorised entry and to respond specifically to the three concerns raised by the Coroner in
the report

Overview of Security Arrangements

Canary Wharf Contractors (CWCL) place considerable importance on health, welfare, safety
and the security of its sites. Requirements for all projects follow and in most cases exceed
the standards set out in the relevant construction legislation and associated HSE guidance.
In relation to security, our projects employ qualified and industry accredited security
companies to manage its sites. The implementation of site security procedures is overseen
by CWCL project managers. Procedures are tailored to the respective projects but in all
cases significant security measures are employed in order to deter, identify and locate
intruders with the aim of ensuring their safety and the protection of the site. Measures
include the following:

1. The site perimeter is secured by a plywood hoarding, 2.4 metres in height in line
with industry requirements. The hoardings are also fitted with a system of wires
which when broken, offer a visual indication to patrolling security staff that the
fence may have been scaled.

2. CCTV is in operation across the Canary Wharf Estate, around the perimeter of
the site boundary and within certain areas of the project. The CCTV, pertinent to
each site, is monitored by a dedicated security guard located within the project
and relayed back to an external control room. The guard works in conjunction
with another security guard also based on the site.

3. Projects have a security presence 24/7. Security guards carry out various
functions including patrols of the site and welfare/office areas, monitoring of the
CCTV, managing visitors, notifying senior management of any incident as
appropriate and initial liaison with emergency services.

4. Within each site certain areas are secured to deter and restrict Intruders from
entering. For example, stair cores leading to the top of the building; crane bases
to prevent intruders climbing to the top of the tower cranes and barriers
surrounding excavations and trenches.

5. Various patrol validation points are located within the site boundary. During the
regular patrols the security guards are required to swipe these points to
demonstrate that they have patrolled the associated areas. The patrols are
monitored to ensure they are completed properly. As a project evolves additional
patrol check points may be introduced, dependent on the size and complexity of
the site layout.

6. Where there is a risk of fall from height, suitable scaffold handrailing or edge
protection guarding is installed in accordance with requirements set out in Work
at Height Regulations 2007 and relevant industry standards.

7. The projects have suitable and sufficient lighting to illuminate safe pedestrian

access and egress and traffic routes. Additional task lighting is also used when
works are in progress.
Canary Wharf Group has recently obtained a high court injunction (Canary Wharf
Investments v Brewer [2018] EWHC 1760 (QB) (23 February 2018)) covering the
Canary Wharf Estate. Breach of the court order may constitute contempt of court
and result in fine or imprisonment. Notices are displayed around various locations
on the estate, warning that the injunction applies to any person trespassing in
breach of the orders. This measure seeks to deter and protect individuals who
may seek to gain unauthorised access to sites.

Following Samuel’s death a review of the project was conducted by the HSE Inspector
Sharon Boyd. The Inspector's review included the fall prevention measures, the site
perimeter, access entry hardware, the general site layout and the security procedures. The
Inspector was generally satisfied with the site arrangements and controls implemented. A
meeting was convened by the Inspector with the project security provider which was
attended by Canary Wharf Groups Head of Security. The meeting discussed the procedures
to ensure clarity relating to the protocols in the event of trespassers. Following this review
meeting, amendments were made to the security procedures to ensure clear protocols
across all projects in the event of trespassers.

As part of the procedural review, Canary Wharf Group has engaged with the Metropolitan
police for specific guidance, in the event of persons being identified as entering a project.
The Metropolitan Police have informed Canary Wharf Group that their deployment to
construction sites will be dependent on the individual circumstances and the dynamic risk
assessments of the officers attending or, if it is more serious, the local Duty Inspector.

Response to the Coroner's Concerns

Please find below a response to the matters of concern raised within the Coroner's
Prevention of Future Deaths Report

Concern 1 - Turnstile height.

During the inquest it was stated that the gap under the turnstile where Samuel accessed the
site had been reduced by 5cm (from 30cm to 25cm) following his death. This was an
incorrect estimate as the gap had in fact been reduced by 10cm (from 30cm to 20cm) by the
introduction of a robust plywood ramp spanning the entire base of the turnstiles so as to
raise the ground level. The photo 1 below showing the reduction in gap was sent to the HSE
(inspector as a sufficient control measure to prevent similar unauthorised
access. The inspector confirmed receipt and required no further action.

The turnstiles are located within an area where CCTV is in operation. During normal working
hours the entrance is used by the entire workforce to enter and exit the project, monitored by
the construction security office which is situated adjacent to the turnstiles. Following
concerns raised at the inquest, a further review of the turnstile was undertaken. As a result,
at the end of each day shift, temporary solid panels are installed to the inside face of the
turnstile pods aimed at preventing any unauthorised out of hours access to the site via this
route. See photo 2 below. This issue does not affect any other existing projects but on future
projects where access to site is via a turnstile direct from public realm, similar security
measures will be adopted.

CWCL undertook a review of the access control entry points and the site perimeters across
all of its projects to identify any potential areas where intruders could access the projects.
This has resulted in the gaps at the base of delivery gates also being reduced.

Photo 1— Reduction in gap

Photo 2 - Photo taken from inside the site showing a turnstile without the demountable panel

installed and a turnstile with the demountable panel in place.
Concern 2 —- Company Contingency Plan

Following Samuel's death, site instructions have been reviewed and amended to clarify the
action to be taken in the event of trespass and to ensure personnel are not put at risk. The
Company’s security procedures, in terms of communication and escalation to the
Emergency Services, have been amended accordingly. A briefing has been held with all
construction security guards to ensure the updated procedures are understood. These
instructions outline clear roles and responsibilities for the communication and escalation
processes for the Canary Wharf Estate security provided by Canary Wharf Management Ltd
(CWML) as well as for the security companies engaged by Canary Wharf Contractors Ltd
(CWCL) to provide site security.

e The security procedures include instructions for a search and seek procedure for a
trespasser by the site security provider. This may require the site team to escalate an
incident to CWCL project management and the construction security control room.

e The security companies can call upon a roaming supervisor to assist with a search
and to seek further guidance if required.

CWML security staff can assist CWCL site personnel in response to trespass activity to
avert a risk to life or to prevent serious injury. In these circumstances the CWML security
staff may enter the site at the invitation of a member of CWCL management or their
nominated representative. This process is reliant on a nominated member of CWC staff

4

responding to a call and attending site prior to the plan being implemented. A safety
briefing will be conducted detailing required Personal Protective Equipment, which will be
provided by CWCL and site specific hazards. Any recommended control measure must
be in place before any deployment of CWML security staff commences. They will be
accompanied on site at all times by a member of CWCL site security or management.
The final decision as to entry onto a CWCL construction site will rest with the CWML
Security Duty Manager who must satisfy themselves that appropriate measures are in
place to maximise the safety of security staff deployed. Security patrols must remain
within the safe areas and (without additional protection measures) cannot venture
beyond safety barriers or into hazardous areas where risk to life could occur in
contravention to our duty of care. The following table outlines the specific actions to be
taken by the construction security providers and the Canary Wharf Estate security in
terms of communication and escalation.

Table: Escalation Protocol for Site Trespass

Action in priority order} | Responsible | Accountable
Contact the police CWCL security CWCL Site This applies In every case of
vla the 999 system provider Manager trespass onto a construction site
regardless of whether the person/s
are on site or have left.

Trespass by unauthorised
person/s onto a CWCL
construction site

Call the Estate
Control Centre on
020 7418 2606
Call the Estate
Contro! Centre on
020 7418 2606

Managing Director
— Security

Site security has not been
breached but a person/s Is
suspected of preparing to do
so or attempting to do so.

CWCL security
provider

Managing Director

If there is any suspicion that an
Intruder may have entered a site
undetected In the interim period
then the Estate Contro! Centre will
be responsible for contacting the
Police

Head of Security -

CWML

Estate Control
Centre to warn other
CWCL sites

ECC Control

Head of Security —
Centre Manager | CWML

(incident detected by CWCL
site security)

Estate Control
Centre to deploy
CWML resources to
Investigate

ECC Control
Centre Manager

Site security has not been
breached but a person/s Is
suspected of preparing to do
80 or attempting to do so.

(incident detected by CWML
security)

Estate Control
Centre to deploy
resources to
investigate

ECC Control
Centre Manager

Head of Security -
CWML

if there is any suspicion that an
intruder may have entered a site
undetected in the interim period
then the Estate Control Centre will
be responsible fer contacting the
Police

If confirmed
attempt/preparation
to breach site
security to warn
other CWCL sites

ECC Contro!
Centre Manager

Head of Security —
CWML

Concern 3 - Torches used by the security guards

The torches used by the security guards during night time patrol were Maglite 2 Cell torches.
These torches are designed for harsh environments and used by the emergency services.
Although they are believed to be sufficiently adequate and appropriate for night time patrols,
the security guards now use a more powerful INFRAY flashlight, which has a beam distance
of 240 metres and 800 lumens.

Furthermore certain areas of the projects, such as walkways are constantly illuminated.
Following the incident a lighting review was conducted to ensure all appropriate areas are lit.