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

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

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