PMCSA Meth Report Debacle – Key Points Summary

1. If PMCSA Report numbers are correct from a health risk perspective, this is a good thing.
2. The PMCSA report has manifest shortcomings, in science, fact, risk assessment and riskmanagement recommendations and as such cannot be relied upon:
a. People are getting sick in houses where low levels of meth are present – these facts are
being ignored, because they are not documented/presented in the specific way the
Office of the PMCSA required in order to be considered
b. Many jurisdictions have guidelines and regulations that apply to meth manufacture ANDuse – the PMCSA has erroneously advised the public of NZ that NZ is unique
c. Research bias – significant real-world science was first considered the day before the
first Executive Summary was produced, while Fairgo articles were being hunted down
months earlier at the start of the research process
d. Leaps of logic – no other jurisdiction in the world is proposing an acceptable level of
meth residues at 15µg/100cm2
e. High risk approach to Environmental toxicology – the Scientist who reported to the
Ministry of Health, work that underpins the standard, does not know how the PMCSA
arrived at its figures and believes that if a recommendation is made to adopt a change
of this magnitude specific research should be done – the PMCSA Report makes no
specific research recommendations
f. Assessment of the risk by the PMCSA skews the figures to diminish the extent of theproblem – less than 1% of swabs in ESR were > 30µg, but these came from 4.5% of
houses and less than 3% of swabs were >15µg coming from 14% of houses. A five-fold
understating of risk.
Full ESR Report
g. If the recommendations for risk management made in the PMCSA are followed by
Landlords, their risks will increase – they will not be able to determine responsibility and
they will only know they are in breach of a requirement enshrined in law, when they get
a positive result – they will be paying back rent and compensating tenants
h. The PMCSA Report relies for its efficacy on the expert opinion of Dr. Nick Kim. Dr. Kim’sviews were examined by 3 separate scientists as part of the Standards process. They
were found to be wanting from a scientific perspective
3. The Standards process that produced NZS8510 was denigrated by Phil Twyford who demanded
it be investigated. This independent investigation has been completed and NZS8510 has
received independent sign off

4. The PMCSA Report and the processes that led to its development have not been subject to
independent review in the same way the process which developed the Standard has, yet, the
Standard has been discounted, while the PMCSA Report has been embraced.
a. The errors in science, fact, risk assessment and recommendations around risk
management are being adopted into policy –
HNZ change on day of PMCSA Report releaseREA in early June
Tenancy Tribunal indicating changes in policy based on PMCSA Report
b. Key actors in the 2 to 3 year strategy to increase acceptable meth residue levels inproperty, were provided with early release reports from the Minister for Housing, withfollow up communications suggested. There is no record of any follow up
communications – inconceivable given the significance of the report