Dear WorkSafe New Zealand,

About 2015 a WorkSafe NZ approved certifier issued a Location Compliance Certificate for the construction of a dangerous goods storage vault for class 4.1 flammable material at Transmitter Rd, Titahi Bay, Wellington. This site is within Whitireia Park on land owned by Radio New Zealand. The applicant was The New Zealand Film Archive (now known as Nga Taonga Sound and Vision) and not Radio New Zealand.

Two years ago I notified WorkSafe NZ that there was a safety issue with this location due to the flammable material being exposed to a known ignition source Radio Frequency Radiation from the nearby AM Radio Transmission Mast.

A WorkSafe Inspector consequently produced a report advising that vault owner Nga Taonga Sound and Vision were adequately managing risks. The Inspector commented that WorkSafe knew nothing about Radio Frequency Radiation but assumed the location of the radiating mast 700 or 800 metres away (actually 520 metres) would have no effect on the flammable material. He also noted that management had requested him to abandon the case.

This year Radio New Zealand intend to erect and energise a new mast located much closer to the dangerous goods vault (about 130 metres). This will considerably increase the risk of inadvertent ignition by radio frequency induced sparking inside the vault.

I have notified WorkSafe of the increased danger and supplied some examples for their consideration. For instance Radio New Zealand themselves recommend no new structure should be built within 1 kilometre of an high power AM Transmission mast. I have also informed WorkSafe of an international standard for determining the safe radius from radio transmission facilities for flammable substances. WorkSafe have to date failed to reply to my correspondence.

My OIA request is for:

1. A copy of the Location Compliance Certificate and any periodic renewals.

2. Evidence that WorkSafe have a copy of the safety standard "Inadvertent Ignition of Flammable Atmospheres by Radio Frequency Radiation" and have applied the recommended initial assessment test, knowing that Nitro-Cellulose Film is highly flammable and while gradually decomposing produces both Methane and Hydrogen gases which are suddenly released from the opening of the metal film cans during an annual inspection process (a time when the risk of sparking is greatest).

3. Evidence that WorkSafe have considered the increased risk of lightning induced damage to the vault electrical systems due to the location close to a very tall mast (an example is the destruction of the Wellington Zephometer wind wand).

Yours faithfully,

P L Ford

Dear WorkSafe New Zealand OIA,

Thank you for your response including the copy of the Location Compliance Certificate.

I have since contacted the compliance certifier Bryan Williamson. He has advised it is up to Acting Deputy General Manager Simon Humphries to decide if WorkSafe consider if the HSNO Legislation statement "Avoid ignition sources unless ignition is intended" also applies to inadvertent ignition from Radio Frequency Radiation. Apparently unless Mt Humphries makes a decision to the contrary then WorkSafe will continue to issue Location Compliance Certificates when they become due.

It was disappointing to learn WorkSafe do not posses the appropriate specialist international safety standards concerning the storage and handling of Nitrate Film and the avoidance of inadvertent ignition from Radio Frequency Radiation. As a consequence it remains unclear how WorkSafe were able to come to the decision that Nga Taonga Sound and Vision have adequately addressed the risk of ignition from Radio Frequency Radiation and/or the storage conditions within the vault comply with "international best practice".

Yours sincerely,

P L Ford