Dear WorkSafe New Zealand,

Subject: Official Information Act Request – RF Exposure Risk Assessment under the Health and Safety at Work Act 2015 (Smart Meters)

Kia ora,

I am making this request under the Official Information Act 1982.

I seek records concerning WorkSafe New Zealand’s consideration of radiofrequency (RF) exposure from electricity smart meters (Advanced Metering Infrastructure – AMI) within the framework of the Health and Safety at Work Act 2015 (HSWA).

This request concerns regulatory oversight and risk management duties. It does not seek a determination of medical causation.

Please provide:

1. RF Exposure as a Risk under HSWA (since 1 January 2015)

Any documents, guidance, internal memoranda, assessments, or policy papers addressing whether RF emissions from smart meters:

Constitute a workplace risk under HSWA;

Fall within WorkSafe’s regulatory oversight where PCBUs install, operate, or maintain AMI infrastructure;

Require specific risk assessment or mitigation steps.

2. Guidance to PCBUs / Electricity Sector

Any guidance, advice, or communications provided to:

Electricity retailers;

Metering providers;

Lines companies;

Industry bodies;

concerning RF exposure risk management, including compliance expectations under sections 30 and 36 of HSWA (duty to manage risks and primary duty of care).

3. Referrals or Inter-Agency Communications

Any communications between WorkSafe and:

The Electricity Authority;

Ministry of Health;

Health NZ;

ESR;

MBIE;

concerning:

Systemic AMI deployment issues;

RF exposure complaints;

Risk management responsibilities.

4. Enforcement Consideration

Any internal discussions or records indicating whether WorkSafe has:

Assessed complaints relating to smart meter RF exposure;

Considered investigation, inspection, or enforcement action;

Determined that RF exposure from AMI falls outside its enforcement remit.

For clarity:

I seek existing documentary records.

I do not seek creation of new analysis.

If this request is considered overly broad, I am willing to refine it under section 13 of the Act.

If information is withheld under section 9, please specify the subsection relied upon and provide the public interest balancing assessment under section 9(1).

If information is refused under section 18(g), please confirm that reasonable searches have been undertaken.

If held electronically, I request electronic copies.

Kind regards,
Spencer Jones