Land Contamination Topic Report

Transcription

1 Land Contamination Topic Report Warkworth Structure Plan March 2018 Prepared by Marija Jukic (Senior Specialist, Resource Consents)

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3 Warkworth Structure Plan Contaminated Land Topic Report 3 Table of Contents Executive Summary Introduction Existing environment Planning context Other Relevant Regulations Constraints, opportunities, and information gaps References... 19

4 4 Warkworth Structure Plan Contaminated Land Topic Report Executive Summary This report outlines the existing environment within the Warkworth Structure plan project area with regards to contaminated land, and assesses the opportunities, constraints, and gaps in information in relation to this topic. A limited desktop assessment undertaken in preparation of this report identified that the majority of the study area has historically been and continues to be utilised for pastoral farmland and rural-residential purposes. Although these land uses are generally considered to be low risk with regards to contamination, localised occurrences may exist, resulting from a number of potential sources, including: Livestock dips or spray race operations in pastoral farmland areas; On-site wastewater disposal systems; Asbestos; Lead-based paints; Burial and burning of farm waste; Importation of unverified fill; Fuel storage. Eight properties within the study area are known or are suspected to have been utilised for horticultural purposes, including market gardening, orchards, green houses and viticulture. Persistent bulk storage and use of pesticides (HAIL Category A10) are commonly associated with such horticultural activities. Other potentially contaminating HAIL activities identified within the study area included: A golf driving range and air rifle shooting range at a single property. The primary contaminant of concern associated with air rifle shooting ranges is lead, whilst persistent bulk storage and use of chemicals such as pesticides (HAIL Category A10) are the primary HAIL activities carried out at golf ranges. A motor mechanic workshop was identified at one property. Depending on the age and condition of the workshop infrastructure, including floors and drainage pits, waste disposal practices, and depth of groundwater beneath the site, the level of contamination could range from negligible to significant. A spare car parts business at a single property. As with the motor mechanics workshop, the level of contamination will depend on the age and condition of the workshop infrastructure, including floors and drainage pits waste disposal practices, and depth of groundwater beneath the site. A search of the Council s consent database revealed that a property had held a consent to discharge wastewater including wash down from stock holding pens, from an abattoir operation. The consent expired in Given the length of time since the assumed cessation of operations, no biological or nutrient issues are

5 Warkworth Structure Plan Contaminated Land Topic Report 5 anticipated to be of concern. However, any chemicals used by the abattoir for cleaning and disinfecting purposes may potentially have impacted the site soils. Two properties appear to be utilised as laydown/ storage areas, one for a freight company and the second for a drilling company. Whether the properties can be assessed as potential or actual HAIL sites will depend in part on the type of freight or drilling equipment/chemicals being stored, and whether vehicle/drill equipment maintenance works are carried out on these properties. An evaluation of the constraints, opportunities and information gaps with respect to contaminated land was carried out, and determined that further assessments within the study area, particularly land proposed for high sensitivity end use, such as residential, children s play areas, child care centres, schools and rest homes would be required at the resource consent stage. These would include: A comprehensive Preliminary Site Investigation, carried out in accordance the Ministry for the Environment s Contaminated Land Management Guidelines No. 1 Reporting on Contaminated Site In New Zealand, which includes a site walkover, interviews with property owners or person knowledgeable of the site history and a review of Council property files, to confirm the actual or potential location and nature of HAIL activities. Should the PSI identify that HAIL activities are more likely than not to have occurred on a property within the study area, then a detailed site investigation (DSI) carried out in accordance the Ministry for the Environment s Contaminated Land Management Guidelines No. 1 Reporting on Contaminated Site In New Zealand and No.5 Site Investigation and Analysis of Soils, including sampling and analysis programme(s) will be required. On the basis of the results of the DSI, the requirement for remedial works and/or resource consents would be assessed. However, overall it is considered that issues arising from contaminated land are unlikely to present significant constraints to land development in the study area. In general, contamination within rural-residential, pastoral farmland properties, if present, is likely to occur as discrete, low volume hotspots (although it is recognised concentrations may be high), whilst contamination associated with the horticultural and recreational land uses identified in this review are likely to be dispersed at lower levels across the properties. It is noted that portions of the study site abut areas currently zoned Business-Light Industry Zone under the AUP (OP). Depending on the contamination status and activities undertaken within these areas, there may be some restrictions on future land use on immediately adjacent land. On this basis, it is recommended that further assessment of this land and its potential impact on the adjacent part of the study area (and other impact assessments) be undertaken, particularly Hudson Road, prior to any urban zoning.

6 6 Warkworth Structure Plan Contaminated Land Topic Report 1 Introduction 1.1 Purpose and scope of the report This is one of a number of topic papers that have been prepared for the Warkworth Structure Plan project. This report outlines the existing environment with regards to contaminated land and summarises the opportunities and constraints of the study area and gaps in information in respect to contaminated land. 1.2 Study Area The study area is the Future Urban zone around Warkworth. It comprises around 1,000ha of land. The study area is shown outlined in red on Figure 1 below. Figure 1: Warkworth Structure Plan study area (outlined in red)

7 Warkworth Structure Plan Contaminated Land Topic Report 7 2 Existing environment As part of the preparation of this topic report, a limited desktop assessment of the historical and current land uses has been undertaken for the study area in relation to potentially contaminating activities, as prescribed on the Ministry for the Environment s Hazardous Activities and Industries List (HAIL). The information gathered as part of this report has included: a) A review of historical aerial photographs obtained from Auckland Council s GeoMaps GIS database and the Local Government Geospatial Alliance s historical imagery resource Retrolens, to identify any indicator of potentially contaminating land uses. b) A review of the Council s resource consents database to assess what consents have been granted and permitted activities undertaken within the study area that may be associated with contaminating activities. c) A high level site visit of the study area (utilising public land only). The assessment has indicated that the majority of the study area has historically been and continues to be utilised for pastoral farmland and rural-residential purposes. Although these land uses are generally considered to be low risk with regards to contamination, localised occurrences may exist, resulting from the following potential sources: a) Livestock dips or spray race operations in pastoral farmland areas Dipping sheep to control external parasites was a legal requirement in New Zealand from 1849 to Due to the associated use of chemicals containing arsenic and organophosphorus pesticides, and the resulting potential impact to human health and the environment, livestock dips or spray race operations are classed as a contaminating activity (HAIL Category A8). b) On-site wastewater disposal systems On-site wastewater disposal systems which usually comprise septic tanks, associated pipework and disposal fields, are considered as potential HAIL activities (HAIL Categories G5 - waste disposal to land, and G6 - waste recycling or waste or wastewater treatment), due to the presence of biological contaminants, nutrients and potential heavy metals that may impact human health and the environment. c) Asbestos Asbestos was a common building material in New Zealand between the 1920s and the mid-1980s, although it may have been used up until It was utilised for a range of purposes, including wall or roof cladding, insulation, soffit fittings, backing to vinyl flooring and in decorative plaster and textured ceilings.

8 8 Warkworth Structure Plan Contaminated Land Topic Report Given the age of a number of the buildings within the study area, including residences, farm sheds and commercial buildings, it is considered that asbestos may be present at some of the properties where former site buildings have been demolished. d) Lead-based paints Lead-based paints were commonly used on NZ building until the early 1980s. Although lead levels in the paints were reduced over the decades (white lead was phased out in the in the mid-1960s, lead chromate was disused in the late 1970s, wood primers containing red lead paint were phased out in the 1980s and roof coatings containing calcium plumbate ceased being used in the 1990s), it is considered that a number of buildings within the study area are sufficiently old that surrounding soils in the immediate vicinity of these buildings may be impacted by the historical use of these paints. e) Burial and burning of farm waste Common waste disposal practices carried out on New Zealand farms, despite their illegality, have been the burial or burning of contaminated waste. Depending on the material burnt or buried, these activities may have resulted in impacts to both the environment and human health, and can be classified as a HAIL activity under Category G5 - waste disposal to land. f) Importation of unverified fill The importation of unverified fill material for farm maintenance works, such as, the upkeep of tracks, backfilling areas susceptible to waterlogging and erosion, and infilling gullies, is recognised as a potential HAIL activity (Category I Any land that has been subject to the intentional or accidental release of hazardous substances in sufficient quantity that it could be a risk to human health or the environment). Contaminants commonly associated with unverified fill material include heavy metals, polycyclic aromatic hydrocarbons and asbestos, although other contaminants may also be present in the material, depending on the source of the fill. g) Fuel storage The storage of fuel on-site for farm vehicles and other plant (HAIL Category A17 Storage tanks or drums for fuel, chemicals or liquid waste) is commonly undertaken on rural properties. Eight properties within the study area are known or are suspected to have been utilised for horticultural purposes, including market gardening, orchards, green houses and viticulture. Persistent bulk storage and use of pesticides (HAIL Category A10) are commonly associated with such horticultural activities. As spraying is the primary method by which pesticides are normally applied to crops, it is anticipated that contaminants are likely to be

9 Warkworth Structure Plan Contaminated Land Topic Report 9 of low concentration and dispersed relatively uniformly across a property, although hotspots of higher contaminant concentrations may occur in areas such as storage sheds and at locations where the chemicals were mixed/prepared. It is noted that properties surrounding these eight horticultural sites would require assessment for potential spray drift impacts. Other potentially contaminating HAIL activities identified within the study area include: a) A golf range and air rifle shooting range at a single property. The primary contaminants of concern associated with air shooting ranges (HAIL Category C2) are selected heavy metals, whilst persistent bulk storage and use of chemicals such as pesticides (HAIL Category A10) are the primary HAIL activities carried out at golf ranges. As with horticultural land use, it is anticipated that contamination across the golf and air rifle ranges would be of a dispersive nature. b) A motor mechanic workshop was identified at one property. Contaminants of concern associated with motor vehicle maintenance include hydrocarbons, solvents and heavy metals. Depending on the age and condition of the workshop infrastructure, including floors and drainage pits, waste disposal practices, and depth of groundwater beneath the site, the level of contamination could range from negligible to significant. c) A spare car parts business at a single property. As with the motor mechanics workshop, the level of contamination will depend on the age and condition of the workshop infrastructure, including floors and drainage pits waste disposal practices, and depth of groundwater beneath the site. d) Search of the Council s consent database revealed that a property had held a consent to discharge wastewater including wash down from stock holding pens, from an abattoir operation. The consent expired in Given the length of time since the assumed cessation of operations, no biological or nutrient issues are anticipated to be of concern. However, any chemicals used by the abattoir for cleaning and disinfecting purposes may potentially have impacted the site soils. Two properties appear to be utilised as laydown/ storage areas, one for a freight company and the second for a drilling company. Whether the properties can be assessed as potential or actual HAIL sites will depend in part on the type of freight or drilling equipment/chemicals being stored, and whether vehicle/drill equipment maintenance works are carried out on these properties. It is noted that portions of the study site abut areas currently zoned Business-Light Industry Zone under the AUP (OP). Depending on the contamination status and activities undertaken within these areas, there may be some restrictions on future land use on immediately adjacent land.

10 10 Warkworth Structure Plan Contaminated Land Topic Report 3 Planning context 3.1 National Policy Statement/s National policy statements are instruments issued under section 52(2) of the Resource Management Act 1991 and state objectives and policies for matters of national significance. Although there is no specific national policy statement that deals directly with contaminated land, a number of the objectives in the National Policy Statement for Freshwater Management (2017) relate to the management of discharges of contaminants into the environment. The National Policy Statement for Freshwater Management provides direction on how local authorities should carry out their responsibilities under the Resource Management Act 1991 for managing freshwater, and guides them, in consultation with their communities, to set objectives for the state of fresh water bodies in their regions and to set limits on resource use to meet these objectives. Objective A1 relates directly to the discharge of contaminants, and states: To safeguard: a) The life-supporting capacity, ecosystem processes and indigenous species including their associated ecosystems, of fresh water; and b) The health of people and communities, as affected by contact with fresh water; in sustainably managing the use and development of land, and of discharges of contaminants. Supporting policies include: Policy A2 Where freshwater management units do not meet the fresh water objectives made pursuant to Policy A1, every regional council is to specify targets and implement methods (either or both regulatory and non-regulatory), in a way that considers the sources of relevant contaminants recorded under Policy CC1, to assist the improvement of water quality in the freshwater management units, to meet those targets, and within a defined timeframe. Policy A3 By regional councils: a) Imposing conditions on discharge permits to ensure the limits and targets specified pursuant to Policy A1 and Policy A2 can be met; and b) Where permissible, making rules requiring the adoption of the best practicable option to prevent or minimise any actually or likely adverse effect on the environment of any

11 Warkworth Structure Plan Contaminated Land Topic Report 11 discharge of contaminant into fresh water, or onto or into land in circumstances that may result in that contaminant (or, as a result of a natural process from the discharge of that contaminant, any other contaminant) entering fresh water. Policy A4 and direction (under section 55 of the RMA) to regional councils By every regional council amending regional plans (without using the process in Schedule 1) to the extent needed to ensure the plans include the following policy to apply until any changes under Schedule 1 to give effect to Policy A1 and Policy A2 (freshwater quality limits and targets) have become operative: 1. When considering any application for a discharge the consent authority must have regards to the following matters: a) The extent to which the discharge would avoid contamination that will have an adverse effect on the life-supporting capacity of fresh water including on any ecosystem associated with fresh water and b) The extent to which it is feasible and dependable that any more than minor adverse effect on fresh water, and on any ecosystem associated with fresh water, resulting from the discharge would be avoided. 2. When considering any application for a discharge the consent authority must have regard to the following matters: a) The extent to which the discharge would avoid contamination that will have an adverse effect on the health of people and communities as affected by their contact with fresh water; and b) The extent to which it is feasible and dependable that any more than minor adverse effect on the health of people and communities as affected by their contact with fresh water resulting from the discharge would be avoided. 3. This policy applies to the following discharges (including a diffuse discharge by any person or animal): a) A new discharge or b) A change or increase in any discharge of any contaminant into fresh water, or onto or into land in circumstances that may result in that contaminant (or, as a result of any natural process from the discharge of that contaminant, any other contaminant) entering fresh water. Objective C1 below highlights the importance of considering the links between land use and the potential impacts on the surrounding environment. To improve integrated management of fresh water and the use and development of land in whole catchments, including the interactions between fresh water, land, associated ecosystems and the coastal environment.

12 12 Warkworth Structure Plan Contaminated Land Topic Report Supporting policies include: Policy C1 By every regional council: a) Recognising the interactions, ki uta ki tai (from the mountains to the sea) between fresh water, land, associated ecosystems and the coastal environment; and b) Managing fresh water and land use and development in catchments in an integrated and sustainable way to avoid, remedy or mitigate adverse effects, including cumulative effects. Policy C2 By every regional council making or changing regional policy statements to the extent needed to provide for the integrated management of the effects of the use and development of: a) Land on fresh water, including encouraging the co-ordination and sequencing of regional and /or urban growth, land use and development and the provision of infrastructure; and b) Land and fresh water on coastal water. 3.2 The Auckland Plan (2012) The Auckland Plan 2012 sets the overall development strategy to accommodate future growth in Auckland up to the year 2040, with up to 40 per cent of growth anticipated to occur in greenfield areas, satellite towns, and rural and coastal towns. Although no specific reference to contamination is provided in the Plan, we consider that the assessment and appropriate management of contaminated land (including remediation and monitoring, where necessary) to ensure minimal impacts to the environment and human health comply with the Plan s Environmental Principles, which include: Auckland s environment must be healthy and resilient in order to support life and lifestyles. To ensure this we must recognise that: 1. The environment supports us the natural resources provided by our environment has limits, and must be protected and restored to ensure our future well-being. 2. We need to consider environmental values in all that we do the interaction between the environment and people is understood and considered in our everyday behaviour and choices. 3. Everything is connected human activities affect the air, sea, land and freshwater systems. Understanding the connections between environments in the way we manage them is critical. 4. We are environmental stewards future generations will depend on hour we manage the natural environment.

13 Warkworth Structure Plan Contaminated Land Topic Report Draft Auckland Plan (2018) A revision of the Auckland Plan (2012) is being publicly notified in February/March As with the original Auckland Plan, although contaminated land is not specifically mentioned, the draft plan reinforces the direction of the Auckland Plan (2012) in relation to the preservation, protection and care of the and natural environment. The proposed environmental and cultural heritage outcome of the Draft Auckland Plan (2018) states: Auckland preserve, protect and care for the natural environment as our shared cultural heritage for its intrinsic value and for the benefit of present and future generations. Key Directions and Focus Areas supporting this outcome include: Direction 1 Ensure Auckland s environment and ecosystems are valued and cared for. Direction 3 Use growth and development to protect and enhance Auckland s environment. Focus Area 1: Encourage all Aucklanders to be stewards of the environment, and to make sustainable choices. Focus Area 2: Focus on restoring environment as Auckland grows. Focus Area 3: Account fully for the past and future impacts of growth. We consider that the assessment and appropriate management of contaminated land are important components in the successful achievement of the proposed outcome. 3.4 The Auckland Unitary Plan (Operative in Part) (2016) The Auckland Unitary Plan (Operative in Part) became operative in part on 15 November Regional Policy Statement Section B10.4 (Land- Contaminated) of the Auckland Unitary Plan (Operative in Part) (AUP OP) Regional Statement Policy speaks directly to the issues of contaminated land and provides clear objectives and policies with respect to their assessment and management. B Objective (1) Human health and the quality of air, land and water resources are protected by the identification, management and remediation of land that is contaminated. B Policies (1) Identify land that is or may be contaminated based on: (a) Sites known to have supported contaminating land use activities in the past; (b) Sites with a significant potential risk to human health; or

14 14 Warkworth Structure Plan Contaminated Land Topic Report (c) Sites having significant adverse effects on the environment. (2) Land which may be contaminated due to having supported contaminating land use activities in the past but has not been investigated will be identified as being potentially contaminated. (3) Manage of remediate land that is contaminated where: (a) The level of contamination renders the land unsuitable for its existing or proposed use; or (b) The discharge of contaminants from the land is generating or is likely to general significant adverse effects on the environment; or (c) Development or subdivision of land is proposed. District Plan (Chapter E Auckland wide Environmental Risk) Specific provisions to manage the environmental risks associated with contaminated land are provided in Section E30 of the AUP (OP). All rules relating to contaminated land have been made fully operative. Section E30 addresses the effects of the discharge of contaminants from contaminated land or land containing elevated levels of contaminants into air, or into water, or onto or into land pursuant to section 15 of the Resource Management Act This section contains thresholds beyond which a risk assessment process is required to determine whether the discharge will result in significant adverse effects, or whether it can be remediated or managed. It also sets out the contaminant discharge consenting requirements.

15 Warkworth Structure Plan Contaminated Land Topic Report 15 4 Other Relevant Regulations 4.1 National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health 2011 National environmental standards are regulations that prescribe standards for environmental and human health protection matters. The government sets standards where appropriate to ensure a consistent standard for an activity or resource use. The National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health 2011 (NES) provides a national environmental standard for activities on pieces of land where soil may be contaminated in such a way as to pose a risk to human health. Activities covered under the NES regulations include removing or replacing a fuel storage system, soil sampling, soil disturbance, subdivision, and changing the use of a piece of land. The NES sets soil contamination standards that define an adequate level of protection of human health for a range of differing land uses (rural, residential, recreational and commercial/industrial) and contaminant exposure pathways (ingestion, inhalation and dermal contact). In relation to the study area, evaluation of the proposed development under the NES regulations would be required at the resource consent stage, if subdivision or a change of land use was proposed at a property or on a piece of land where a HAIL activity was known to have or suspected to have been carried out, that may have resulted in contamination. 4.2 Health and Safety at Work (Asbestos) Regulation (2016) The Health and Safety at Work (Asbestos) Regulation (2016) details the requirements regarding asbestos contamination, including eliminating and minimising risk to health and safety. An Approved Code of Practice has been prepared by WorkSafe New Zealand, which details how to identify and control the work health and safety risks arising from asbestos, in order to assist with the compliance of this regulation and with the Health and Safety at Work Act 2015.

16 16 Warkworth Structure Plan Contaminated Land Topic Report 5 Constraints, opportunities, and information gaps This section summarises the contaminated land constraints and opportunities of the structure plan area and information gaps. 5.1 Constraints HAIL activities have been identified as having or potentially having occurred within the study area; and therefore further contamination assessment will be required to confirm the contamination status of properties across the study area. Should further assessment indicate the presence of contamination at levels that may impact human health or the environment, restrictions may be placed on future land use changes if no remedial works are proposed, or require resource consents and/or the completion of remedial work to ensure the protection of human health and the environment. There may be some restrictions on future land use changes on land immediately adjoining properties located within the areas currently zoned Business-Light Industry Zone under the AUP (OP), depending on contaminant migration and associated potential impacts. Zoning considerations must be given to future land use changes where reverse sensitivity issues arise, such as land adjoining areas zoned for Business-Light Industry or Business Heavy Industry. All future developments within the study area will require evaluation under the resource consenting process to determine whether proposed development is a permitted activity or requires a resource consent. 5.2 Opportunities Opportunities that have been identified in relation to contaminated land include: The opportunity to address any contamination issues as part of the future plan change process in line with Direction 3 of the Auckland Plan (2018) to use growth and development to protect and enhance Auckland s environment and with Environmental Principle 1 of the Auckland Plan (2012) that states: The environment supports us the natural resources provided by our environment has limits, and must be protected and restored to ensure our future well-being. There are opportunities to further protect more sensitive land use areas such as Open Space zones, by allocating adjoining areas for more sensitive land use areas. There are opportunities to promote enhanced environmental protection measures, such as riparian planting to stabilise any old fill areas and better sediment discharge controls

17 Warkworth Structure Plan Contaminated Land Topic Report 17 due to modern practices in the design of stormwater management systems, for example, the use of rain gardens and stormwater treatment devices. 5.3 Information gaps Whilst the desktop assessment has identified a number of HAIL activities having been or potentially having been undertaken within the study area, due to the limited nature of this assessment, it is recognised that further HAIL activities may have occurred within the study area that have not been identified to-date. In addition, where HAIL activities have been identified, the contamination status of these areas has not yet been determined. Therefore, further assessments within the study area, particularly land proposed for high sensitivity end use, such as residential, children s play areas, child care centres, schools and rest homes will be required at the resource consent stage. These would include: A comprehensive Preliminary Site Investigation, carried out in accordance the Ministry for the Environment s Contaminated Land Management Guidelines, No.1: Reporting on Contaminated Site in New Zealand, which includes a site walkover, interviews with property owners or person knowledgeable of the site history and a review of Council property files, to confirm the actual or potential location and nature of HAIL activities. Should the PSI identify that HAIL activities are more likely than not to have occurred on a property within the study area, then a detailed site investigation (DSI) carried out in accordance the Ministry for the Environment s Contaminated Land Management Guidelines, No. 1: Reporting on Contaminated Site In New Zealand, and No.5: Site Investigation and Analysis of Soils, including sampling and analysis programme(s) will be required. On the basis of the results of the DSI, the requirement for remedial works and/or resource consents would be assessed. As discussed in Section 3, portions of the study site abut areas currently zoned Business-Light Industry Zone under the AUP (OP). Depending on the contamination status and activities undertaken within these areas, there may be some restrictions on future land use on immediately adjacent land. On this basis, it is recommended that further assessment of this land and its potential impact on the adjacent part of the study area (and other impact assessments) be undertaken, particularly Hudson Road, prior to any urban zoning.

18 18 Warkworth Structure Plan Contaminated Land Topic Report 5.4 Conclusions Although further assessments within the study area are required and some remedial works and resource consents may be required, overall it is considered that issues arising from contamination land are generally unlikely to present significant constraints to land development in the study area. In general, contamination within rural-residential, pastoral farmland properties, if present, is likely to occur as discrete, low volume hotspots (although it is recognised concentrations may be high), whilst contamination associated with the horticultural and recreational land uses identified in this review are likely to be dispersed at lower levels across the properties.

19 Warkworth Structure Plan Contaminated Land Topic Report 19 6 References Auckland Council (2012) The Auckland Plan. Retrieved from Auckland Council, (2016, November 2016) Auckland Unitary Plan (Operative in Part) Plan_Print Auckland Council (2018) Draft Auckland Plan. Retrieved from WEB.htm8 Ministry for the Environment, (2012) Resource Management (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health) Regulations Retrieved from =ts_regulation_contaminants_resel&p=1&sr=1 Ministry for the Environment, (2011) Contaminated Land Management Guidelines No. 1 Reporting on Contaminated Sites In New Zealand Ministry for the Environment, (2016) Contaminated Land Management Guidelines No. 5 Site Investigation and Analysis of Soils New Zealand Government (2014) National Policy Statement for Freshwater Management Wellington: Ministry for the Environment. New Zealand Government (2014) Approved Code of Practice Management and Removal of Asbestos (2016). Worksafe New Zealand

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