Follow-up Request: Testing WorkSafe’s Treatment of RF Exposure as a Workplace Hazard

This request follows WorkSafe New Zealand’s response to OIA Ref: 260178, in which the agency confirmed that:

> no information exists regarding any assessment of RF exposure from electricity smart meters, and the request was refused under section 18(e).

While that response establishes that no specific smart meter RF assessment is held, it does not clarify a more fundamental issue:

> whether radiofrequency (RF) or electromagnetic field (EMF) exposure is recognised or managed as a workplace hazard within WorkSafe’s regulatory framework at all.

This follow-up request has therefore been submitted to clarify:

• whether RF/EMF exposure is treated as a workplace hazard under the Health and Safety at Work Act 2015
• what guidance, standards, or frameworks (if any) WorkSafe applies to RF exposure
• whether smart meter RF exposure has ever been considered, either explicitly or implicitly
• and the scope of the searches undertaken in the original response

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Why This Matters

The initial response raises a broader question:

> if no records exist for smart meter RF exposure, does this reflect:
• a genuine absence of risk assessment
• a limitation in how RF hazards are defined or tracked
• or a gap in how emerging exposure risks are considered within workplace safety regulation

Given that:

• RF exposure is a recognised environmental and occupational exposure category internationally
• smart meters are widely installed across residential and occupational environments
• and other agencies appear to rely on distributed responsibility or international standards

this request seeks to determine whether:

> RF exposure is systematically assessed within New Zealand’s workplace safety framework — or whether it falls between regulatory domains.

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Context Within Wider OIA Series

This request should be read alongside related OIAs examining:

• scientific advice and capability (ESR / PHF Science)
• public health oversight (Ministry of Health)
• governance and inter-agency responsibility (Electricity Authority and others)

Across these requests, a consistent pattern is emerging:

• scientific capability exists
• exposure sources are widespread
• but responsibility and documented assessment appear fragmented or unclear

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Purpose of This Request

This follow-up is intended to move beyond document retrieval and instead clarify:

• how RF exposure is conceptualised within regulatory frameworks
• whether it is actively assessed as a workplace risk
• and whether any implicit assumptions or exclusions exist

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Summary

This request marks a shift from:

• identifying whether specific documents exist

to:

• determining whether a category of risk is recognised, assessed, or systematically addressed within New Zealand’s workplace safety system.

The response will help clarify whether the absence identified in the original request reflects:

• a documentation gap
• a scope limitation
• or a broader regulatory blind spot.