Expert Witness Report

Plaintiff: Ms. Taylor Swift

Defender: MTB CARPENTRY & CONSTRUCTION PTY LTD

Prepared by: Johnson Chang (SID:13850502)

Partner: Jiansong xu (SID: 13654872)
Dated: 11th November 2023
LEAD CONSULTANTS PTY LTD
1. Executive summary

I, Johnson Chang, am preparing an expert report on behalf of Ms. Taylor Swift for submission
to the Supreme Court of Queensland, serving as an expert witness concerning driveway
damage and coating peeling in a residential setting.
On the grounds of the following factual evidence:
1. Thickness of the driveway concrete slab
2. Tensile strength of the steel reinforcement
3. Space of concrete cover
4. Control joints
5. Loads applied to the driveway concrete slab
6. Wal painting standards
7. Proper wall sarking
8. Proper of sill flashing
9. Pipes leakage
I reach the conclusions that:
1. the crack in the driveway concrete slab exceeds the standard tolerance and is deemed to be
severe.
2. the crack in the driveway concrete slab is due to the lack of provision of the concrete joint
and inadequate concrete cover.
3. the growth of mold in the walls is caused by the damaged sarking behind the walls.

the expert’s resume is attached in the appendix to demonstrate the expert’s experience and
knowledge in the relevant area. The literature used to support the decision making is also
attached to showcase the detailed process. Moreover, the appendix also includes a detailed
explanation of glossaries occurred in the report to facilitate judge and juries’ understanding.
2. INTRODUCTION

Addressed to The Supreme Court of Queensland

The expert Johnson Chang (LEAD CONSULTANTS PTY LTD)
1/38 Pacific Avenue, Miami, QLD 4220
On behalf of Taylor Swift (hereinafter " Taylor ");
21 Northwestern Court, Varsity Lakes, Qld 4227
Defendant: MTB CARPENTRY & CONSTRUCTION PTY LTD
(hereinafter " MTB LTD");
ABN 70603318476
Commission: The BOND LEGAL

3. PURPOSE OF REPORT
3.1 THE PURPOSE OF THIS REPORT IS TO PROVIDE AN EXPERT
OPINION TO ASSIST THE COURT IN UNDERSTANDING:
A) What is expected of a competent and qualified contractor exercising due
consideration, diligence and skill;
B) What happened that caused the failure (driveway damage, wall coatings
peeling off)
C) Whether the contractor did something or failed to do something, that led to
the quality failure (driveway damage, wall coatings peeling off)
D) The consequences flowing or led to by the contractor’s performance; and
E) Whether the contractor’s performance lived up to the standard expected of
a competent and skilled provider.

4. EXPERT CURRICULUM VITAE

Enclosed in the annexure as ‘Annexure A - Curriculum Vitae’, you will find a comprehensive
curriculum vitae outlining my employment history in relevant positions, my publications,
related studies, and professional qualifications.

5. MATTERS UPON WHICH MY OPINIONS ARE BASED

A) Background: PhD in concreting performances;
B) Experience: Over ten years as a registered builder and concreter;
C) Consultancy: Over five years as a building consultant specializing in concrete
problems;
 D) Inspection: Conducted a property inspection on 1st September 2023 at 09:00;
E) Document Review: Reviewed documents as listed below under 'Documents
Reviewed';
F) References: Adhered to the Building Code of Australia (BCA), Australian
Standards (AS), and other relevant construction performance requirement documents,
as specified below under 'Documents Reviewed'.

6. DOCUMENTS REVIEWED
• Copy of the signed contract between the owner, Taylor and the builder, MTB LTD
on 1 May 2022; and
• Copy of the construction plan and drawings provided by the MTB LTD; and
• Copy of the original sales contract provided by the owner, Taylor, and
• Standards & Tolerances Guide issued by the Queensland Building and Construction
Commission;
and
• AS 2870-2011 the classification of damage to concrete floors; and
• AS 3600-2018 Concrete Structures; and
• AS 4671:2019 Steel Reinforcing Materials; and
• AS 4000-1997 General conditions of contract

7. MATERIAL FACT
7.1 BACKGROUND INFORMATION
• On 1 May 2022, MTB CARPENTRY & CONSTRUCTION PTY LTD signed a
contract with Ms. Taylor Swift, MTB CARPENTRY & CONSTRUCTION PTY LTD
is supposed to build a driveway for Ms. Taylor Swift within 1 month, the quality
guarantee period is 12 months. The contract also included applying coating to the
interior walls of the property.
• On 7 May 2022, MTB CARPENTRY & CONSTRUCTION PTY LTD confirmed
the deposit, and the project formally started.
• On 5 Jun 2022, MTB CARPENTRY & CONSTRUCTION PTY LTD finished the
whole project and it is handed over to Ms. Taylor Swift.
• On 10 Jun 2022, Ms. Taylor Swift pays off all the fees, and the contract is end.
• On 16 Dec 2022, Ms. Taylor Swift found that there were stripes of color difference
in the driveway, which was reflected to MTB CARPENTRY & CONSTRUCTION
PTY LTD. The company said that this was a trace of water passing through, and there
was no quality issue.
• On 1 Aug 2023, Ms. Taylor Swift discovered cracks in the original color area, and
informed MTB CARPENTRY & CONSTRUCTION PTY LTD on the same day to
activate the warranty terms to assist in repairs. The company was unwilling to repair
it on the grounds that it exceeded the warranty.
• On 12 Oct 2023, after heavy rain, Ms. Taylor Swift found that the original crack had
broken into two parts. At the same time, there is problem of coating peelings on the
 interior walls of the house. There were safety concerns, so she notified MTB
CARPENTRY & CONSTRUCTION PTY LTD again to handle it. The company was
responsible for the project representative resignation and refused to make any
subsequent comments on the matter. If she wants to repair it, it will be quoted on the
actual damage and pay for repairs.

7.2 DEFECTIVE PROBLEMS AND ISSUES

A) cracks are evident on the surface of driveway
B) 1.5 to 14mm width, 2-meter long’s cracking on the concrete slab.
C) the cracks in the driveway and walking steps exceed tolerance
D) coating peelings on the interior wall of the house

8. ASSUMED FACTS

1. Following my inspection and the perusal of various documents made

available to me I have made the flowing assumptions.
2. Crack developed in concrete can be due to the following factors: inadequate
thickness, the lack of control joints, excessive loads placed on the top,
inadequate concrete cover and substandard steel reinforcement.
3. Improper sill flashing and wall sarking, pipe leakage are possible factors that
can allow rainwater to seep into the structure, causing mold on the walls.
4. Ponding can happen after rains at the uneven concrete slab.

9. INSPECTION AND ASSESSMENT

I, the expert, conducted an inspection on 25th October 2023. The aim of this inspection was
to examine the issues of shrinkage cracking on the driveway and mold presence on the walls.

9.1 SHRINKAGE CRACK

9.1.1 Upon inspection of the driveway, cracking on the surface of the concrete was observed,
with the shrinkage clearly visible in the provided photographs.
 Figure 1 & 2: Evidence of Shrinkage Crack

9.1.2 The width of the crack was measured, ranging from 1.5 to 14mm, with a length of
about 2m near the driveway. According to the owner, the length of the crack seemed to be
increasing, prompting a follow-up inspection after one month, during which a 2mm
increment was observed as shown in the image below.

Figure 3 increased crack in the driveway concrete slab

9.1.3 Upon reviewing relevant standards, it was found that a crack is deemed acceptable if its
width is less than 1.5mm as per the guidelines of the Queensland Building and Construction
Commission (QBCC). Given that the crack ranges from 1.5mm to 14mm, it has exceeded the
stipulated tolerance. Additionally, the classification of concrete damage as outlined in
AS2870 indicates that a crack width ranging from 1.5 mm to 14 mm falls under the category
of severe damage.
 Figure 4 AS2870 Concrete Damage Category

9.1.4 based on my professional experiences, four common reasons that can develop crack in
concrete slab are:
1. insufficient thickness of the concrete slab
2. improper steel reinforcement and concrete cover inside the concrete
3. lack of concrete joints
4. excessive loads on the concrete slab
The above four causes will be assessed below.

9.1.5 regarding the cause 1, gauged by a measure tape, the thickness of the slab on the
driveway is roughly 154mm. The result meets the required specifications and standard of
Brisbane City Council which stipulates that household driveways slab be a minimum of
125mm thick. Therefore, the concrete has sufficient thickness to maintain its load bearing
capacity. The cause 1 does not apply for the concrete crack.
9.1.6 regarding the cause 2, figure 5 demonstrates the required concrete cover in different
types of exposure. Given that the driveway slab should be classified as B1 (see figure 6) and
the design strength for the slab is 25MPa, a minimum of 60mm concrete cover is required.
Ultrasonic testing method (see figure 7) is employed to determine the thickness of concrete
cover. One advantage of this method is that it uses sound waves to detect the concrete over
reinforcement bars. It can provide reliable results while not damaging the concrete slab. The
tests are conducted multiple times in order to obtain the unbiased result. In the end, by
averaging all the results, the average concrete cover is 45.67mm, that fails to meet the
minimum requirement in the standard.
 Figure 5 the required concrete cover in different types of exposure

Figure 6 exposure classification based on environmental conditions

Figure 7 Ultrasonic testing

In addition, proper concrete reinforcement can enhance slabs’ load bearing capacity and
distribute loads more efficiently. As shown in the figure 8, driveway, garage and industrial
floor slabs require 3000-4000 psi compressive strength (around 20 – 28 MPa). Samples of
broken reinforcement bars are tested in the laboratory. The yield strength of the
reinforcement bar is examined in a tensile test. As shown in the figure 9, the machine keeps
applying a pulling force to the sample at a constant rate to let the sample undergone physical
deformation. Meanwhile, data is measured including the force applied to the sample (stress)
and the observed deformation (strain). The data is used to create the stress-strain curve,
which can demonstrate some important properties of the sample including its yield strength.
As indicated in figure 10, the graph shows the yield strength curve of the test. After
calculation, it is estimated that the yield strength of the reinforcement steel bar in the
driveway concrete is about 24MPa, falling within the required range. An inadequate concrete
cover can lead to the corrosion of the steel reinforcement, then cracking of the concrete.
Therefore, inadequate concrete cover can be considered as one cause to the crack in the
driveway slab.

Figure 8 concrete compressive strength requirement

Figure 9 tensile test apparatus

 Figure 10 the stress-strain curve of the tested reinforcement steel sample

9.1.7 regarding the cause 3, concrete control joints are intentionally created to control
cracking caused by natural shrinkage of concrete. They tend to be placed in a predetermined
pattern such as straight lines. The design plan of the driveway concrete slab is shown below.
Places requiring concrete joints are indicated as © in the plan. Five expansion joints are show
in the plan. However, based on the results reported back from the ultrasonic test device,
only four joints are detected whereas one joint near the location of the crack (circled in red)
is undetected. That could indicate the absence of this joint before the concrete pouring. As
per AS3600, control joints should be provided at maximum 3 meters center. The absence of
the joint can leave about 5.4m distances between control joint 1 and 2, violating the
standard requirement in AS3600. Besides, it is observed that the slab in the circle presented
more severe crack than other parts of slab under the protection of joints.

Figure 11 The design plan of the driveway concrete slab

9.1.8 as for the cause 4 regarding the excessive loads exerted on the concrete slab, the actual
loads on the concrete slab should be measured, including all the possible weights on the
slab. It is assumed that the major loads the slab experiences are from the owner’s vehicle.
The weights of people could be omitted in this case since they were tiny compared with the
vehicle’s loads. Assuming the owner’s car is about 3000 pounds, through calculation, its
loads on the slab are about 13344N. therefore, given that the total area of the driveway is
about 10m2, the load per mm2 is 0.013(MPa). That is significantly smaller than 25MPa, the
design load of the driveway concrete slab. Thus, the cause 4 concerning the excessive loads
on the concrete slab does not hold.

9.2 Coating peeling in the interior walls

9.2.1 The provided photographs show coating peeling off on the interior walls of the house,
significantly impacting the owners' living experience.

Figure 12 & 13 & 14 & 15, Evidence of coating peeling on the interior walls of
the house

9.2.2 based on my professional experiences, four common reasons that can cause coating
pealing on the interior wall are:
1. coating is not provided by standard
2. lack in the integrity of wall sarking
3. improper sill flashings
4. pipes leakage in walls
The above four causes will be assessed in the following.
9.2.3 regarding to the cause 1, if the coating is not provided by standard, the coating may not
perform the good quality and may present various issues including peeling off. Based on
Australian Standard AS/NZS 2311:2017 Guide to the painting of buildings (see figure 16),
given that the walls in the house have plaster surface, it is required that three coats must be
applied to any bare plaster surface and first and last coat must be “back-rolled”, i.e. It must
have a roller finish. By cutting a small sample of coatings from the coated area and examining
its cross section under a microscope, three distinct lines are observed which represents three
layers. Additionally, by visual inspection, touch, and feel, the sample coatings are smooth and
uniform without distinct rough patches. Therefore, it could be concluded that the coatings
provided to the interior walls follow the standard.
 Figure 16 Australian Standard AS/NZS 2311:2017 Guide to the painting of buildings
9.2.4 regarding to the cause 2, the integrity of wall sarking is crucial for waterproofing the
walls, necessitating a thorough inspection to determine the root cause of the coating
peeling. We examine the interior of walls exhibiting coating peeling, documenting our
findings. Additionally, we establish control groups by inspecting some unaffected walls to
ascertain if wall sarking is a contributing factor to the problem. Upon inspecting the interiors
of all affected walls, it is discerned that most present damaged sarking, contrasting with the
control group where the sarking is intact, and no damage is present. Photographs of the
affected and unaffected wall sarking taken from the inspection are illustrated below.
 Figure 14 & 15 sarking of affected wall.

Figure 15 & 16 unaffected wall sarking

9.2.5 with regards to cause 3, improper sill flashing can lead moisture to ingress the walls,
causing the coating to peel off. Therefore, inspecting the sill flashing around openings can
shed light on potential causes. Our inspection covers 3 window openings in the house,
examining if they have proper sill flashing. The following results are obtained:
- First, all the sill flashings are present and remained intact.
- Second, all the flashings are installed with a slope to direct water away from the window to
outside.
- Third, multiple layers are used in each sill flashing to enhance its ability to prevent water
entering.
- Finally, all flashings are extended beyond the sides of the window frame with an overhang
to allow water flowing.
Moreover, the materials of sill flashings should be concerned since they can have significant
impact on their effectiveness and durability. Some samples of sill flashings from the site are
taken to the laboratory to receive tests. It is found out these flashings made of specialized
tapes are waterproof, corrosion resistant and compatible with local climate.
Therefore, the cause concerning the sill flashings does not hold.

Figure 17 & 18 & 19 sill flashings in window openings

9.2.6 concerning for cause 4, any leakage from pipes installed within the walls could spread
water throughout, trapping moisture and fostering mold growth, eventually causing coating
peeling off. With the owner providing a plumbing plan (see figure 20), we inspect the
specified regions, especially where the peeling is evident on the wall surface by using the
hole saw and drywall knife to create a small inspection opening.
 Figure 20 plumbing facility plan
An exhaustive check reveals no sign of leakage, eliminating pipe issues as a potential cause.
The photographs of plumbing facilities taken in the inspection are shown below.

Figure 21 & 22 & 23 plumbing facility inspections

10. EXPERT OPINION
10.1 crack in the concrete slab in driveway

10.1.1 based on the guidelines of the Queensland Building and Construction

Commission (QBCC), the crack is deemed acceptable if its width is less than 1.5mm.
given that the crack in driveway concrete slab ranges from 1.5mm to 14mm, it has
exceeded the stipulated tolerance.
10.1.2 with reference to AS2870, the crack width ranging from 1.5mm to 14mm
should be categorized as severe damage.
10.1.3 the thickness of the driveway concrete slab meets the specifications and
standard required by Brisbane City Council which requires 125mm minimum slab
thickness in the driveway. Thus, the concrete has sufficient thickness to support the
loads.
10.1.4 the concrete cover in the driveway concrete slab is 45.67mm, failing to comply
with 60mm concrete cover minimum requirement.
10.1.5 the yield strength of reinforcement bars is 24MPa, falling into the required
range of concrete compressive strength between 20 – 28 MPa.
10.1.6 one of the control joints is not detected by the ultrasonic test device. The
absence of the joint not only fails to comply with the concrete detail plan, but also
violates the standard requirement that allows 3 meters distance between joints at
maximum. It is also observed in the slab that the region with absence of the joint
showed more severe crack than other regions. Therefore, it is reasonable to consider
the absence of the joint as the cause of the crack.
10.1.7 as calculated, the estimated loads applied to the slab is about 0.013MPa,
significantly smaller than the design load of the driveway concrete slab. That means
the concrete slab is rigid enough to support loads on the top.

10.2 coating peeling in the interior walls

10.2.1 the coatings being provided to the interior walls follow the requirements stated in the
Australian Standard AS/NZS 2311:20. Also, by visual inspection, touch, and feel, the sample
coatings are smooth and uniform without distinct rough patches. That eliminates the issue of
off-standard coatings as the cause of coating peeling off.

10.2.2 most affected walls have damaged sarking. The improper sarking can allow water to
penetrate the building, leading to leak and growth of mold.

10.2.3 sill flashings in each opening are present and properly installed to prevent moisture
penetrating the wall. Besides, sill flashings made of specialized tapes are waterproof,
corrosion resistant and compatible with local climate, which meets the purpose of moisture
and leakage prevention.

10.2.4 no sign of leakage is detected in the pluming facilities behind the mold-affected walls.
That eliminates pipes issues as the cause of coating peeling off.

11 summaries of opinion

11.1 the crack in the driveway concrete slab exceeds the standard tolerance and is deemed
to be severe.

11.2 the crack in the driveway concrete slab is due to the lack of provision of the concrete
joint and inadequate concrete cover. MTB LTD may be liable for the provision of joints and
concrete cover during the construction of the property.

11.3 the peeling of coatings in the interior walls is not due to the off-standard coatings
provided by MTB LTD, therefore, MTB LTD is not liable for the damage in the interior walls.

11.4 the peeling of coating in the interior walls is caused by the damaged sarking behind the
walls. However, that is the service provided by another contractor rather than MTB LTD.
Therefore, the contractor which takes charge of the wall construction of this house should
take responsibility for the damage.

11.4 The opinion I have provided in this report is final.

11. DECLARATION

I, Johnson Chang of LEAD CONSULTANTS PTY LTD, confirm that:

• The factual matters stated in this report are, as far as I know, true; and

• I have made all enquiries considered appropriate; and

• The opinions stated in the report are genuinely held by myself; and

• The report contains reference to all matters I consider significant; and

• I understand my duty to the court and have complied with the duty.

This is the end of the expert report.

Please advise me if any further assistance with this matter or any explanation of
this report.

Yours sincerely,

LEAD CONSULTANTS PTY LTD

Sign ___________

Johnson Chang

Registered and Accredited Building Consultant

10 Nov 2023
ANNEXURE A – CURRICULUM VITAE

Johnson Chang
1/38 Pacific Avenue, Miami, QLD 4220
Phone: +61 7 5648 0800
Email: Johnson@leadconsultants.com.au

Professional Summary
Accomplished Partner at LEAD CONSULTANTS PTY LTD with a PhD in
Construction Management, and extensive expertise in concrete, timber, brick
walls, and building services. Demonstrates a strong background in project
management, contract administration, and dispute resolution. Has a history of
academic excellence complemented by published industry research and
recognized for outstanding performance during internship.

Education
PhD in Construction Management - Bond University, Jan 2018 - Aug 2021
Master's Degree in Construction Practice - Bond University, Jan 2016 - Oct
2017
Bachelor of Engineering Honours (Civil Engineering) - University of Sydney,
Jan 2012 - Dec 2015

Professional Experience
Partner
LEAD CONSULTANTS PTY LTD, 2021 - Present
Specialises in concrete, construction, timber, brick wall, and building services,
contributing to firm leadership and strategic direction.

Project Manager, Brisbane Project

Multiplex, 2018 - 2020

Intern
Multiplex, 2016 - 2017

Relevant Coursework and Learning Experience

* Building Structures
* Project Management
* Project Contract Administration
* Expert Witness & Dispute Resolution

Publications
* 2018: "DIY Retaining Wall Construction: A Step-by-Step Guide," The
Construction Index.
* 2019: "House Inspections: An Essential Checklist," The New York Times.
* 2020: "Advanced Methodologies for Construction Site Analysis," Building
Design + Construction.
* 2021: "A Comprehensive Overview of Construction Industry Evolution and
Prospects," Construction Week.
NNEXURE B – GLOSSARY OF TERMS

Joists:

Structural elements used in building construction, typically in floors or ceilings.

Joists are horizontal supports that span open spaces, often between beams or
walls, and are capable of bearing the load of the floor or ceiling above.

Shrinkage Crack:

A type of fissure that occurs in concrete or similar materials as they cure and dry.
Shrinkage cracks are caused by the reduction in volume due to loss of water
content, and they typically manifest as thin, linear cracks on the surface of the
material.

Wall Sarking:

A layer of material attached to the frame of a building beneath the exterior wall
covering. Wall sarking serves several functions including acting as a moisture
barrier to improve water resistance, providing thermal insulation, and enhancing
the overall structural integrity of the wall system.

ANNEXURE C – BACKGROUND INFORMATION

Do Later