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Location of Heritage Nitrate Film Dangerous Goods Vault at AM Radio Transmission Site.

P L Ford made this Official Information request to Jacinda Ardern

This request has an unknown status. We're waiting for P L Ford to read recent responses and update the status.

From: P L Ford

Dear Jacinda Ardern,

Two years ago, when you were opposition spokesperson for Culture and Heritage, we corresponded about the risks associated with the location at the High Power AM Radio Transmission site at Titahi Bay Wellington of Nga Taonga Sound and Vision's dangerous goods vault store for the long term storage of pre 1950 Nitrate Films. At that time I was unable to convince you or the then Minister for Culture and Heritage Maggie Barry that the problem was serious enough to require an investigation.

Following the change of government I continued to express my concerns by writing to the Chief Executive of WorkSafe NZ and the Minister responsible, MP Iain Lees-Galloway. CE Nicole Rosie did not reply but to his credit finally MP Iain Lees-Galloway asked WorkSafe management to re-assess the situation.

I offered to provide WorkSafe with details of two international standards I expected the site would normally be expected to comply with:
“PD CLC/TR 50427:2004 Assessment of inadvertent ignition of flammable atmospheres by radio-frequency radiation — Guide” and
“Standard for the Storage and Handling of Cellulose Nitrate Film NFPA-40 2016 Edition”.

Although the site fails both of the above international safety recommendations/standards, Mr Humphries, Acting General Manager of WorkSafe, has advised it is not mandatory for WorkSafe NZ to follow them.

A similar Radio Frequency Radiation situation arose at Homebush, Sydney, Australia in 2003. A local council permitted the erection of an apartment block about 200 metres from an AM Radio Transmission mast energised by two 5 Kw transmitters. When a builder received Radio Frequency burns the Radio Stations were ordered to cease transmission from the particular mast and an investigation was carried out. The result was the Australian Government admitted construction so close to a mast should not have been approved.

The replacement 220m mast at Titahi Bay due to be erected later this year, will be approximately 130 metres from the dangerous goods vault, and will be energised by 50 Kw transmitters. This is worse than the situation in Australia.

Mr Simon Humphries has admitted that WorkSafe do not have copies of the international safety standards quoted above, but he was instead able to conclude that Nga Taonga Sound and Vision had adequately addressed the problem of risk of ignition from Radio Frequency Radiation. Apparently nothing further would be done unless the risks changed after the 220m high replacement mast is erected and energised.

My OIA request is for any information in Government Legislation that permits WorkSafe NZ to refuse to purchase/consider the recommendations in international safety standards when they do not have adequate knowledge themselves and/or take into account similar matters of significance such as the Australian incident.

Yours faithfully,

P L Ford

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From: Rt. Hon Jacinda Ardern

Kia ora,

 

Thanks very much for taking the time to get in touch with Prime Minister
Jacinda Ardern.

We appreciate your email. Because of the large number of emails we
receive each day, you may not receive a response immediately.

While you are waiting for a reply, here's a list of links that may help
you find what you’re looking for:

[1]Beehive website

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[4]Full list of Ministers

 

We hope one of the above links helps answer your question! In any case,
we'll get back to you as soon as possible.

Thanks again.

Authorised by Jacinda Ardern MP, Parliament Buildings, Wellington

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From: Rt. Hon Jacinda Ardern

I am writing on behalf of the Prime Minister, Jacinda Ardern, to acknowledge receipt of your Official Information Act request.

Your request will be responded to under the provisions of the Official Information Act 1982.

Yours sincerely

Dinah Okeby
Office of the Prime Minister

Authorised by Rt Hon Jacinda Ardern MP, Parliament Buildings Wellington 6012

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From: Simone Gordon


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Dear P L Ford

 

Please see attached letter

 

Kind regards

 

Office of the Prime Minister

 

DDI +64 4 817 8700

 

Authorised by Rt. Hon Jacinda Ardern MP, Parliament Buildings, Wellington

 

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From: P L Ford

Dear Simone Gordon and/or Mike Munro,

Thank you for your reply to my FYI OIA request.

I note you have decided to refer my request to Hon Iain Lees-Galloway. Mr Lees Galloway has already asked WorkSafe NZ on more than one occasion to look into this matter. WorkSafe remain adamant there is minimal risk of damage to the heritage Nitrate Films stored near a High Power AM Transmitting mast and have accordingly recently renewed the site location compliance certificate.

As the Minister for Culture and Heritage I am sure that Hon Jacinda Ardern (and Associate Ministers Grant Robertson or Carmel Sepuloni) would be very interested to know about the danger, especially with the greatly increased risk of possible destruction of the entire heritage collection once a replacement transmission mast is erected close to the dangerous goods storage vault later this year.

May I suggest that, as well as transferring my request to Iain Lees-Galloway, you inform the Prime Minster and the Associated Ministers of the problem, including informing them of the Australian Government investigation into a similar issue where it was found an error was made in permitting the construction of a building not associated with Radio Transmission close to an AM Transmission mast.

Yours sincerely,

P L Ford

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From: I Lees-Galloway (MIN)
Jacinda Ardern


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Dear P L Ford,

 

I am writing to acknowledge receipt of your official information request
dated 24-May 2018 for,

 

“Any information in the Government Legislation that permits WorkSafe NZ to
refuse to purchase/ consider the recommendation in international safety
standards when they do not have adequate knowledge themselves and/or take
in to account similar matters of significance such as the Australian
incident.”

 

We received transfer of your request 6-June 2018. We will endeavour to
respond to your request as soon as possible and in any event no later than
4-July 2018, being 20 working days after the day your request was
received.

 

If we are unable to respond to your request by then, we will notify you of
an extension of that timeframe.

 

Yours Sincerely

 

[1]Crest Office Hon Iain Lees-Galloway

Minister of Immigration |Minister for Workplace Relations &
Safety | Minister of ACC | Deputy Leader of the House | MP for
Palmerston North | 4.5R, Executive Wing |Parliament Buildings |
Private Bag 18041 | Wellington 6160 | New Zealand | P: 64 (4) 817
8713

                         Authorised by Iain Lees-Galloway, Parliament
Buildings, Wellington 6011

 

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Joss J. left an annotation ()

Just saw this information on Wikipedia. It may help if it becomes a Crown Entity so they take your concerns more seriously:
"In June 2018, Internal Affairs Minister Tracey Martin and the Associate Minister for Arts, Culture and Heritage Grant Robertson announced a National Archival and Library Institutions Ministerial Group. As part of its remit, the group will "investigate options for ensuring Ngā Taonga Sound & Vision has appropriate governance, and a sustainable structure and funding (this will include a consideration of whether Ngā Taonga Sound & Vision should be established as a Crown entity)"

https://en.wikipedia.org/wiki/Ng%C4%81_T...

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P L Ford left an annotation ()

Dear Joss J,

Thank you for your annotation. Some very useful information. Correspondingly I have sent the following text to the working group ministers.

Dear Honourable Sirs and Madams,

I was recently informed of the formation of a National Archival and Library Institutions Ministerial Working Group. I would like to make a detailed submission in regard to the remit to “investigate options for ensuring Ngā Taonga Sound & Vision has appropriate governance, and a sustainable structure and funding (this will include a consideration of whether Ngā Taonga Sound & Vision should be established as a Crown entity)”. Please advise if and how I may do this?

My background. I am retired from a technical career in Radio, Television and Telecommunications. At various times I had contracts with Nga Taonga Sound and Vision (then the New Zealand Film Archive) mainly to attempt recovery of heritage material from obsolete analogue video formats.

More recently I have been trying to inform Ministers of a situation putting almost the entire collection of pre 1950 Nitrate Films at risk of destruction. This is due to the collection being stored within the intense electromagnetic field of the high power AM radio transmission site at Titahi Bay. The location is subjecting the collection to the risk of inadvertent ignition from radio frequency sparking.

NTSV appear to have completely disregarded recommendations in the two relevant international safety standards;

Standard for the Storage and Handling of Cellulose Nitrate Film NFPA-40

PD CLC/TR 50427:2004 Assessment of inadvertent ignition of flammable atmospheres by radio-frequency radiation — Guide.

For example NFPA-40 states a Nitrate Film fire is almost impossible to extinguish. Burning Nitrate Film will continue to burn even underwater and the only suitable fire protection method is by storing film cans stacked no more than two high (recently tightened down from six high) in isolated “pigeon holes” constructed of no-conductive material and the installation of an automated water deluge sprinkler system (to quickly lower temperature). Apparently NTSV have stacked film cans eight high on metal shelving and the fire control method is by provision of a bucket of water at the entrance to the dangerous goods storage vault.

In Homebush, Sydney, Australia a builder received radio frequency burns when working on the construction of a new apartment building 200 meters from an AM transmission mast energized by two 5 Kilowatt transmitters. The owners of the mast were ordered to immediately stop transmission while an investigation was carried out. Eventually the Australian Government admitted the apartment building was far too close to the mast and construction should never have been permitted.

In New Zealand, after the earthquakes in Christchurch, there was a proposal to rezone the land around the Gebbies Pass AM transmission site for new housing. Radio New Zealand submitted that there would be problems from Radio Frequency radiation if new buildings were erected closer than 1 kilometer from the mast.

Later this year Radio New Zealand intend to erect a replacement mast at the Titahi Bay site about 130 meters from the Nitrate Film dangerous goods vault. It is to be energized by 50 Kilowatt transmitters. In addition it is well known that tall masts attract lightning. The transmitters and transmitter building is designed to withstand damage from such a strike. The Nitrate Film storage vault has not been included in the lightning protection design and electrical systems inside such as alarms and air conditioning equipment is likely to sustain damage. Obviously the above two factors greatly increase the risk of an accident. Unfortunately WorkSafe NZ are refusing to investigate as they have been assured by NTSV all risks are being correctly managed.

About 15 years ago the New Zealand Film Archive borrowed from me a fairly valuable working heritage Video Character Generator. Management thought it was junk and disposed of it.

Carelessness by NZ Film Archive staff and management has resulted in irreparable damage to very rare Video Recorders. Six of the large and heavy machines were originally purchased to record and edit the Commonwealth games in 1974. The Film Archive inherited a pair when they were retired from service at the Avalon Television centre. One of them they dropped off the back of a truck and completely destroyed it. Later the second one failed after it got (accidentally?) covered in sawdust. The Film Archive then decided it was uneconomical to strip it down for repair. At the time it was the only surviving working machine of the particular type (Ampex AVR1) and absolutely the best machine for the recovery of pre 1980 Broadcast Television tapes.

I can supply the working group with a lot more detail about the incidents described above. It is my opinion that NTSV management is not fit to be the custodians of our Film and Video heritage.

P Ford

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From: I Lees-Galloway (MIN)
Jacinda Ardern


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Good Afternoon,

 

Please find attached a response to your OIA request from Hon Iain
Lees-Galloway, Minister for Workplace Relations and Safety.

 

Kind regards,

 

 

[1]Crest Office Hon Iain Lees-Galloway

Minister of Immigration |Minister for Workplace Relations &
Safety | Minister of ACC | Deputy Leader of the House | MP for
Palmerston North | 4.5R, Executive Wing |Parliament Buildings |
Private Bag 18041 | Wellington 6160 | New Zealand | P: 64 (4) 817
8713

                         Authorised by Iain Lees-Galloway, Parliament
Buildings, Wellington 6011

 

From: I Lees-Galloway (MIN)
Sent: Wednesday, 13 June 2018 10:10 AM
To: [FOI #7928 email]
Subject: OIA Ack Transfer | P L Ford | 6-June 2018

 

 

Dear P L Ford,

 

I am writing to acknowledge receipt of your official information request
dated 24-May 2018 for,

 

“Any information in the Government Legislation that permits WorkSafe NZ to
refuse to purchase/ consider the recommendation in international safety
standards when they do not have adequate knowledge themselves and/or take
in to account similar matters of significance such as the Australian
incident.”

 

We received transfer of your request 6-June 2018. We will endeavour to
respond to your request as soon as possible and in any event no later than
4-July 2018, being 20 working days after the day your request was
received.

 

If we are unable to respond to your request by then, we will notify you of
an extension of that timeframe.

 

Yours Sincerely

 

[2]Crest Office Hon Iain Lees-Galloway

Minister of Immigration |Minister for Workplace Relations &
Safety | Minister of ACC | Deputy Leader of the House | MP for
Palmerston North | 4.5R, Executive Wing |Parliament Buildings |
Private Bag 18041 | Wellington 6160 | New Zealand | P: 64 (4) 817
8713

                         Authorised by Iain Lees-Galloway, Parliament
Buildings, Wellington 6011

 

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From: P L Ford

Dear I Lees-Galloway (MIN),

Thank you for your reply. After lodging my OIA request I was informed that a Ministerial Working Group is to be set up to investigate, among other things, if Nga Taonga Sound and Vision should be made a crown entity. I intend to make a submission.

I am not sure I follow your logic in the comment "experts do not always agree". In this case the possibility of Inadvertent Ignition by Radio Frequency Radiation has been extensively researched over many years by a European working group. Nga Taonga are not experts in this field, yet they have managed to convince WorkSafe there is not a potential problem.

Similarly handling and storage of Nitrate Film to ensure safety has been extensively studied in USA. The experts have concluded an automated water deluge sprinkler system is mandatory as has been installed at the Archives NZ small Nitrate storage vault in Wellington. Nga Taonga have decided a bucket of water at the door should be adequate. This has been approved by WorkSafe.

If you are comfortable that WorkSafe have made the correct decisions then I guess there is nothing further I can do, except hope the dangerous goods storage vault does not explode and nobody is killed.

Yours sincerely,

P L Ford

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From: I Lees-Galloway (MIN)
Jacinda Ardern

On behalf of Hon Iain Lees-Galloway, Minister of Immigration, Minister for
ACC and Minister for Workplace Relations and Safety thank you for your
email. Please consider this email as an acknowledgement.

Thank you for taking the time to write and please be assured that your
comments will be read by the Minister. However, there may be no further
response to you.

Kind regards,

Office of Hon Iain Lees-Galloway

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