23 April 2026
File Ref: 260282
Spencer Jones
Via FYI.org.nz
Dear Spencer
Thank you for your Official Information Act (the Act) request received on 24 March 2026. You
requested:
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
PO Box 165, Wellington 6140
RF/EMF as a Workplace Hazard WorkSafe recognises that there are potential risks to health stemming from exposure to
radiofrequencies and electromagnetic fields (EMF) exceeding the limits set by applicable exposure
standards such as NZS 2772. For further information, see the Ministry of Health webpage on non-
ionising fields:
Radiofrequency field exposure standard. WorkSafe’s role as a regulator under the Health and Safety at Work Act 2015 (HSWA) is not to
determine what constitutes a potential hazard and subsequently hold information used to make
that determination. Instead, businesses are required under HSWA to identify potential hazards
within their workplace and manage so far as is reasonably practicable.
As such this part of your request is refused under section 18(e) of the Act as the information
requested does not exist or, despite reasonable efforts to locate it, cannot be found.
Consideration of RF Exposure in Practice The WorkSafe website has the fol owing documents which contains some guidance for EMF:
Health and safety by design: an introduction | WorkSafe Safe use of machinery | WorkSafe
WorkSafe also holds a copy of the
2010 American Conference of Government Industrial Hygienists
(ACGIH) Time Limit Values (TLV) for Radiofrequency and Microwave Radiation.
WorkSafe would
refer to reference material such as this if required.
This document is available to purchase through the American Conference of Governmental
Industrial Hygienist’s website here:
RADIOFREQUENCY/MICROWAVE RADIATION - ACGIH
This part of your request has been refused under section 18(d) of the Act, as the information
requested is publicly available, noting that publicly available can also mean that the information is
available for purchase.
Consideration of Smart Meters RF Exposure I refer this part of your request to our previous response, reference 260178, advising that
WorkSafe does not hold information on RF exposure from electricity smart meters. WorkSafe has
not explicitly considered RF exposure from smart meters as distinct from any other potential
exposure source.
Scope of Previous Search As your previous request was seeking records on WorkSafe’s consideration of RF exposure
specifically for Smart Meters, the Energy Safety team were asked to confirm what information
would be held on this topic. Researching would have identified any references to EMF or RF,
regardless of their origin.
This reply addresses the information you requested. You have the right to ask the Ombudsman to
investigate and review my decision, and further information is available at
www.ombudsman.parliament.nz. If you require further assistance, please contact
[email address]. Yours sincerely
Rob Pope
Head of Inspectorate
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