NZ Standards for Meth - public consultation and NZPIF policy
The draft NZ Standard for meth is now open for public consultation. Submissions close on 20 February 2017. The NZPIF will make a submission, however any individual can as well. You can make a submission here: under the section DZ 8510 (Committee P8510), Testing and decontamination of methamphetamine-contaminated properties is a copy of the draft.
A key aspect of the draft is that it offers two possible options for meth levels that affected properties should be cleaned to. One is from the Ministry of Health report released by them last month. The other is from the Meth Standards Committee. Further information on this is supplied below.
The two key points for our industry to consider are the two recommended levels and how landlords can self test their properties.
There are also some other points that the NZPIF will be commenting on in its submission.
The following is some comment on the draft standard and the NZPIF's position.
1. Recommended levels of Meth
1.1 MOH recommendations
The MOH contracted the Governments Environmental Science and Research Institute (ESR) to conduct a toxicology review on meth levels. The toxicologist authors determined that while the risk assessment of meth itself warranted increasing the level to 2, manufacturing and smoking meth in a property produced different levels of health risk. This is because extra chemicals can be used when manufacturing meth that are not present when it is used.
The toxicologists also determined that it was difficult to assess and remove meth in soft furnishings and carpets and, with practicalities and costs in mind, determined that there should be different levels for properties with and without carpet.
So the recommendation was that the 0.5 micrograms per 100cm2 level should remain where a property has been used for manufacture, should be increased to 1.5 for properties with carpet and 2 for properties without carpet.
The committee agreed to endorse the MOH recommendations in the interim, however they saw some practical problems with them.
The first is that as there are different manufacturing processes, it is difficult (some scientists say impossible) to absolutely confirm if manufacturing has occurred.
This raised issues with local authorities, who are the organisations that actually develop policy for their areas on how meth affected properties should be handled. This means that rather than a standard nationwide policy, individual local authorities could implement whatever rules they want. Some indicated that if you couldn't positively confirm that only smoking had occurred, then they would take the safest measure and treat the property as having been used for manufacture.
There is concern that applying the MOH recommendations would cause inconsistencies, confusion and application difficulties. Because of this, the Standards committee developed an alternative, based on the MOH study and extra information from New Zealand scientists.
1.2 Standards Committee meth level recommendations
Because of the practical difficulties in the MOH recommendations, the committee developed a different recommendation for meth levels.
The committees assessment was that states in the USA that were mentioned in the MOH report used levels of 1.5 micrograms, showing that this level of meth, whether achieved from either use or manufacture, was not a health risk in a property.
They also thought that there was not enough available information on carpet, plus testing carpet meant cutting out samples to be sent to a lab, therefore ruining it anyway.
Therefore the committee has recommended that one level of 1.5 be used regardless of the meth source or carpet. If the level was above 1.5, then the standard meant that carpet had to be removed.
This creates a lot more certainty.
In addition, the MOH report didn't cover limited exposure areas (roof spaces for instance) so the committee, led by scientists, determined a level of 3.8 micrograms per 100cm2.
1.2 NZPIF assessment
Uncertainty on how to determine meth manufacture and individual local authorities having the authority to determine how they will apply recommendations, means that the MOH recommendation could see the level effectively remain at 0.5.
However accepting the Standards Committee's recommendation means properties with or without carpet miss out on the higher 2 microgram level.
The NZPIF believe that the NZ Standards Committee recommendation is the better of the two proposals. However the NZPIF believe that if the standard will involve removing carpet, then the MOH recommendation of 2 micrograms should be applied, not the 1.5 microgram level recomended by the Committee.
The rationale for this is that the MOH finding was that meth at a level of 2 micrograms where there was no carpet was not a health risk. If the standard states that the carpet is going to be removed, then the 2 microgram level should be applied as it is not a health risk.
2. Use of self test kits
The NZPIF believes that it is critical for NZ landlords to be able to conduct a meth test on their properties. The easier it is for rental properties to be tested, then problems will be picked up earlier and the cost of remediation will be lower. There are some issues with self testing however.
Self test kits only show whether meth is present at a determined level. If the test is positive, then further sampling must be undertaken to determine the actual level of meth to ascertain if it is at or below the guideline levels or whether cleaning needs to occur.
There is concern that cheap kits available on-line are not accurate enough. The standard allows landlords to do their own testing but with some conditions. The self test kit must be verified as accurate and the Tester (i.e. landlord) must be trained.
It will be up to self test kit suppliers to seek confirmation that their product meets the standards. It will then be confirmed as allowable for use.
The standard details how the Tester must check for meth and also how they record what they did and what they found. The training is to confirm that they know what they are doing.
There is currently no NZQA qualification for course providers in meth testing. The standard says that any course will be acceptable until the NZQA system is established. At that point it will be up to course providers to ensure they are NZQA qualified.
The NZPIF believe that these are reasonable conditions for landlords.
3. Other Matters
3.1 Local Authorities
The NZPIF does not believe that the meth standards need to be approved by individual local authorities as this will lead to different regulations in different parts of the country.
The NZPIF will recommend that the Meth Standard should be approved at a national level.
The NZPIF will also be recommending that a national policy should be developed so that the LIM record of Meth being found in a property is removed once the property has been cleaned and confirmed as safe to be habited again. Property owners should not have an ongoing stigma attached to their property when it has been remedied and found not to be a health hazard.
3.2 Tenant authority to undertake a meth test
Section 3.2.2 (g) of the standard says that a landlord must confirm occupant (tenant) consent has been received before testing for Meth.
If a tenant is smoking meth in a property then they are not going to give their permission. The NZPIF will submit that this clause be removed.