Public Annotation – Defence Estate Hazard Governance Architecture (What This OIA Reveals)

This OIA has now received a formal decision. While partially answered, it reveals an important governance architecture finding regarding environmental and airborne hazard management across the Defence estate.

The Ministry of Defence (MoD) confirms that it does not manage estate-level environmental hazards operationally. Those responsibilities sit with the New Zealand Defence Force (NZDF). MoD’s role is limited to audit and assurance under the HSNO Act framework, specifically hazardous substances controls.

Key structural findings from the response:
• Operational hazard management → NZDF
• Hazardous substances audit (HSNO) → MoD
• Record retention for estate hazards → NZDF
• Audit reporting to Ministers → MoD

The OIA confirms that:
• MoD does not hold operational hazard management policies (s18(g)).
• 25 years of correspondence was refused under s18(f) (substantial collation).
• A 2019 hazardous substances audit was commenced but not completed.
• 2019 audit materials were withheld under s9(2)(g)(i) and s9(2)(f)(iv).
• No confirmation was provided that airborne particulate, asbestos, mould, or legacy contamination risks fall within the HSNO audit scope.

The structural issue emerging is not whether audits occur — it is whether there is a single, coherent, accountable governance layer for environmental and airborne hazards across Defence estates.

This OIA demonstrates a classic policy/operator separation:
• MoD audits.
• NZDF operates.
• Records are fragmented.
• Historic correspondence is not centrally collated.

For researchers and journalists examining estate governance, environmental exposure, or record destruction concerns, this architecture split is central.

The request is technically completed but substantively partial.

Public Annotation – Structural Split in Defence Estate Hazard Governance (OIA #33540)

This OIA confirms a clear structural split in how environmental and hazardous substance risks are governed across the Defence estate.

The Ministry of Defence (MoD) has formally confirmed that it does not manage environmental or airborne hazards operationally. Those responsibilities sit with the New Zealand Defence Force (NZDF).

MoD’s role is limited to conducting periodic audits under the Hazardous Substances and New Organisms Act (HSNO). It holds audit reports, but not the underlying estate-level hazard records or correspondence.

The response further confirms:
• Operational hazard management → NZDF
• Hazard record retention → NZDF
• Hazardous substances audit (HSNO) → MoD
• Ministerial reporting → MoD
• 25 years of correspondence → not centrally collated
• 2019 audit → commenced but not completed; material withheld under s9

This architecture creates a layered model:

Operator (NZDF) holds site-level data.
Auditor (MoD) holds periodic summaries.
Neither holds a unified, longitudinal environmental governance record.

The OIA does not establish wrongdoing.
It establishes fragmentation.

For researchers examining environmental exposure, asbestos management, airborne hazards, or record retention integrity across Defence estates, this structural split is the key governance finding.