Clarification of Hazardous Substances Audit Scope and 2019 Audit Status
SPENCER JONES made this Official Information request to Ministry of Defence
The request was partially successful.
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
From: Information
Ministry of Defence
Kia ora,
Please find attached our response to your Official Information Act
request.
Kind regards,
Ministry of Defence
+------------+
||Ministerial|
||and Public |
||Services |
||Branch |
|| |
||Manatū |
||Kaupapa |
||Waonga - |
||New Zealand|
||Ministry of|
||Defence |
|| |
|| |
|| |
|| |
|| |
||Defence |
||House, 34 |
||Bowen |
||Street, PO |
||Box 12703, |
||Wellington |
||6144, New |
||Zealand |
+------------+
-----Original Message-----
From: SPENCER JONES
[mailto:[FOI #33743 email]]
Sent: Monday, 16 February 2026 7:44 p.m.
To: Information <[email address]>
Subject: Official Information request - Clarification of Hazardous
Substances Audit Scope and 2019 Audit Status
------------------------------------------------------------------------------
CAUTION: This email originated from outside of the organization.
Do not follow guidance, click links, or open attachments unless you
recognize the sender and know the content is safe. If in any doubt, please
forward the email to [1][email address] and then delete the email from
your Inbox. Thank you
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
-------------------------------------------------------------------
This is an Official Information request made via the FYI website.
Please use this email address for all replies to this request:
[2][FOI #33743 email]
Is [3][Ministry of Defence request email] the wrong address for Official Information
requests to Ministry of Defence? If so, please contact us using this form:
[4]https://fyi.org.nz/change_request/new?bo...
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[5]https://fyi.org.nz/help/officers
If you find this service useful as an Official Information officer, please
ask your web manager to link to us from your organisation's OIA or LGOIMA
page.
-------------------------------------------------------------------
Note:
The information contained in this email message is intended only for the
addressee and is not necessarily the official view or communication of the
Ministry. If you are not the intended recipient you must not use,
disclose, copy or distribute this message or the information in it. If you
have received this message in error, please email or telephone the sender
immediately. Thank you"
References
Visible links
1. mailto:[email address]
2. mailto:[FOI #33743 email]
3. mailto:[Ministry of Defence request email]
4. https://fyi.org.nz/change_request/new?bo...
5. https://fyi.org.nz/help/officers
hide quoted sections
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).
Offensive? Unsuitable?
Requests for personal information and vexatious requests are not considered valid requests for Official Information (read more).
If you believe this request is not suitable, you can report it for attention by the site administrators
Report this request
SPENCER JONES left an annotation ()
Annotation – Hazardous Substances Audit Scope, Audit Architecture, and What Remains Missing
This request sought clarification of how the Ministry of Defence defines and scopes “hazardous substances” when conducting audit or assurance activity relating to the New Zealand Defence Force.
The Ministry’s response is useful because it confirms several important governance points.
First, the Ministry confirms that, when undertaking assurance activities relating to hazardous substances, it applies the definition of “hazardous substance” in section 2 of the Hazardous Substances and New Organisms Act 1996 (HSNO). Second, it confirms that, for recent audits, practical scoping has been aligned with NZDF Defence Force Order 41 – Safe Management of Hazardous Substances. Third, it confirms that audit scope is set for each audit through a Terms of Reference (ToR) informed by a risk assessment conducted before audit planning. 
These are significant admissions because they show that hazardous substance oversight is not informal. It is structured through:
• a statutory definition under HSNO,
• an internal NZDF operational framework (DFO 41),
• and a formal audit-scoping process involving risk assessment and ToR documentation.
However, while the response explains the framework, it does not provide the underlying records that would allow the public to assess how this framework has been applied in practice.
What this response appears to confirm exists
Based on the Ministry’s own wording, the following documents or record classes are likely to exist:
• audit Terms of Reference;
• pre-audit risk assessments;
• audit planning documentation;
• potentially audit reports or assurance summaries arising from those ToR.
Those underlying records were not provided in this response. The request therefore appears to have been answered at a framework level, but not at the level of supporting audit evidence.
Why this matters
This is important for anyone researching:
• hazardous substances management within NZDF facilities;
• defence estate environmental governance;
• the scope of Ministry of Defence assurance functions;
• whether specific hazards are included or excluded from audit practice.
The response helps establish the audit architecture, but it does not yet show how that architecture has operated in specific audits, what risks were identified, or whether any categories of hazard were excluded in practice.
Related FYI requests for researchers
This request should be read alongside related OIA threads that help map the wider defence environmental governance picture:
Defence estate environmental hazard governance and records
https://fyi.org.nz/request/33540-officia...
Environmental and airborne hazard management records (2000–2025)
https://fyi.org.nz/request/33539-officia...
Environmental monitoring or oversight relating to defence facilities
https://fyi.org.nz/request/33541-officia...
This request is also directly linked to the present clarification thread:
Clarification of hazardous substances audit scope and 2019 audit status
https://fyi.org.nz/request/33743-clarifi...
Taken together, these requests help reconstruct:
• who holds operational records,
• who performs audit and assurance,
• what legal and policy definitions are used,
• and what records should exist to document environmental and hazardous substances oversight within the defence estate.
Current position
This request appears to have been partially answered rather than refused.
It establishes the legal and operational framework used by the Ministry of Defence, but it leaves the actual audit evidence undisclosed. For researchers, the next logical step is to request the underlying Terms of Reference, risk assessments, and audit outputs referred to in the response.
Link to this