Its both. That recorder's mic-input stage is unable to support microphones with a sensitivity of 40mV/Pa when things get loud.
If he were using mics that WERE fully capable of handling high SPLs AND had a sensitivity that high, the recorder's input stage would most certainly clip before the microphone does, unless the output was sufficiently padded down.
A couple come to mind:
Sennheiser MKH 800 TWIN: 40mV/Pa, 136dBmax SPL, 4V max output
DPA 4006-TL: 36 mV/Pa, 146dB max SPL, 8V RMS max output
I'm sure there are others.