Hazardous substances audit ToR, risk assessments, and audit records
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,
Kia ora,
Thank you for your response of 11 March 2026 regarding the Ministry of Defence’s hazardous substances audit scope.
In that response, the Ministry confirmed that:
• hazardous substances assurance activity uses the definition in section 2 of the Hazardous Substances and New Organisms Act 1996;
• recent audit scoping has been aligned with NZDF Defence Force Order 41 – Safe Management of Hazardous Substances; and
• audit scope is set for each audit through a Terms of Reference (ToR) informed by a risk assessment conducted before audit planning.
I now request, under the Official Information Act 1982, the following information:
1. Audit Terms of Reference
Please provide copies of any Terms of Reference used by the Ministry of Defence for hazardous substances audit or assurance activity relating to NZDF from 1 January 2018 to the present.
2. Pre-audit risk assessments
Please provide copies of any risk assessments, scoping papers, planning memoranda, or equivalent records used to inform the audit scope for those hazardous substances audits or assurance activities during the same period.
3. Audit outputs
Please provide copies of any:
• final audit reports,
• assurance reports,
• findings summaries,
• closure reports,
• or recommendation summaries
arising from those hazardous substances audit or assurance activities from 1 January 2018 to the present.
4. Scope inclusion / exclusion
Please provide any document, note, or guidance used in audit planning that records whether the following were included or excluded from hazardous substances audit scope:
• airborne particulate hazards;
• asbestos-related hazards or exposure records;
• contaminated land or environmental residue issues;
• non-HSNO but operationally hazardous materials.
5. 2019 audit status
If any hazardous substances audit or assurance activity was commenced in or around 2019, please provide:
• the ToR;
• the risk assessment or scoping document;
• and any record showing whether that audit was completed, paused, superseded, or not finalised.
If any part of this request is likely to engage section 18(f), please provide reasonable assistance under section 13 by identifying how the request may be refined while preserving access to the core audit-planning and audit-output documents.
I am happy to receive the information electronically in PDF format where possible.
Kind regards,
Spencer Jones
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Public Annotation – Follow-up Request for Hazardous Substances Audit Records
This request follows an earlier clarification request regarding how the Ministry of Defence defines and scopes “hazardous substances” when conducting audit or assurance activity relating to the New Zealand Defence Force.
In its previous response the Ministry confirmed that:
• hazardous substances are defined according to section 2 of the Hazardous Substances and New Organisms Act 1996 (HSNO)
• audit scoping aligns with NZDF Defence Force Order 41 – Safe Management of Hazardous Substances
• audit scope is determined through Terms of Reference informed by a pre-audit risk assessment
That response effectively described the governance framework used to audit hazardous substances, but it did not provide the underlying records referenced in that explanation, such as:
• audit Terms of Reference
• risk assessments used to determine audit scope
• audit findings or assurance reports
Those records are important because they would show how hazardous substance oversight is actually implemented within defence estate operations, rather than simply how the framework is described.
This follow-up request therefore seeks the audit planning and audit output records themselves, including:
• Terms of Reference for hazardous substance audits
• audit risk assessments
• audit reports or findings
• documentation showing whether particular hazard categories were included or excluded from audit scope
This request aims to clarify how hazardous substance risks are monitored within the defence environment and whether particular categories of hazard may fall outside the practical scope of defence assurance activity.
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Related FYI requests for researchers
This request forms part of a wider set of public information requests examining environmental governance, hazardous substances oversight, and risk management within the defence estate.
Relevant requests include:
Clarification of hazardous substances audit scope and 2019 audit status
https://fyi.org.nz/request/33743-clarifi...
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...
Taken together, these requests help map the defence environmental governance chain, including:
• which agencies hold environmental records
• how hazardous substances are defined and monitored
• how defence estate risk assessments are conducted
• what assurance mechanisms exist to review environmental hazards
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Why this follow-up request matters
The previous response confirmed that hazardous substance oversight operates through a structured audit and risk-assessment process. However, the practical operation of that system cannot be evaluated without access to the underlying audit documentation.
Providing those records would allow researchers and the public to understand:
• how hazardous substance risks are assessed within defence operations
• what issues are typically examined in defence environmental audits
• whether particular hazards are included or excluded from audit scope
• and how assurance findings are recorded or acted upon.
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Research context
Public OIA requests such as this help build an evidence-based understanding of how environmental governance systems operate in practice.
For researchers examining defence environmental governance, this request therefore aims to clarify how the audit framework described by the Ministry translates into actual audit activity and risk oversight within the defence estate.
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