Endnotes

  1. Exhibit 28 – Written submission of the United Firefighters Union; Written submission of the Volunteer Fire Brigades Victoria
  2. Exhibit 1 – Statement of Craig Lapsley, para. 100; Exhibit 29 – Second statement of Steven Harkins, para. 38
  3. Exhibit 1 – Statement of Craig Lapsley, para. 128
  4. Lapsley T65:8-13
  5. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 30
  6. Exhibit 29 – Second statement of Steven Harkins, para. 40
  7. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 12; Exhibit 29 – Second statement of Steven Harkins, para. 40; Exhibit 29 – Second statement of Steven Harkins, annexure 2
  8. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 30 attachment, Report of Hazelwood hand injury (FSC.0011.001.0034)
  9. Exhibit 10 – Statement of Steven Harkins, para. 51
  10. Exhibit 28 – Written submission of the United Firefighters Union, p. 65
  11. Exhibit 28 – Written submission of the United Firefighters Union, para. 3.2.8
  12. Exhibit 1 – Statement of Craig Lapsley, para. 175 attachment, IMSS Report to Country Fire Authority – The Morwell Open-Cut Mine Fire 12-19 October, 2006 (CFA.005.001.0209)
  13. Exhibit 38 – Statement of Paul Torre, para. 11
  14. Exhibit 48 – Expert report of Donald Campbell, p. 3
  15. Lester T1139:3-11
  16. Exhibit 38 – Statement of Paul Torre, para. 11
  17. Lapsley T694:2
  18. Exhibit 1 – Statement of Craig Lapsley, para. 175 attachment, IMSS Report to Country Fire Authority – The Morwell Open-Cut Mine Fire 12-19 October, 2006 (CFA.005.001.0209) p. 30
  19. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 11
  20. Lapsley T682:27 – T684:14
  21. Exhibit 24 –Statement of Doug Steley; Written submission of the Volunteer Fire Brigades Victoria
  22. Exhibit 24 – Statement of Doug Steley, attachment DS-1
  23. Exhibit 24 –Statement of Doug Steley, para. 34
  24. Exhibit 1 – Statement of Craig Lapsley, para. 98 attachment, hand-written Incident Action Plan (CFA.0007.001.0001); Exhibit 10 – Statement of Steven Harkins, annexure 14
  25. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 10
  26. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 11
  27. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 11
  28. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 11 attachment, draft Regional SOP – Latrobe Valley Open Cut Coal Mines – Response to fires (version 7a) (FSC.0011.0001.0133)
  29. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 14
  30. Lapsley T698:1-18
  31. Exhibit 26 – Supplementary statement of Craig Lapsley, paras 15 & 16
  32. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 17
  33. Exhibit 1 – Statement of Craig Lapsley, para. 128
  34. Exhibit 26 – Supplementary statement of Craig Lapsley, paras 19-21
  35. Exhibit 28 – Written submission of the United Firefighters Union, attachment 5.1.22
  36. Exhibit 28 – Written submission of the United Firefighters Union; Written submission of the Volunteer Fire Brigades Victoria
  37. Lapsley T708:3-11
  38. Exhibit 28 – Written submission of the United Firefighters Union, attachment 5.1.14
  39. Exhibit 48 – Expert report of Donald Campbell, para. 18
  40. Exhibit 13 – Statement of Robert Dugan, annexure 2, p. 11
  41. Exhibit 12 – Mine Fire Instructions, p. 18
  42. Harkins T731:17-31
  43. Exhibit 29 – Second statement of Steven Harkins, annexure 2
  44. Occupational Health and Safety Act 2004 (Vic), s. 21
  45. Exhibit 70 – Statement of Leonard Neist, para. 19
  46. Exhibit 83 – Letter from VGSO dated 10 June 2014
  47. Exhibit 83 – Letter from VGSO dated 10 June 2014
  48. Exhibit 83 – Letter from VGSO dated 10 June 2014
  49. Exhibit 31 – Statement of Robert Kelly, para. 39
  50. Exhibit 31 – Statement of Robert Kelly, para. 43
  51. Kelly T783:16-29
  52. Exhibit 28 – Written submission of the United Firefighters Union, pp. 14–24
  53. Exhibit 28 – Written submission of the United Firefighters Union, pp. 24–26
  54. Exhibit 28 – Written submission of the United Firefighters Union, pp. 25 & 26, paras 3, 6, 9 & 12
  55. Exhibit 28 – Written submission of the United Firefighters Union, attachment 5.1.26
  56. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 24
  57. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 25
  58. Exhibit 26 – Supplementary statement of Craig Lapsley, paras 24–27
  59. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 26
  60. Exhibit 26 – Supplementary statement of Craig Lapsley, para. 26
  61. Exhibit 28 – Written submission of the United Firefighters Union, attachment 5.1.32
  62. Exhibit 28 – Written submission of the United Firefighters Union, attachment 5.1.32
  63. Second written submission of the Victorian Government, 18 June 2014, paras 4.21 & 4.24
  64. Exhibit 28 – Written submission of the United Firefighters Union, p. 25, para. 2; attachment 5.1.26
  65. Exhibit 28 – Written submission of the United Firefighters Union, p. 25, paras 4 & 5; Exhibit 15 – Statement of Lawrence Jeremiah, paras 24 & 87; Exhibit 22 – Statement of Robert Barry, para. 15
  66. Exhibit 84 – Statement of Steven Warrington, para. 29
  67. Exhibit 22 – Statement of Robert Barry, para. 30.2