Printed from https://fyi.org.nz/request/34034-hazardous-substances-audit-tor-risk-assessments-and-audit-records?unfold=1 on May 27, 2026 19:03

Hazardous substances audit ToR, risk assessments, and audit records

SPENCER JONES made this Official Information request to Ministry of Defence

Response to this request is long overdue. By law Ministry of Defence should have responded by now (details and exceptions). The requester can complain to the Ombudsman.

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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SPENCER JONES left an annotation ()

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.

⸻

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

⸻

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.

⸻

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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From: Information
Ministry of Defence

Kia ora,
 
Thank you for your request for official information. This will be managed in accordance with the provisions of the Official Information Act 1982, which may include transfer to a more relevant agency or Minister.
 
The Ministry may publish the content of our response to your request on the Ministry of Defence website (www.defence.govt.nz). Your personal information will not be published. More information on making an official information request with the Ministry of Defence is available here: https://www.defence.govt.nz/contact-us/o....
 
Ngā mihi,
Ministry of Defence

-----Original Message-----
From: SPENCER JONES <[FOI #34034 email]>
Sent: Wednesday, 11 March 2026 5:35 pm
To: Information <[email address]>
Subject: Official Information request - Hazardous substances audit ToR, risk assessments, and audit records

------------------------------------------------------------------------------
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 [email address] and then delete the email from your Inbox. Thank you

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

-------------------------------------------------------------------

This is an Official Information request made via the FYI website.

Please use this email address for all replies to this request:
[FOI #34034 email]

Is [Ministry of Defence request email] the wrong address for Official Information requests to Ministry of Defence? If so, please contact us using this form:
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:
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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.

-------------------------------------------------------------------

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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"

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Ministry of Defence

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Attachment 2019 ToR.pdf
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UNCLASSIFIED

Kia ora Spencer,

 

Please find attached our response to your Official Information Act
request, along with the relevant enclosure.

 

Kind regards,

Ministry of Defence

 

[1]cid:image001.png@01DCA4B2.EA4E5B90 Ministerial and Public Services

Manatū Kaupapa Waonga  - New Zealand
Ministry of Defence

 

 

Defence House, 34 Bowen Street, PO
Box 12703, Wellington 6144, New
Zealand

 

 

UNCLASSIFIED

-----Original Message-----
From: SPENCER JONES <[FOI #34034 email]>
Sent: Wednesday, 11 March 2026 5:35 pm
To: Information <[email address]>
Subject: Official Information request - Hazardous substances audit ToR,
risk assessments, and audit records

 

------------------------------------------------------------------------------

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 [email address] and then delete the email from your
Inbox. Thank you

 

 

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

 

-------------------------------------------------------------------

 

This is an Official Information request made via the FYI website.

 

Please use this email address for all replies to this request:

[FOI #34034 email]

 

Is [Ministry of Defence request email] the wrong address for Official Information
requests to Ministry of Defence? If so, please contact us using this form:

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:

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"

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