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