Printed from https://fyi.org.nz/request/33833-rf-exposure-risk-assessment-under-the-health-and-safety-at-work-act-2015-smart-meters on March 17, 2026 07:36

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

SPENCER JONES made this Official Information request to WorkSafe New Zealand

Currently waiting for a response from WorkSafe New Zealand, they must respond promptly and normally no later than (details and exceptions).

From: SPENCER JONES

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

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From: Ministerial Services – WorkSafe
WorkSafe New Zealand

Tēnā koe Spencer

Thank you for your Official Information Act request received by WorkSafe New Zealand on 24 February 2026.

We will respond to your request in accordance with the provisions of the Official Information Act as soon as reasonably practicable and not later than 20 working days.

If we need to extend this timeframe, we will let you know before that date with the reasons why.

Please contact [email address] if you have any questions.

Ngā mihi,

Ministerial Services
8 Willis Street
Wellington
W    worksafe.govt.nz

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SPENCER JONES left an annotation ()

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.

⸻

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.

⸻

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.

⸻

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.

⸻

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.

⸻

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.

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Things to do with this request

Anyone:
WorkSafe New Zealand only: