Hazardous Substance Inventory for 1080 stored in Whitianga, October 2017
S C McKee made this Official Information request to Department of Conservation
The request was partially successful.
From: S C McKee
Dear Department of Conservation,
Please provide the following documents.
Pertaining to the bulk storage of 1080 pellets at 20 Joan Gaskell Drive, Whitianga, during October, 2017:
1. The tracking record ( Required HSNO control)
2. The hazardous substance inventory ( Required HSNO control)
3. The Location Test Certificate ( Required HSNO control)
4. The Emergency response plan including fire fighting measures for this Hazchem classification 2XE
6. Copy of the plan that was sent to the local NZ Fire Service Area Manager.
5. Copy or photos of the signage text that was posted on the doors of the building where the bags of 1080 were stored.
Yours faithfully,
S C McKee
From: Penny Loomb
Department of Conservation
Good morning
Please find attached a response to your Official Information Act request.
Regards
Penny Loomb | Personal Assistant to David Speirs, Director – Operations
Department of Conservation | Te Papa Atawhai | Kirikiriroa / Hamilton
Office
Private Bag 3072 | Hamilton 3240 | Level 4 | 73 Rostrevor Street |
Hamilton
DDI: 07 8581007 | M: 027 5366894 | Email: [1][email address]
[2]cid:image004.png@01D2E6A7.D5543C00
-----Original Message-----
From: S C McKee [[3]mailto:[FOI #6832 email]]
Sent: Sunday, 12 November 2017 10:49 p.m.
To: OIA <[4][DOC request email]>
Subject: Official Information request - Hazardous Substance Inventory for
1080 stored in Whitianga, October 2017
Dear Department of Conservation,
Please provide the following documents.
Pertaining to the bulk storage of 1080 pellets at 20 Joan Gaskell Drive,
Whitianga, during October, 2017:
1. The tracking record ( Required HSNO control) 2. The hazardous substance
inventory ( Required HSNO control) 3. The Location Test Certificate (
Required HSNO control) 4. The Emergency response plan including fire
fighting measures for this Hazchem classification 2XE 6. Copy of the plan
that was sent to the local NZ Fire Service Area Manager.
5. Copy or photos of the signage text that was posted on the doors of the
building where the bags of 1080 were stored.
Yours faithfully,
S C McKee
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From: S C McKee
Dear Penny Loomb,
Thank you for your response to my OIA request regarding the Hazardous Substance Inventory for 1080 stored in Whitianga, October 2017.
That is good you removed names to respect privacy of staff and protect staff from harassment. I am only interested in processes and regulations around this storage of 23,000kg of 1080.
I note that the 23tonnes of 1080 was stored in a building at 20 Joan Gaskell Drive, in the Whitianga CBD, near a Liquor Store and Supermarkets for over four months, while the neighbours, local residents and the local fire chief were unaware of this. The bulk 1080 was stored from the 8th June, but I understand that DoC did not receive the permit to go ahead with the 1080 drops until 23rd September, after only applying for the permit from the Waikato District Health Board on the 11th/13th August, 2017.
You claim that the Emergency Response plan did not require you to inform the local Fire Chief. Yet in the MSDS the manufacturer states that in the event of a fire, combustion of the 1080 baits , once heated, will produce toxic Hydrogen Fluoride gas, requiring evacuation of the area. The HAZCHEM Classification E means Evacuation. It is negligent that the Department did not preprare a proper Emergency Response Plan. A "she'll be right" attitude is not acceptable with dealing with Class 1A Ecotoxins.
Warehouse fires can happen, such as the 2006 Murupara combustion of brodifacoum baits causing hospitalisation of 18 people. ( Source: Rotorua Daily Post, 11th Oct , 2006) That fire started with petrol that ignited and spread to the baits. The Fire department was also unaware of the toxic bait being stored.
It is unacceptable to expose the citizens and visitors of Whitianga to this risk without their knowledge. DoC needs to improve its processes and hopefully the new regulations under the Health and Safety at Work Act 2017, will mean this reckless situation will never be repeated.
Yours sincerely,
S C McKee
From: Penny Loomb
Department of Conservation
Thanks for your email, I am on leave, back in the office on 9 January, and
then on leave again until 15 January, and will respond to your email when
I return. For anything urgent please contact reception on 07 8581000.
Regards
Penny
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From: Penny Loomb
Department of Conservation
Good morning
Thank you for your email. I have forwarded this on to the Whitianga Operations Manager for his information.
Regards
Penny Loomb | Personal Assistant to David Speirs, Director – Operations
Department of Conservation | Te Papa Atawhai | Kirikiriroa / Hamilton Office
Private Bag 3072 | Hamilton 3240 | Level 4 | 73 Rostrevor Street | Hamilton
DDI: 07 8581007 | M: 027 5366894 | Email: [email address]
-----Original Message-----
From: S C McKee [mailto:[FOI #6832 email]]
Sent: Tuesday, 19 December 2017 12:59 p.m.
To: Penny Loomb <[email address]>
Subject: Re: FW: Official Information request - Hazardous Substance Inventory for 1080 stored in Whitianga, October 2017
Dear Penny Loomb,
Thank you for your response to my OIA request regarding the Hazardous Substance Inventory for 1080 stored in Whitianga, October 2017.
That is good you removed names to respect privacy of staff and protect staff from harassment. I am only interested in processes and regulations around this storage of 23,000kg of 1080.
I note that the 23tonnes of 1080 was stored in a building at 20 Joan Gaskell Drive, in the Whitianga CBD, near a Liquor Store and Supermarkets for over four months, while the neighbours, local residents and the local fire chief were unaware of this. The bulk 1080 was stored from the 8th June, but I understand that DoC did not receive the permit to go ahead with the 1080 drops until 23rd September, after only applying for the permit from the Waikato District Health Board on the 11th/13th August, 2017.
You claim that the Emergency Response plan did not require you to inform the local Fire Chief. Yet in the MSDS the manufacturer states that in the event of a fire, combustion of the 1080 baits , once heated, will produce toxic Hydrogen Fluoride gas, requiring evacuation of the area. The HAZCHEM Classification E means Evacuation. It is negligent that the Department did not preprare a proper Emergency Response Plan. A "she'll be right" attitude is not acceptable with dealing with Class 1A Ecotoxins.
Warehouse fires can happen, such as the 2006 Murupara combustion of brodifacoum baits causing hospitalisation of 18 people. ( Source: Rotorua Daily Post, 11th Oct , 2006) That fire started with petrol that ignited and spread to the baits. The Fire department was also unaware of the toxic bait being stored.
It is unacceptable to expose the citizens and visitors of Whitianga to this risk without their knowledge. DoC needs to improve its processes and hopefully the new regulations under the Health and Safety at Work Act 2017, will mean this reckless situation will never be repeated.
Yours sincerely,
S C McKee
-----Original Message-----
Good morning
Please find attached a response to your Official Information Act request.
Regards
Penny Loomb | Personal Assistant to David Speirs, Director – Operations
Department of Conservation | Te Papa Atawhai | Kirikiriroa / Hamilton Office Private Bag 3072 | Hamilton 3240 | Level 4 | 73 Rostrevor Street | Hamilton
DDI: 07 8581007 | M: 027 5366894 | Email: [1][email address]
[2]cid:image004.png@01D2E6A7.D5543C00
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Wendy Pond left an annotation ()
DoC has replied (below), but the information sought by McKee and Pond is still not known to us: 1. what total quantity of 1080 poison pellet was delivered to Liquor King warehouse in the Whitianga CBD during 2017; 2. when was it delivered; 3. please provide a Toxic bait tracking sheet showing all arrivals and movements of 1080 toxic bait in and out of store at 20 Joan Gaskell Drive during 2017.
Good afternoon Wendy
Thank you for your further email. The bait for the Papakai operation was delivered to Joan Gaskill Drive on 8 June 2017. The bait for the Moehau/Otahu operation was delivered to an undisclosed location on 13 June 2017 (details of the location were withheld under section 6(c) of the Official Information Act as outlined in the Department's response of 8 February 2018). The toxic bait tracking sheet you refer to was for the Otahu/Moehau operation.
Regards
Penny Loomb
From: S C McKee
Dear Penny Loomb,
Thank you for your letter of 9th January 2018 saying you would forward my letter on to the Whitianga Operations Manager for "his information".
I have not had any reply nor have I heard back that it has been received.
Could you please forward the following questions to the Whitianga Operations Manager? Thank you Penny.
Dear Operations Manager of Whitianga DoC,
When I asked DoC under the Official Information Act to send me the emergency management plan for the storiage of 23,700kg of 1080 baits, I was sent the MSDS - Manufacturer's Safety Data Sheet for the 0.15%1080 possum baits.
In the MSDS it stated that in the event of a fire, the combustion of sodium monofluoroacetate would produce extremely toxic hydrogen fluoride gas. If this happened the firemen would have to be wearing full breathing apparatus.
Yet DoC stated to me that they were "not required" to inform the local fire department!
When toxic baits caught fire in a Murupara warehouse in 2009, the fire brigade not knowing of the bait storage, attended the fire and 18 people were hospitalised from inhaling toxic smoke.
I find it incomprehensible that DoC managers of this operation would not have done a risk-assessment and prepared a proper emergency response plan given the known risks described in the MSDS.
One can only conclude that DoC did not want anyone to know about this 4 month storage of 1080. In other words, the managers decided that this would be secret, and informed no-one, including the TCDC, the Community Council, adjacent residences even the co-tenants of the building. Is this correct?
Question 1 ( under OIA)
Whom did you inform about the storage of the ecotoxic baits in the Liquor King building? ( from June 8th to October 17th )
Question 2 ( under OIA)
When you read the MSDS, why did you not prepare an emergency response plan knowing that in the worst case scenario of a warehouse fire, extremely toxic gas ( hydrogen fluoride) would be produced, requiring evacuation of anyone in its path?
Question 3 ( under OIA)
When you read the MSDS, you would have read that firemen attending a fire of the baits would have to be trained in the use of breathing apparatus. Why did you not check with the fire chief that they had that equipment and that his staff were trained in the use of breathing apparatus?
It is not responsible to simply dismiss my questions as fear-mongering .
Every organisation has to have health and safety and emergency plans for a worst-case scenario. School teachers when taking students on a walk or a school trip have to do a Risk-Assessment and plan for contingencies. Managing hazardous substances such as 23,700 kg of Class A1 ecotoxic baits carries with it a huge responsibility for health and safety. Especially it being stored in the middle of a town.
Under the Health and Safety at Work ( Hazardous Substances) Regulations 2017 from December 1st 2017, you are most certainly required have to have an emergency response plan.
The HSNO Controls for Sodium fluroroacetate cereal-based pellets state the following:
You need an emergency response plan.
Refer to the Emergency Preparation section of Your Practical Guide.
You need to refer to the safety data sheets for your substances to find out what personal protective equipment people using each substance need to wear. Also refer to the Keep Safe with Hazardous Substances section of Your Practical Guide.Under HSE, all substances require the use of protective clothing.
You need secondary containment.
Under the Official Information Act, I expect to receive a reply within 20 days, else I may complain to the Ombudsman.
Yours sincerely,
S C McKee
From: Penny Loomb
Department of Conservation
Good afternoon
Please find attached a response to your Official Information Act request.
Regards
Penny Loomb
Personal Assistant to David Speirs, Director – Operations
Department of Conservation | Te Papa Atawhai
DDI: +64 7 858 1007 | M: +64 27 536 6894 | VPN: 6007
Hamilton Office
Level 4 | 73 Rostrevor Street | Private Bag 3072 | Hamilton 3240
T: +64 7 858 1000
Conservation leadership for our nature Tākina te hī, tiakina te hā, o te
ao tūroa
-----Original Message-----
From: S C McKee [[1]mailto:[FOI #6832 email]]
Sent: Saturday, 24 February 2018 12:48 p.m.
To: Penny Loomb <[2][email address]>
Subject: Re: FW: Official Information request - Hazardous Substance
Inventory for 1080 stored in Whitianga, October 2017
Dear Penny Loomb,
Thank you for your letter of 9th January 2018 saying you would forward my
letter on to the Whitianga Operations Manager for "his information".
I have not had any reply nor have I heard back that it has been received.
Could you please forward the following questions to the Whitianga
Operations Manager? Thank you Penny.
Dear Operations Manager of Whitianga DoC,
When I asked DoC under the Official Information Act to send me the
emergency management plan for the storiage of 23,700kg of 1080 baits, I
was sent the MSDS - Manufacturer's Safety Data Sheet for the 0.15%1080
possum baits.
In the MSDS it stated that in the event of a fire, the combustion of
sodium monofluoroacetate would produce extremely toxic hydrogen fluoride
gas. If this happened the firemen would have to be wearing full breathing
apparatus.
Yet DoC stated to me that they were "not required" to inform the local
fire department!
When toxic baits caught fire in a Murupara warehouse in 2009, the fire
brigade not knowing of the bait storage, attended the fire and 18 people
were hospitalised from inhaling toxic smoke.
I find it incomprehensible that DoC managers of this operation would not
have done a risk-assessment and prepared a proper emergency response plan
given the known risks described in the MSDS.
One can only conclude that DoC did not want anyone to know about this 4
month storage of 1080. In other words, the managers decided that this
would be secret, and informed no-one, including the TCDC, the Community
Council, adjacent residences even the co-tenants of the building. Is this
correct?
Question 1 ( under OIA)
Whom did you inform about the storage of the ecotoxic baits in the Liquor
King building? ( from June 8th to October 17th )
Question 2 ( under OIA)
When you read the MSDS, why did you not prepare an emergency response
plan knowing that in the worst case scenario of a warehouse fire,
extremely toxic gas ( hydrogen fluoride) would be produced, requiring
evacuation of anyone in its path?
Question 3 ( under OIA)
When you read the MSDS, you would have read that firemen attending a fire
of the baits would have to be trained in the use of breathing apparatus.
Why did you not check with the fire chief that they had that equipment and
that his staff were trained in the use of breathing apparatus?
It is not responsible to simply dismiss my questions as fear-mongering .
Every organisation has to have health and safety and emergency plans for a
worst-case scenario. School teachers when taking students on a walk or a
school trip have to do a Risk-Assessment and plan for contingencies.
Managing hazardous substances such as 23,700 kg of Class A1 ecotoxic baits
carries with it a huge responsibility for health and safety. Especially it
being stored in the middle of a town.
Under the Health and Safety at Work ( Hazardous Substances) Regulations
2017 from December 1st 2017, you are most certainly required have to have
an emergency response plan.
The HSNO Controls for Sodium fluroroacetate cereal-based pellets state the
following:
You need an emergency response plan.
Refer to the Emergency Preparation section of Your Practical Guide.
You need to refer to the safety data sheets for your substances to find
out what personal protective equipment people using each substance need to
wear. Also refer to the Keep Safe with Hazardous Substances section of
Your Practical Guide.Under HSE, all substances require the use of
protective clothing.
You need secondary containment.
Under the Official Information Act, I expect to receive a reply within 20
days, else I may complain to the Ombudsman.
Yours sincerely,
S C McKee
-----Original Message-----
Good morning
Please find attached a response to your Official Information Act request.
Regards
Penny Loomb | Personal Assistant to David Speirs, Director – Operations
Department of Conservation | Te Papa Atawhai | Kirikiriroa / Hamilton
Office Private Bag 3072 | Hamilton 3240 | Level 4 | 73 Rostrevor Street
| Hamilton
DDI: 07 8581007 | M: 027 5366894 | Email: [1][email address]
[2][3]cid:image004.png@01D2E6A7.D5543C00
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[4][FOI #6832 email]
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[5]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.
-------------------------------------------------------------------
Caution - This message and accompanying data may contain information that
is confidential or subject to legal privilege. If you are not the intended
recipient you are notified that any use, dissemination, distribution or
copying of this message or data is prohibited. If you received this email
in error, please notify us immediately and erase all copies of the message
and attachments. We apologise for the inconvenience. Thank you.
References
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2. mailto:[email address]
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Wendy Pond left an annotation ()
This request is unresolved because the OIA information supplied to S C McKee appears to be inconsistent with the OIA information supplied to W Pond on 8 February 2018.
The OIA reply to W Pond on 8 February 2017 states that the 1080 pellets arrived at the Whitianga base at 20 Joan Gaskell Drive on 8 June 2017.
The Toxic bait tracking sheet provided to W Pond on 8 February 2018 states that 25,500 kg of 1080 poison pellets came in to store on 13 June 2017.
The Toxic bait tracking sheet provided to S McKee on 6 December 2017 states that 23,700 kg of 1080 poison pellets were held in store on 8 June 2017.
I will ask DoC to provide a definitive statement.
Wendy Pond
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