Public Annotation – RF Exposure Risk Assessment under the Health and Safety at Work Act 2015 (Smart Meters)

This request seeks clarification of whether any formal risk assessments, internal advice, or documented consideration has occurred regarding radiofrequency (RF) exposure from advanced metering infrastructure (smart meters) in the context of obligations under the Health and Safety at Work Act 2015 (HSWA).

The request does not seek to re-litigate scientific exposure limits. It seeks documentary traceability of statutory risk assessment processes.

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Why this request is governance-relevant

The Health and Safety at Work Act 2015 establishes a framework requiring:
• Identification of hazards;
• Assessment of risks;
• Consideration of control measures;
• Ongoing review where circumstances change.

Where smart meters are deployed at scale, and where agencies make public statements concerning safety compliance, it is reasonable to understand:

1️⃣ Whether RF exposure was formally assessed as a potential hazard under HSWA frameworks;
2️⃣ Whether risk assessments were documented internally or across agencies;
3️⃣ Whether reassessment occurred as deployment increased;
4️⃣ Whether reliance was placed solely on existing standards (e.g., NZS 2772.1:1999), or whether additional risk evaluation occurred.

The purpose of this request is not to question statutory standards, but to clarify whether documented HSWA-style risk assessment processes were undertaken.

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What a substantively complete response would include

A complete response would ideally identify:
• Any hazard identification documentation referencing RF exposure from smart meters;
• Risk assessment papers or registers referencing RF exposure;
• Advice provided to decision-makers concerning HSWA obligations in relation to AMI rollout;
• Records of cross-agency consultation where HSWA risk management responsibilities were discussed;
• Documentation confirming reliance on a particular standard as the control measure.

If no such documentation exists, confirmation of that absence would be governance-significant.

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Clarifying scope (to avoid drift)

This request:
• Does not require new scientific modelling;
• Does not seek operational inspection records unrelated to RF exposure;
• Does not request personal health data;
• Does not seek to expand statutory duties beyond existing legislation.

It is limited strictly to identifying whether formal HSWA-style risk assessment documentation exists in relation to smart meter RF exposure.

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Oversight architecture context

Smart meter deployment intersects with multiple regulatory domains:
• Electricity market regulation;
• Energy safety oversight;
• Public health standards;
• Workplace health and safety obligations.

Understanding whether HSWA risk assessment documentation exists contributes to mapping:
• Whether oversight responsibility is formally allocated;
• Whether hazard assessment was documented at rollout stage;
• Whether reassessment occurs when deployment conditions evolve;
• Whether reliance on technical standards substitutes for documented risk evaluation.

This request therefore contributes to transparency regarding statutory risk management processes.

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Possible response scenarios (neutral framing)

The response may indicate:
• A formal risk assessment exists and will be released;
• RF exposure was considered within broader hazard registers;
• Reliance was placed solely on compliance with NZS 2772.1:1999;
• No specific HSWA risk assessment documentation exists.

Each outcome carries different governance implications.

This annotation records the purpose of the request as documentary clarification of statutory risk assessment processes.

I will update this thread once the agency has provided its substantive response.

📌 Annotation: WorkSafe Confirms No RF Risk Assessment for Smart Meters under HSWA

This request sought to determine whether WorkSafe New Zealand has undertaken or holds any assessment of radiofrequency (RF) exposure risks from electricity smart meters under the Health and Safety at Work Act 2015.

WorkSafe has now confirmed that:

no information was identified and the request has been refused under section 18(e) (information does not exist) 

This response indicates that:
• WorkSafe has not undertaken, or does not hold records of, any assessment of RF exposure risks associated with smart meters in a workplace or occupational safety context.

This is notable given that:
• WorkSafe is the primary regulator responsible for workplace health and safety risks in New Zealand
• Smart meters are widely installed in residential and occupational environments
• RF exposure is a recognised category of environmental and occupational exposure internationally

When considered alongside other requests:
• No clear NZ-specific scientific assessment has been identified from ESR/PHF Science
• Responsibility for RF exposure governance appears to be distributed across agencies

This raises an important question:

whether any New Zealand agency has undertaken a comprehensive assessment of RF exposure risks from smart meters within either public health or occupational safety frameworks.

The absence of such records at WorkSafe suggests a potential gap in how emerging or non-traditional exposure risks are assessed under the Health and Safety at Work Act.

Cross-Request Annotation: Emerging Multi-Agency Gap in Smart Meter RF Governance (New Zealand)

This request forms part of a wider series of Official Information Act (OIA) investigations examining how radiofrequency (RF) exposure from electricity smart meters is assessed, governed, and monitored in New Zealand.

Across multiple FYI.org.nz requests, a consistent pattern is emerging:
scientific capability exists, but no clear agency appears to hold or produce a New Zealand-specific assessment of smart meter RF exposure.

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Key Related OIA Requests

The following requests should be read together:

• Scientific advice / reviews (ESR / PHF Science)
https://fyi.org.nz/request/33832-scienti...

• Public health assessment, complaints, and inter-agency correspondence
https://fyi.org.nz/request/34077-smart-m...

• Governance, standards, and inter-agency oversight
https://fyi.org.nz/request/34076-smart-m...

• Follow-up: health enquiries and recordkeeping trail
https://fyi.org.nz/request/34075-follow-...

• Executive allocation of responsibility for RF oversight
https://fyi.org.nz/request/33836-executi...

• Workplace risk assessment under the Health and Safety at Work Act
https://fyi.org.nz/request/33833-rf-expo...

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Key Finding from This Request (WorkSafe)

WorkSafe New Zealand has confirmed that:

> no information exists regarding any assessment of RF exposure risks from smart meters under the Health and Safety at Work Act 2015.

This indicates that:

• no documented workplace risk assessment has been undertaken or retained
• RF exposure from smart meters has not been formally assessed within the occupational safety framework

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🔬 Parallel Findings from Other Requests

Across related OIAs:

• Institute of Environmental Science and Research Limited / New Zealand Institute for Public Health and Forensic Science
– Demonstrated historical RF expertise (via the National Radiation Laboratory)
– However, no NZ-specific smart meter RF assessment has been identified

• Ministry of Health
– Appears to rely on international standards (ICNIRP, NZS 2772.1:1999)
– No clearly identified domestic scientific review

• Electricity Authority
– Defers to health agencies regarding RF risk

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Emerging System Pattern

Taken together, these requests suggest:

• scientific capability exists within government research institutions
• regulatory responsibility is distributed across multiple agencies
• no single agency appears to hold end-to-end responsibility
• no NZ-specific scientific assessment of smart meter RF exposure is clearly identifiable

This creates a “governance gap” in which:

> exposure exists, capability exists, but documented assessment is not evident

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🔍 Why This Matters

Smart meters are widely deployed across residential and occupational environments.

In most regulatory contexts, such exposure would typically involve:

• scientific risk assessment
• public health evaluation
• occupational safety consideration
• inter-agency coordination

The absence of identifiable records across these domains raises questions about:

• whether such assessments were ever undertaken
• whether responsibility has been fragmented across agencies
• or whether relevant work exists but has not been disclosed

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For Researchers and Investigators

This OIA series should be considered as a linked evidence set, not isolated requests.

Future lines of inquiry may include:

• cross-agency search adequacy (what was searched, and where)
• whether scientific advice was provided informally or without documentation
• whether reliance on international standards has substituted for domestic assessment
• identification of any “hidden” advisory pathways (e.g. committees, working groups, consultants)

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Summary

This request contributes to a growing body of evidence suggesting that:

> New Zealand may not have undertaken a clearly documented, country-specific scientific or regulatory assessment of smart meter RF exposure, despite having both the capability and regulatory frameworks to do so.

Further responses — particularly from the Ministry of Health — will be critical in determining whether this reflects:

• a true absence of assessment
• a fragmentation of responsibility
• or the existence of undisclosed advisory material

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