Mike Holt Basis for Determining Emails Redactions Applied.pdf

1.  Basis for Determining "Insufficient Information on Adverse Health Effects"
External Consultation or correspondence with HUD, contractors, experts or peer
reviewers
27 November 2020
From:  Vanessa James

Sent:  Friday, 27 November 2020 2:29 pm  Withheld under
To:
Peter Cressey
Section 9(2)(a) of the
Subject:
RE: Meth report
Official Information Act 1982

Yes, that would be great, as it wil  be a change from our current terminology. Cheers

From: Peter Cressey
Sent: Friday, 27 November 2020 2:18 pm
To: Vanessa James
Subject: RE: Meth report

First-hand – smoking or other intended intake
Second-hand – unintended exposure to smoke or manufacturing process
Third-hand – unintended exposure to residues of intake or manufacture

Probably a good idea to be very explicit about this. I wil  add a deﬁnition.

From: Vanessa James

Sent: Friday, 27 November 2020 12:33 p.m.
To: Peter Cressey

Subject: RE: Meth report

We’ve talked about exposure to low levels of methamphetamine residue. Looking at
your advice below, it seems the appropriate terminology should be third-hand
methamphetamine exposure?
Is that correct and if so how would you deﬁne this?

From: Peter Cressey

Sent: Friday, 27 November 2020 10:46 am
Withheld under
To: Vanessa James
  Section 9(2)(a) of the
Subject: Meth report
Official Information Act 1982

Hi Vanessa

Thanks for the discussions earlier. Below is the current wording of the
summary/conclusions from our report:

Residential environments may become contaminated by the il icit drug,
methamphetamine, due to the use of the premises for the synthesis of
methamphetamine (clandestine laboratories) or due to the use of methamphetamine

by occupants of the premises. Residues of methamphetamine, precursor chemicals
and processing chemicals may persist and constitute a hazard to subsequent residents
of the premises.
The Ministry of Housing and Urban Development (HUD) have legal obligations in relation
to the built residential environment. HUD is developing regulations under section 138C
of the Residential Tenancies Act 1986, with a primary objective of minimising the health
impacts of methamphetamine contamination and requested advice from ESR in
relation to potential adverse human health effects from third-hand exposure to
methamphetamine.
HUD’s request for advice from ESR was capture in a series of questions. The fol owing
text addresses these questions in the context of the analysis and review provided in the
current report.
Can ESR provide brief evidence to the effect that methamphetamine residue may be
harmful to health, in the context of residential accommodation?
While the study of Wright et al. (2020) has many shortcomings, it is likely to be the best
evidence of adverse effects due to third-hand methamphetamine exposure that can be
ethical y obtained. The symptoms reported by residents of methamphetamine-
contaminated premises are reasonably consistent with symptoms reported by
responders exposed in clandestine laboratories. The symptoms are also reasonable
consistent with methamphetamine’s known mechanism of action.
Reported symptoms are mainly related to local effects on the skin, eyes or respiratory
tract or systemic neurological effects. Al  effects appear to be reversible.
Does ESR recommend that HUD prescribe maximum acceptable levels of
contamination, or a means of calculating maximum acceptable levels?
While the study of Wright et al. (2020) did not identify a clear biological gradient for
adverse effects associated with methamphetamine exposure, principles of toxicology
require such a gradient. A biological gradient means that with increasing exposure,
either the probability and/or the severity of adverse health effects wil  increase. This
further suggests that there wil  be a level of methamphetamine contamination that
results in unacceptable risks of adverse effects and some mechanism is required to
protect residents of methamphetamine-contaminated premises from unacceptable
levels of risk.
What does ESR recommend that those maximum acceptable levels, or means of
calculating those levels, should be? (noting that “levels” includes the potential for
setting ranges of methamphetamine contamination)
Section 2 of this report discusses the derivation of the reference dose (RfD) that was
used as the basis for the original ESR risk assessment (Fowles et al., 2016) and a less
conservative revised RfD, based on a reconsideration of the uncertainty factors used in
the RfD derivation. The revised RfD is 10-fold higher than the CalEPA RfD and would
support a 10-fold higher limit for methamphetamine surface contamination. The higher
surface contamination limit is co-incidentally the same as the value proposed
in the PMCSA report (Bardsley and Low, 2018).
As an in-detail assessment of the exposure model used for the ESR risk assessment
suggests that the model is neither overly in insufficiently conservative, a maximum
mean surface contamination concentration of 15 μg/100 cm2 is likely to be health
protective for almost al  of the exposed population

What are the options for presentation of maximum acceptable levels, or means of
calculating those levels, taking into account the potential for new scientiﬁc evidence on
health risks? Any health-based guidance value (exposure limit), or concentration limit
based on a health-based guidance value should be qualiﬁed as being derived on the
basis of currently available information. If signiﬁcant new information becomes
available, it should be considered and weighted as to its relevance for revision of the
existing limits.
What is international best practice in setting exposure limits?
Unfortunately, procedures for deriving exposure limits are not uniform across
organisations and it is not unusual for different organisations to derive different
exposure limits from the same toxicological data.
These differences are usual y due to the application of more or less conservative
uncertainty factors.
Does ESR recommend a “bright line” approach to a maximum inhabitable level, or a
different approach?
Given the relatively mild and reversible nature of the adverse health effects described
by Wright et al. (2020) and in the pivotal toxicological studies used as a basis for RfD
derivation, ESR considers that a mean surface contamination concentration of
15μg/100 cm2 should be viewed as a guideline level.
Analytical results above this level should be considered along with information on the
possible use of the premise for methamphetamine production, the presence of
sensitive individuals (pregnant women, infants) in the household and reports of adverse
health effects amongst residents of the premises.
What does ESR recommend as a maximum inhabitable level, above which a tenancy
should be terminated due to the health risk?
ESR does not consider that there is sufficient evidence to deﬁne a maximum
inhabitable level for methamphetamine. No evidence is available of severe health
effects associated with third-hand methamphetamine. However, ESR considers that
instances where the mean surface contamination concentration of methamphetamine
exceeds 15μg/100 cm2 should be viewed as potential y harmful.
While surface contamination concentrations below 15μg/100 cm2 wil  be associated
with a very low probability of harm, such residues should stil  be viewed as undesirable.
How does ESR recommend that a maximum inhabitable level should be applied in
practice, particularly where that level is present in only part of the premises?
ESR considers that a mean surface contamination concentration of methamphetamine
of 15μg/100 cm2 should be viewed as a guideline level, prompting further investigation
and possible action. ESR considers that the more conservative surface contamination
concentration of methamphetamine of 1.5μg/100 cm2, as included in the current New
Zealand standard remains a suitable target for properties to be remediated to, should
remediation be deemed appropriate.

Given that the report has stil  to have peer review completed, please view this text
accordingly.

Kind regards

Peter

Peter Cressey
Science Leader
Institute of Environmental Science and Research Limited (ESR)
Christchurch Science Centre: 27 Creyke Road, Ilam, Christchurch 8041
PO Box 29181, Christchurch 8540, New Zealand

DDI: +
/ T:
EXTN:

Withheld under
E:

Section 9(2)(a) of the
www.esr.cri.nz
Official Information Act 1982

The information contained in this message and/or attachments from ESR is intended
solely for the
addressee and may contain conﬁdential and/or privileged material. If you are not the
intended
recipient, any review, disclosure, copying, distribution or any action taken or omitted to
be taken in
reliance on it is prohibited by ESR. If you have received this message in error, please
notify the sender
immediately.

Disclaimer

This email is conﬁdential and solely for the use of the intended recipient. If you have
received this email in error, then any use is strictly prohibited. Please notify us
immediately and delete al  copies of this email and any attachments. Any opinions
expressed in this message are not necessarily those of the Ministry of Housing and
Urban Development.
The information contained in this message and/or attachments from ESR is intended
solely for the addressee and may contain conﬁdential and/or privileged material. If you
are not the intended recipient, any review, disclosure, copying, distribution or any action
taken or omitted to be taken in reliance on it is prohibited by ESR. If you have received
this message in error, please notify the sender
immediately.

Disclaimer
This email is conﬁdential and solely for the use of the intended recipient. If you have
received this email in error, then any use is strictly prohibited. Please notify us
immediately and delete al  copies of this email and any attachments. Any opinions
expressed in this message are not necessarily those of the Ministry of Housing and
Urban Development.

Monday 14 December

From:  Peter Cressey
Sent:  Monday, 14 December 2020 11:30 am
To:
Vanessa James; Jeff Fowles
Subject:
RE: Peer reviews
Attachments: FW20045 HUD_meth-evidence DRAFT 14 Dec 2020 changes
accepted.docx; Response to
peer review comments Dec 2020.docx

Hi Vanessa

Please ﬁnd attached a (slightly) amended version of our report and a summary of the
reviewers’ comments and our responses. For a number of the reviewer comments it
was unclear what changes were being suggested. Where reviewer comments suggested
that further information should be given, this has been added.

Perhaps the comment of most interest is Dr Scheps assertion that weight loss should
not be considered to be an adverse effect. We have outlined reasons why we disagree
with this assertion.

The reviewers’ comments and the subsequent amendment to the report do not, in our
opinion, impact the substantive conclusions of the report.

We look forward to receiving the ﬁnal reviewer’s feedback.

Kind regards

Peter

From: Vanessa James
Sent: Friday, 11 December 2020 12:30 p.m.
To: Peter Cressey ; Jeff Fowles
Subject: Peer reviews

Thanks Peter.

I have two peer reviews and we are expecting a third but this wil  not be completed for
probably another week (due to availability). I was intending to send you al  three
together.

I have just had a request to ask you if you’d be able to consider the existing 2 peer
reviews and make any changes by this Monday 14th.

Obviously this may not be possible due to the short notice but could you please let me
know either way?

We are brieﬁng the Minister on Monday so if you were able to consider the reviews
before then we could include your report and note that it takes account of the reviews.

One review is pasted direct from email below, and the other is attached.

Ng? mihi
Vanessa

Hi Vanessa
Thanks for the opportunity to review the report. I have read it a couple of times, but can
only comment on those sections which are epidemiological y related (section 4).
Therefore, I suggest you seek a ful
review of the report by a toxicologist. Two possibilities: Dr Michael Beasley, National
poisons Centre,
and A/Prof Sal y Gaw, University of Canterbury

Here are my comments of the epidemiology-related section:

Wright et al (2002) (pgs 26-7):
*
ESR acknowledge the study “has many shortcomings”, which are described on
pg 26. The report
says “this study is currently the best available assessment of adverse health effects”.
However, these methodological deﬁciencies severely compromise the validity of the
study, and therefore little credence should be given to its ﬁndings.
*
ESR say that Wright et al (2002) “did not identify a clear biological gradient” and
that the “principles of toxicology require such a gradient.”
*
Assessing Wright et al (2002) against the criteria suggested by Hil  (1965) that
might be suggestive of “causality”, show that there is little evidence of a causal
relationship.

Other studies (pgs 28-9): there is no critical evaluation of the study methodology, and
therefore, it is not known if the results might be plausible of due to some bias
*
Burgess et al (1996) –- how were the labs selected?
*
Witter et al (2007) - how were the personnel selected, and symptoms were self-
reported?
*
Sternquist (2012) – no information is provided on the selection process or
conﬁrmation of the symptoms
*
Thrasher et al (2009) – these are case reports

Conclusion
The ﬁndings from the cited epidemiological studies provide little or no evidence of
adverse effects.

Best wishes

Barry

-------------------------------------------------------------------------------------------------
Professor Barry Borman, Professor of Epidemiology
Director, Environmental Health Intel igence NZ, www.ehinz.ac.nz
New Zealand Birth Defects Registry
Co-Director PAWS (People•Animals•Wel being•Surveil ance)
E:
DDI:

M:
| T:

A: Massey University | Wel ington Campus | PO Box 756 | Wel ington 6140
Level D | Block 3 | Wallace Street | Wel ington 6021

From: Peter Cressey

Sent: Wednesday, 9 December 2020 3:03 pm
To: Vanessa James
; Jeff Fowles <tox-
[email address]>
Subject: RE: Question

Hi Vanessa

Out of Scope





Cheers

Peter

From: Vanessa James

Sent: Wednesday, 9 December 2020 12:51 p.m.
To: Peter Cressey
; Jeff Fowles <[email address]>
Subject: RE: Question

Out of Scope



Nga mihi
Vanessa

From: Peter Cressey

Sent: Wednesday, 9 December 2020 9:44 am
To: Vanessa James
; Jeff Fowles <tox-
[email address]>
Subject: RE: Question

Hi Vanessa

Out of Scope



Jeff, do you have anything to add?

I hope this is helpful.

Kind regards

Peter

From: Vanessa James

Sent: Wednesday, 9 December 2020 9:16 a.m.
To: Peter Cressey
; Jeff Fowles <[email address]>
Subject: Question

Morena Peter & Jeff

Out of Scope

Thanks
Vanessa

Vanessa James (she/her)
Principal Policy Advisor (contract) | Tenures and Housing Quality
Housing and Urban Settings
Withheld under

Section 9(2)(a) of the
www.hud.govt.nz | 7 Waterloo Quay, Wel ingon
Official Information Act 1982

Disclaimer

This email is conﬁdential and solely for the use of the intended recipient. If you have
received
this email in error, then any use is strictly prohibited. Please notify us immediately and
delete all
copies of this email and any attachments. Any opinions expressed in this message are
not
necessarily those of the Ministry of Housing and Urban Development.
The information contained in this message and/or attachments from ESR is intended
solely for the
addressee and may contain conﬁdential and/or privileged material. If you are not the
intended
recipient, any review, disclosure, copying, distribution or any action taken or omitted to
be taken in

reliance on it is prohibited by ESR. If you have received this message in error, please
notify the sender
immediately.

Disclaimer

This email is conﬁdential and solely for the use of the intended recipient. If you have
received
this email in error, then any use is strictly prohibited. Please notify us immediately and
delete all
copies of this email and any attachments. Any opinions expressed in this message are
not
necessarily those of the Ministry of Housing and Urban Development.
The information contained in this message and/or attachments from ESR is intended
solely for the
addressee and may contain conﬁdential and/or privileged material. If you are not the
intended
recipient, any review, disclosure, copying, distribution or any action taken or omitted to
be taken in
reliance on it is prohibited by ESR. If you have received this message in error, please
notify the sender
immediately.

Disclaimer

This email is conﬁdential and solely for the use of the intended recipient. If you have
received
this email in error, then any use is strictly prohibited. Please notify us immediately and
delete all
copies of this email and any attachments. Any opinions expressed in this message are
not
necessarily those of the Ministry of Housing and Urban Development.