RF / EMF as a Workplace Hazard

SPENCER JONES made this Official Information request to WorkSafe New Zealand

The request was partially successful.

From: SPENCER JONES

Dear WorkSafe New Zealand,

Kia ora,

Thank you for your response (Ref: 260178) advising that no information was identified in scope of my previous request regarding RF exposure from electricity smart meters.

To better understand WorkSafe New Zealand’s approach to radiofrequency (RF) exposure risks under the Health and Safety at Work Act 2015, I request the following information:

1. RF / EMF as a Workplace Hazard
Please confirm whether WorkSafe recognises radiofrequency (RF) or electromagnetic field (EMF) exposure as a potential workplace hazard within its regulatory or guidance framework.

If so, please provide:
• any guidance documents, policies, or internal frameworks relating to RF/EMF exposure
• any standards, references, or external sources relied upon (e.g. ICNIRP, NZS 2772.1:1999)

2. Consideration of RF Exposure in Practice
Please provide any documents, guidance, or internal material that describe how RF/EMF exposure risks are assessed, monitored, or addressed in workplace contexts (including but not limited to telecommunications, utilities, or electrical infrastructure environments).

3. Consideration of Smart Meters
Please confirm whether RF exposure from electricity smart meters (Advanced Metering Infrastructure – AMI) has ever been:

• explicitly considered
• implicitly considered as part of broader RF/EMF hazard assessments
• or explicitly excluded from consideration

If so, please provide any records, guidance, or communications reflecting that consideration.

4. Scope of Previous Search
For clarity, please outline the scope of the searches undertaken in response to my previous request (Ref: 260178), including:

• which teams, units, or directorates were consulted
• whether policy, regulatory, or inspectorate functions beyond the Energy Safety team were included

5. Absence Confirmation
If no information is held in relation to the above, please confirm whether this reflects:

• that WorkSafe has not undertaken or documented any consideration of RF/EMF exposure as a workplace risk; or
• that such matters are considered to fall outside WorkSafe’s regulatory scope

I am happy to refine the scope of this request under section 13 if required.

Kind regards,

Spencer Jones

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SPENCER JONES left an annotation ()

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.

---

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

---

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

---

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.

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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 March 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

-----Original Message-----
From: SPENCER JONES <[FOI #34229 email]>
Sent: Tuesday, 24 March 2026 11:21 pm
To: Ministerial Services – WorkSafe <[email address]>
Subject: Official Information request - RF / EMF as a Workplace Hazard

[You don't often get email from [FOI #34229 email]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentific... ]

Dear WorkSafe New Zealand,

Kia ora,

Thank you for your response (Ref: 260178) advising that no information was identified in scope of my previous request regarding RF exposure from electricity smart meters.

To better understand WorkSafe New Zealand’s approach to radiofrequency (RF) exposure risks under the Health and Safety at Work Act 2015, I request the following information:

1. RF / EMF as a Workplace Hazard
Please confirm whether WorkSafe recognises radiofrequency (RF) or electromagnetic field (EMF) exposure as a potential workplace hazard within its regulatory or guidance framework.

If so, please provide:
• any guidance documents, policies, or internal frameworks relating to RF/EMF exposure • any standards, references, or external sources relied upon (e.g. ICNIRP, NZS 2772.1:1999)

2. Consideration of RF Exposure in Practice Please provide any documents, guidance, or internal material that describe how RF/EMF exposure risks are assessed, monitored, or addressed in workplace contexts (including but not limited to telecommunications, utilities, or electrical infrastructure environments).

3. Consideration of Smart Meters
Please confirm whether RF exposure from electricity smart meters (Advanced Metering Infrastructure – AMI) has ever been:

• explicitly considered
• implicitly considered as part of broader RF/EMF hazard assessments • or explicitly excluded from consideration

If so, please provide any records, guidance, or communications reflecting that consideration.

4. Scope of Previous Search
For clarity, please outline the scope of the searches undertaken in response to my previous request (Ref: 260178), including:

• which teams, units, or directorates were consulted • whether policy, regulatory, or inspectorate functions beyond the Energy Safety team were included

5. Absence Confirmation
If no information is held in relation to the above, please confirm whether this reflects:

• that WorkSafe has not undertaken or documented any consideration of RF/EMF exposure as a workplace risk; or • that such matters are considered to fall outside WorkSafe’s regulatory scope

I am happy to refine the scope of this request under section 13 if required.

Kind regards,

Spencer Jones

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From: Ministerial Services – WorkSafe
WorkSafe New Zealand


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Kia ora Spencer

 

Please see attached the response to your Official Information Act request.

 

Ngâ mihi

 

Ministerial Services

8 Willis Street

Wellington

W    [1]worksafe.govt.nz

 

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-----Original Message-----
From: SPENCER JONES <[FOI #34229 email]>
Sent: Tuesday, 24 March 2026 11:21 pm
To: Ministerial Services – WorkSafe
<[email address]>
Subject: Official Information request - RF / EMF as a Workplace Hazard

 

[You don't often get email from
[7][FOI #34229 email]. Learn why this is
important at [8]https://aka.ms/LearnAboutSenderIdentific... ]

 

Dear WorkSafe New Zealand,

 

Kia ora,

 

Thank you for your response (Ref: 260178) advising that no information was
identified in scope of my previous request regarding RF exposure from
electricity smart meters.

 

To better understand WorkSafe New Zealand’s approach to radiofrequency
(RF) exposure risks under the Health and Safety at Work Act 2015, I
request the following information:

 

1. RF / EMF as a Workplace Hazard

Please confirm whether WorkSafe recognises radiofrequency (RF) or
electromagnetic field (EMF) exposure as a potential workplace hazard
within its regulatory or guidance framework.

 

If so, please provide:

• any guidance documents, policies, or internal frameworks relating to
RF/EMF exposure • any standards, references, or external sources relied
upon (e.g. ICNIRP, NZS 2772.1:1999)

 

2. Consideration of RF Exposure in Practice Please provide any documents,
guidance, or internal material that describe how RF/EMF exposure risks are
assessed, monitored, or addressed in workplace contexts (including but not
limited to telecommunications, utilities, or electrical infrastructure
environments).

 

3. Consideration of Smart Meters

Please confirm whether RF exposure from electricity smart meters (Advanced
Metering Infrastructure – AMI) has ever been:

 

• explicitly considered

• implicitly considered as part of broader RF/EMF hazard assessments • or
explicitly excluded from consideration

 

If so, please provide any records, guidance, or communications reflecting
that consideration.

 

4. Scope of Previous Search

For clarity, please outline the scope of the searches undertaken in
response to my previous request (Ref: 260178), including:

 

• which teams, units, or directorates were consulted • whether policy,
regulatory, or inspectorate functions beyond the Energy Safety team were
included

 

5. Absence Confirmation

If no information is held in relation to the above, please confirm whether
this reflects:

 

• that WorkSafe has not undertaken or documented any consideration of
RF/EMF exposure as a workplace risk; or • that such matters are considered
to fall outside WorkSafe’s regulatory scope

 

I am happy to refine the scope of this request under section 13 if
required.

 

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:

[9][FOI #34229 email]

 

Is [10][WorkSafe New Zealand request email] the wrong address for Official Information
requests to WorkSafe New Zealand? If so, please contact us using this
form:

[11]https://aus01.safelinks.protection.outlo...

 

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:

[12]https://aus01.safelinks.protection.outlo...

 

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.

 

 

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

 

[13]www.govt.nz - your guide to finding and using New Zealand government
services

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

Any opinions expressed in this message are not necessarily those of
WorkSafe New Zealand. This message and any files transmitted with it are
confidential and solely for the use of the intended recipient. If you are
not the intended recipient or the person responsible for delivery to the
intended recipient, be advised that you have received this message in
error and that any use is strictly prohibited. Please contact the sender
and delete the message and any attachment from your computer.

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