Clarification of Hazardous Substances Audit Scope and 2019 Audit Status
SPENCER JONES made this Official Information request to Ministry of Defence
Currently waiting for a response from Ministry of Defence, they must respond promptly and normally no later than (details and exceptions).
From: SPENCER JONES
Dear Ministry of Defence,
Tēnā koutou,
I refer to your response dated 16 February 2026 to OIA request #33540 (Defence Estate Environmental Hazard Governance and Records).
This request is a narrowed clarification seeking confirmation of audit scope and document existence only. No historical correspondence collation is sought.
Please provide the following:
1. Definition of “hazardous substances” within MoD audit scope
Please provide:
1.1 The definition, framework, or interpretive guidance used by the Ministry of Defence when auditing NZDF under the Hazardous Substances and New Organisms Act 1996 (HSNO).
1.2 Any document (policy, audit framework, audit terms of reference, checklist, or internal guidance) that defines the scope of substances, exposures, or risks included in those audits.
If this definition is contained within a specific statutory interpretation or audit manual, please provide the relevant extract only.
2. Airborne particulate hazards
Please confirm (yes/no):
2.1 Whether airborne particulate hazards (including but not limited to dust, fibres, combustion by-products, mould spores, or environmental particulates) fall within the scope of MoD hazardous substances audits.
2.2 If airborne particulate hazards are excluded from audit scope, please confirm which authority (if any) is responsible for assurance oversight of those risks within the Defence estate.
No incident records are requested — confirmation of scope only.
3. Asbestos exposure records
Please confirm:
3.1 Whether MoD hazardous substances audits include review of NZDF asbestos registers, exposure records, or management plans.
3.2 If asbestos management falls outside the HSNO audit framework, please identify the oversight mechanism under which it is reviewed.
4. 2019 Hazardous Substances Audit
In your previous response, you noted that a 2019 hazardous substances audit was commenced but not completed.
Please confirm:
4.1 Whether working papers, draft findings, field notes, or preliminary reports from the 2019 audit still exist.
4.2 If such material exists, whether it is held by MoD or NZDF.
4.3 If the material no longer exists, please confirm the applicable disposal authority under the Public Records Act 2005.
No release of substantive audit content is sought at this stage — confirmation of existence and custody only.
5. Format
Please provide responses in written form.
If any requested information is held by another agency, please transfer under section 14 of the OIA.
Kind regards,
Spencer Jones
Things to do with this request
- Add an annotation (to help the requester or others)
- Download a zip file of all correspondence (note: this contains the same information already available above).

