{"id":"F2019L01097","name":"Statement of Principles concerning malignant neoplasm of the bladder (Balance of Probabilities) (No. 84 of 2019)","slug":"statement-of-principles-concerning-malignant-neoplasm-of-the-bladder-balance-of-probabilities-no-84-","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":440204,"registerId":"F2019L01097-fast-fetch-1775955921847","compilationNumber":null,"startDate":"2026-04-12","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Statement of Principles concerning malignant neoplasm of the bladder (Balance of Probabilities) (No. 84 of 2019)","content":"---\nmeta-content-style-type: text/css\nmeta-content-type: application/xhtml+xml; charset=utf-8\nmeta-generator: Aspose.Words for .NET 22.10.0\n---\n\n?xml version=\"1.0\" encoding=\"utf-8\" standalone=\"no\"?>\n\n\n\n \n\nStatement of Principles\n\nconcerning\n\nMALIGNANT NEOPLASM OF THE BLADDER (Balance of Probabilities)\n\n(No. 84 of 2019)\n\nThe Repatriation Medical Authority determines the following Statement of Principles under subsection 196B(3) of the Veterans' Entitlements Act 1986.\n\n \n\nDated 23 August 2019\n\n \n\n \n\n \n\n \n\n \n\n| The Common Seal of the Repatriation Medical Authority was affixed to this instrument at the direction of:
|\n| --- |\n| 
Professor Nicholas Saunders AO
Chairperson
|\n\n\n \n\n \n\n\nContents\n\n1 Name\n\n2 Commencement\n\n3 Authority\n\n4 Repeal\n\n5 Application\n\n6 Definitions\n\n7 Kind of injury, disease or death to which this Statement of Principles relates\n\n8 Basis for determining the factors\n\n9 Factors that must exist\n\n10 Relationship to service\n\n11 Factors referring to an injury or disease covered by another Statement of Principles\n\nSchedule 1 - Dictionary\n\n1 Definitions\n\n \n\n\n\n\n1 Name\n\nThis is the Statement of Principles concerning malignant neoplasm of the bladder (Balance of Probabilities) (No. 84 of 2019).\n\n2 Commencement\n\n This instrument commences on 23 September 2019.\n\n3 Authority\n\nThis instrument is made under subsection 196B(3) of the Veterans' Entitlements Act 1986.\n\n4 Repeal\n\nThe Statement of Principles concerning malignant neoplasm of the bladder No. 97 of 2011 (Federal Register of Legislation No. F2011L01730) made under subsections 196B(3) and (8) of the VEA is repealed.\n\n5 Application\n\nThis instrument applies to a claim to which section 120B of the VEA or section 339 of the Military Rehabilitation and Compensation Act 2004 applies.\n\n6 Definitions\n\nThe terms defined in the Schedule 1 - Dictionary have the meaning given when used in this instrument.\n\n7 Kind of injury, disease or death to which this Statement of Principles relates\n\n(1) This Statement of Principles is about malignant neoplasm of the bladder and death malignant neoplasm of the bladder.\n\nMeaning of malignant neoplasm of the bladder\n\n(2) For the purposes of this Statement of Principles, malignant neoplasm of the bladder:\n\n(a) means a primary malignant neoplasm arising from the epithelial cells of the urinary bladder, including the ureteric orifice and the urethral orifice of the bladder; and\n\n(b) includes urothelial carcinoma (also known as transitional cell carcinoma), squamous cell carcinoma, adenocarcinoma, small cell carcinoma and carcinoma in situ; and\n\n(c) excludes soft tissue sarcoma, carcinoid tumour, non-Hodgkin lymphoma and Hodgkin's lymphoma.\n\n(3) While malignant neoplasm of the bladder attracts ICD‑10‑AM code C67 or D09.0, in applying this Statement of Principles the meaning of malignant neoplasm of the bladder is that given in subsection (2).\n\n(4) For subsection (3), a reference to an ICD-10-AM code is a reference to the code assigned to a particular kind of injury or disease in The International Statistical Classification of Diseases and Related Health Problems, Tenth Revision, Australian Modification (ICD-10-AM), Tenth Edition, effective date of 1 July 2017, copyrighted by the Independent Hospital Pricing Authority, ISBN 978-1-76007-296-4.\n\nDeath from malignant neoplasm of the bladder\n\n(5) For the purposes of this Statement of Principles, malignant neoplasm of the bladder, in relation to a person, includes death from a terminal event or condition that was contributed to by the person's malignant neoplasm of the bladder.\n\nNote: terminal event is defined in the Schedule 1 – Dictionary.\n\n8 Basis for determining the factors\n\nOn the sound medical‑scientific evidence available, the Repatriation Medical Authority is of the view that it is more probable than not that malignant neoplasm of the bladder and death from malignant neoplasm of the bladder can be related to relevant service rendered by veterans or members of the Forces under the VEA, or members under the MRCA.\n\nNote: MRCA, relevant service and VEA are defined in the Schedule 1 – Dictionary.\n\n9 Factors that must exist\n\nAt least one of the following factors must exist before it can be said that, on the balance of probabilities, malignant neoplasm of the bladder or death from malignant neoplasm of the bladder is connected with the circumstances of a person's relevant service:\n\n(1) smoking at least five pack-years of cigarettes, or the equivalent thereof in other tobacco products, before the clinical onset of malignant neoplasm of the bladder, where smoking commenced at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\nNote: pack-years of cigarettes, or the equivalent thereof in other tobacco products is defined in the Schedule 1 – Dictionary.\n\n(2) having received a cumulative equivalent dose of at least 0.5 sievert of ionising radiation to the bladder at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\nNote: cumulative equivalent dose is defined in the Schedule 1 - Dictionary. \n\n(3) inhaling, ingesting or having cutaneous contact with high concentrations of polycyclic aromatic hydrocarbons, through work involving the specified industrial or manufacturing process 1:\n\n(a) for a cumulative period of at least 3 500 hours before the clinical onset of malignant neoplasm of the bladder; and\n\n(b) where the first exposure occurred at least ten years before the clinical onset of malignant neoplasm of the bladder.\n\nNote: polycyclic aromatic hydrocarbons and specified industrial or manufacturing process 1 are defined in the Schedule 1 - Dictionary.\n\n(4) inhaling, ingesting or having cutaneous contact with an agent from the specified list of agents containing high concentrations of polycyclic aromatic hydrocarbons:\n\n(a) for a cumulative period of at least 3 500 hours before the clinical onset of malignant neoplasm of the bladder; and\n\n(b) where the first exposure occurred at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\nNote: specified list of agents containing high concentrations of polycyclic aromatic hydrocarbons is defined in the Schedule 1 – Dictionary.\n\n(5) inhaling, ingesting or having cutaneous contact with an aromatic amine from the specified list of aromatic amines:\n\n(a) for a cumulative period of at least 2 000 hours before the clinical onset of malignant neoplasm of the bladder; and\n\n(b) where the first exposure occurred at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\nNote 1: Inhaling, ingesting or having cutaneous contact with an aromatic amine does not include exposure due to cigarette smoke or hair dyes.\n\nNote 2: specified list of aromatic amines is defined in the Schedule 1 – Dictionary.\n\n(6) inhaling, ingesting or having cutaneous contact with a high concentration of an aromatic amine, through work involving the specified industrial or manufacturing process 2:\n\n(a) for a cumulative period of at least 3 500 hours before the clinical onset of malignant neoplasm of the bladder; and\n\n(b) where the first exposure occurred at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\nNote 1: Inhaling, ingesting or having cutaneous contact with a high concentration of an aromatic amine does not include exposure due to cigarette smoke or hair dyes.\n\nNote 2: specified industrial or manufacturing process 2 is defined in the Schedule 1 – Dictionary.\n\n(7) inhaling, ingesting or having cutaneous contact with tetrachloroethylene for a cumulative period of at least 10 000 hours before the clinical onset of malignant neoplasm of the bladder, where the first exposure occurred at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\n(8) being exposed to arsenic as specified before the clinical onset of malignant neoplasm of the bladder, where the first exposure to arsenic occurred at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\nNote: being exposed to arsenic as specified is defined in the Schedule 1 – Dictionary.\n\n(9) working as a painter for a cumulative period of at least 10 000 hours before the clinical onset of malignant neoplasm of the bladder, where that work began at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\nNote: working as a painter is defined in the Schedule 1 – Dictionary.\n\n(10) having renal stone disease or a bladder stone at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\n(11) having chronic renal failure at least one year before the clinical onset of malignant neoplasm of the bladder;\n\nNote: chronic renal failure is defined in the Schedule 1 – Dictionary.\n\n(12) having an infection of the bladder with Schistosoma haematobium at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\n(13) having an indwelling bladder catheter or other foreign body in the bladder for a continuous period (excepting routine catheter changes) of at least ten years, before the clinical onset of malignant neoplasm of the bladder;\n\n(14) having neurogenic bladder at least ten years before the clinical onset of malignant neoplasm of the bladder;\n\nNote: neurogenic bladder is defined in the Schedule 1 – Dictionary.\n\n(15) ingesting aristolochic acid as specified at least four years before the clinical onset of malignant neoplasm of the bladder;\n\nNote: ingesting aristolochic acid as specified is defined in the Schedule 1 – Dictionary.\n\n(16) consuming a total of at least 250 grams of phenacetin at least five years before the clinical onset of malignant neoplasm of the bladder;\n\nNote: phenacetin is defined in the Schedule 1 – Dictionary.\n\n(17) being treated with systemic cyclophosphamide or systemic ifosfamide, at least five years before the clinical onset of malignant neoplasm of the bladder;\n\n(18) being treated with chlornaphazine at least five years before the clinical onset of malignant neoplasm of the bladder;\n\n(19) inability to obtain appropriate clinical management for malignant neoplasm of the bladder.\n\n10 Relationship to service\n\n(1) The existence in a person of any factor referred to in section 9, must be related to the relevant service rendered by the person.\n\n(2) The factor set out in subsection 9(19) applies only to material contribution to, or aggravation of, malignant neoplasm of the bladder where the person's malignant neoplasm of the bladder was suffered or contracted before or during (but did not arise out of) the person's relevant service.\n\n11 Factors referring to an injury or disease covered by another Statement of Principles\n\nIn this Statement of Principles:\n\n(1) if a factor referred to in section 9 applies in relation to a person; and\n\n(2) that factor refers to an injury or disease in respect of which a Statement of Principles has been determined under subsection 196B(3) of the VEA;\n\nthen the factors in that Statement of Principles apply in accordance with the terms of that Statement of Principles as in force from time to time.\n\n \n\n \n\nSchedule 1 - Dictionary \n\nNote: See Section 6\n\n1 Definitions\n\nIn this instrument:\n\n being exposed to arsenic as specified means:\n\n(a) consuming drinking water with an average arsenic concentration of at least 50 micrograms per litre for a cumulative period of at least ten years; or\n\n(b) consuming drinking water resulting in a cumulative total arsenic exposure equivalent to having consumed drinking water containing at least 50 micrograms per litre for at least ten years; or\n\n(c) having clinical evidence of chronic arsenic toxicity.\n\n chronic renal failure means:\n\n(a) having a glomerular filtration rate of less than 15 mL/min/1.73 m2 for a period of at least three months; or\n\n(b) a need for renal replacement therapy (dialysis or transplantation) for treatment of complications of decreased glomerular filtration rate which would otherwise increase the risk of morbidity and mortality; or\n\n(c) undergoing chronic dialysis.\n\n cumulative equivalent dose means the total dose of ionising radiation received by the particular organ or tissue from external exposure, internal exposure or both, apart from normal background radiation exposure in Australia, calculated in accordance with the methodology set out in the Guide to calculation of 'cumulative equivalent dose' for the purpose of applying ionising radiation factors contained in Statements of Principles determined under Part XIA of the Veterans' Entitlements Act 1986 (Cth), Australian Radiation Protection and Nuclear Safety Agency, as in force on 2 August 2017.\n\nNote 1: Examples of circumstances that might lead to exposure to ionising radiation include being present during or subsequent to the testing or use of nuclear weapons, undergoing diagnostic or therapeutic medical procedures involving ionising radiation, and being a member of an aircrew, leading to increased levels of exposure to cosmic radiation.\n\nNote 2: For the purpose of dose reconstruction, dose is calculated as an average over the mass of a specific tissue or organ. If a tissue is exposed to multiple sources of ionising radiation, the various dose estimates for each type of radiation must be combined.\n\n ingesting aristolochic acid as specified means:\n\n(a) consuming a total of at least 60 grams of plant material of the genus Aristolochia as a constituent of herbal medication; or\n\n(b) consuming plant material of the genus Aristolochia or foods containing plant material of the genus Aristolochia, as part of the regular diet for a period of at least 15 months.\n\nmalignant neoplasm of the bladder—see subsection 7(2).\n\n MRCA means the Military Rehabilitation and Compensation Act 2004.\n\n neurogenic bladder means flaccid, spastic or mixed bladder dysfunction caused by neurological damage affecting the bladder.\n\nNote: Examples of a cause of neurogenic bladder include, but are not limited to, spinal cord injury, cerebrovascular accident, Parkinson's disease and diabetic autonomic neuropathy. \n\n pack-years of cigarettes, or the equivalent thereof in other tobacco products means a calculation of consumption where one pack-year of cigarettes equals twenty tailor-made cigarettes per day for a period of one calendar year, or 7 300 cigarettes. One tailor-made cigarette approximates one gram of tobacco or one gram of cigar or pipe tobacco by weight. One pack-year of tailor-made cigarettes equates to 7.3 kilograms of smoking tobacco by weight. Tobacco products mean cigarettes, pipe tobacco or cigars, smoked alone or in any combination.\n\n phenacetin means an aniline derivative that has analgesic and antipyretic properties, that was formerly used as a constituent of several over-the-counter compound analgesic medications, including Bex or Vincent's powder, Empirin Compound and Bromo seltzer.\n\n polycyclic aromatic hydrocarbons means hydrocarbons with three or more condensed aromatic rings in which certain carbon atoms are common to two or three rings. Polycyclic aromatic hydrocarbons occur in crude oil, shale oil and coal tars, and can be formed during the combustion of organic material or during high temperature processing of crude oil, coal, coke or other industrial carbon compounds.\n\n relevant service means:\n\n(a) eligible war service (other than operational service) under the VEA;\n\n(b) defence service (other than hazardous service and British nuclear test defence service) under the VEA; or\n\n(c) peacetime service under the MRCA.\n\nNote: MRCA and VEA are also defined in the Schedule 1 - Dictionary.\n\n soot means a carbonaceous by-product material produced from the incomplete combustion of fossil fuel or other carbon-containing material, including airborne, residual, pyrolysed fuel particles such as coal, cenospheres, charred wood and petroleum coke.\n\n specified industrial or manufacturing process 1 means:\n\n(a) aluminium production; or\n\n(b) coal gasification; or\n\n(c) iron or steel foundries or smelters.\n\n specified industrial or manufacturing process 2 means:\n\n(a) auramine production; or\n\n(b) magenta production; or\n\n(c) rubber manufacturing.\n\n specified list of agents containing high concentrations of polycyclic aromatic hydrocarbons means:\n\n(a) coal tar pitch during paving and roofing; or\n\n(b) soot during the cleaning of chimneys or flues.\n\nNote: soot is also defined in the Schedule 1 – Dictionary.\n\n specified list of aromatic amines means:\n\n(a) 2-naphthylamine;\n\n(b) 4-aminobiphenyl;\n\n(c) benzidine; or\n\n(d) ortho-toluidine.\n\n terminal event means the proximate or ultimate cause of death and includes the following:\n\n(a) pneumonia;\n\n(b) respiratory failure;\n\n(c) cardiac arrest;\n\n(d) circulatory failure; or\n\n(e) cessation of brain function.\n\n VEA means the Veterans' Entitlements Act 1986.\n\n working as a painter:\n\n(a) means applying paint, including solvent- or water-based conventional paint, spray paint, varnish, enamel, lacquer, water-emulsion and solution finish, nonaqueous dispersion or organosol, plastisol, and powder coating, during the course of activities such as building, maintenance and construction, interior and exterior decoration, artistic painting, and wood and metal painting; and\n\n(b) includes mixed activities in which application of paint occurs with other tasks, such as wallpapering and plastering, and activities that are preparatory to painting, such as mixing paints, maintaining painting equipment, and background preparation of surfaces for application of paint.\n\n \n\n \n\n \n\n \n","sortOrder":0}],"analysis":{"kimi_summary":{"content_quality":"ok","complexity_score":6,"scope_assessment":{"changed":false,"description":"This instrument maintains the established scope of Repatriation Medical Authority Statements of Principles. It replaces the 2011 version (No. 97 of 2011) with updated medical evidence and refined definitions, but does not expand beyond the original purpose of establishing causal factors for bladder cancer in veterans. The structure—19 factors covering occupational, environmental, medical, and lifestyle causes—remains consistent with the RMA's standard approach for cancer-related Statements of Principles."},"complexity_factors":["19 distinct causal factors with varying cumulative exposure thresholds (ranging from 2,000 to 10,000 hours, or 4-10 year latency periods)","22 defined terms in Schedule 1, many requiring cross-referenced technical definitions (e.g., 'cumulative equivalent dose' references a separate ARPANSA methodology guide)","Nested definitional structures: terms like 'being exposed to arsenic as specified' contain 3 sub-conditions, and 'chronic renal failure' contains 3 alternative criteria","Multiple exclusion clauses within definitions (e.g., aromatic amine exposure excludes cigarette smoke and hair dyes)","Technical medical and scientific terminology throughout (sieverts, pack-years, glomerular filtration rates, specific chemical compounds)","Conditional logic with dual requirements: most factors require both cumulative exposure AND minimum latency period (typically 10 years)","Cross-referencing mechanism in section 11 allowing incorporation of other Statements of Principles by reference","Specific ICD-10-AM coding references with edition-specific citations (Tenth Edition, 1 July 2017)","Dual statutory framework application (VEA and MRCA) with different service definitions"],"plain_english_summary":"The Repatriation Medical Authority’s Statement of Principles sets medical criteria linking bladder cancer to military service: if a veteran’s cancer aligns with at least one of 19 listed risk factors, it’s presumed service-related. \n\nIt affects veterans, serving/former defence members and their families seeking benefits under veterans’ legislation, using the “balance of probabilities” test to make it easier to establish causation and obtain compensation."},"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"},"flash_summary":{"complexity_score":6,"scope_assessment":{"changed":false,"description":"This instrument remains within the original purpose: it is a Statement of Principles specifying medical/causal criteria for linking malignant neoplasm of the bladder to veterans’ or members’ relevant service. It repeals and replaces an earlier SOP (No. 97 of 2011) but does not expand the Act’s domain or create new classes of benefit. The update refines and clarifies definitional language, formalises quantitative exposure thresholds and adds/updates specified agents and occupational processes (see section 4 and section 9 plus Schedule 1). Those are substantive updates to eligibility criteria and evidentiary thresholds, but they do not change the fundamental scope (assessing whether bladder cancer is related to service)."},"complexity_factors":["Approximately 18 defined terms in Schedule 1 (e.g. cumulative equivalent dose, pack‑years, specified industrial processes, specified lists of agents and aromatic amines, neurogenic bladder, chronic renal failure).","Section 9 contains 19 discrete, alternative factors (any one of which suffices), each with different quantitative thresholds and time lags (2,000 / 3,500 / 10,000 hours; 0.5 sievert; 250 g phenacetin; 4–10 year lags).","Multiple nested conditions and exclusions (e.g. aromatic amine factors exclude cigarette smoke and hair dye exposures).","Cross‑reference to an external technical method for dose calculation (ARPANSA guide) for radiation exposures (Schedule definition of cumulative equivalent dose).","Mix of exposure metrics (hours, sieverts, concentrations in drinking water, cumulative grams of drug, clinical disease thresholds) requiring different types of evidence.","Interplay with other Statements of Principles (section 11) so some factors are governed by separate SOPs, creating cross‑instrument dependency.","Defined occupational and agent lists (specified industrial processes 1 & 2; specified lists of agents and aromatic amines) that require mapping claimant work histories to the lists.","Different legal tests for material contribution or aggravation where the disease began before or during service (section 10(2))."],"plain_english_summary":"**What this instrument does (mechanics first)\n\n- This is a Statement of Principles (SOP) made by the Repatriation Medical Authority under the Veterans' Entitlements Act. It replaces the earlier SOP on bladder cancer and sets the medical / causal rules the Department uses when deciding whether a case of malignant neoplasm of the bladder (or death from it) can be connected to a veteran's or member's relevant service.\n- It applies to claims under the VEA (section 120B) and the MRCA (section 339) (section 5).\n- The SOP defines the illness covered (primary cancers originating in the bladder epithelium; subsection 7(2)), explains that death caused or materially contributed to by the bladder cancer is included (subsection 7(5)), and lists specific exposure, medical and treatment-related \"factors\" which, if present and related to service, are sufficient on the balance of probabilities to establish a connection between the cancer and service (sections 8 and 9).\n- The instrument repeals the earlier SOP and commences on 23 September 2019 (sections 2 and 4).\n\nWhat the Authority says is its rationale\n\n- The Repatriation Medical Authority states that, on the available medical-scientific evidence, it is \"more probable than not\" that malignant neoplasm of the bladder can be related to relevant service (section 8). That view is the stated basis for listing the qualifying factors in section 9.\n\nWho is affected\n\n- Veterans and current or former members of the Australian Defence Force who lodge claims for bladder cancer (or death from it) under the VEA or MRCA.\n- Employers, record-keepers and clinicians who may need to provide occupational histories, exposure evidence, medical records, or dose reconstructions.\n\nHow the SOP operates in practice (key rules and thresholds)\n\n- A claimant only needs at least one of the listed factors in section 9 to be present (and to be linked to the person’s relevant service) for the SOP to say the disease can be related to service on the balance of probabilities. The factors are concrete exposures, medical conditions or treatments, and each carries timing and magnitude requirements.\n- Examples of listed factors and their main thresholds (section 9 and Schedule 1):\n - Smoking: at least five pack‑years, where smoking started at least 10 years before clinical onset (subsection 9(1); pack‑year defined in the Schedule).\n - Ionising radiation: cumulative equivalent dose of at least 0.5 sievert to the bladder, with first exposure at least 10 years before clinical onset (subsection 9(2); cumulative equivalent dose defined in the Schedule and cross‑referenced to an ARPANSA guide).\n - High concentrations of polycyclic aromatic hydrocarbons (PAHs) from certain industrial processes (e.g. aluminium production, coal gasification, iron/steel foundries): at least 3,500 cumulative hours of exposure and first exposure at least 10 years before onset (subsection 9(3) and Schedule).\n - Specified agents with high PAH concentration (coal tar pitch in paving/roofing; soot during chimney/flue cleaning): 3,500 hours and 10‑year lag (subsection 9(4), Schedule).\n - Certain aromatic amines (e.g. 2‑naphthylamine, benzidine): 2,000 cumulative hours and 10‑year lag (subsection 9(5), Schedule) — cigarette smoke and hair dye exposures are explicitly excluded from this aromatic amine factor (note to subsection 9(5)).\n - Other occupational exposures: 3,500 hours in certain aromatic‑amine‑intensive industries; 10,000 hours as a painter; 10,000 hours of tetrachloroethylene exposure (subsections 9(6)–(9)).\n - Medical and disease factors: renal or bladder stones (10‑year lag), chronic renal failure (at least 1 year before onset), indwelling bladder catheter for at least 10 years, neurogenic bladder (10‑year lag), prior infection with Schistosoma haematobium (10‑year lag) (subsections 9(10)–(14)).\n - Chemical and drug exposures: ingestion of aristolochic acid (specified amounts; 4‑year lag), cumulative phenacetin use of at least 250 g (5‑year lag), systemic cyclophosphamide or ifosfamide treatment (5‑year lag), chlornaphazine treatment (5‑year lag) (subsections 9(15)–(18) and Schedule definitions).\n - A final factor allows \"inability to obtain appropriate clinical management\" to be considered but only where the cancer began before or during service and the material contribution or aggravation is relevant (subsection 9(19) and section 10(2)).\n- Section 10 requires that any factor relied upon be related to the person’s relevant service (see the Schedule for the meaning of \"relevant service\").\n- Section 11 says that if a listed factor overlaps with another SOP (i.e. the factor is itself an injury/disease covered by another SOP), the terms of that other SOP govern how that factor is applied.\n\nPractical consequences, incentives and implementation considerations\n\n- Who pays / who benefits: If a claimant meets the SOP (i.e. has a listed factor that is related to service), the SOP operates as a medical determination the Department can rely on when accepting a claim under the VEA/MRCA. That can lower the evidentiary burden on claimants compared with cases where no SOP applies and complex expert causation evidence would otherwise be required. The fiscal cost is borne by the Commonwealth through the veterans’ compensation and treatment schemes; the benefit is concentrated among claimants meeting the listed factors (see section 9 and the Schedule).\n- Who decides: The SOP provides a legal medical template used by decision‑makers (Department/Tribunal) to decide causation; in practice those decision‑makers evaluate documentary and medical evidence to show the required exposure/timing thresholds are met and that exposures are linked to relevant service (sections 5, 9 and 10).\n- Evidence and compliance burden: Claimants must produce evidence of occupational history, exposure duration/intensity, medical records, or radiation dose reconstructions (the SOP requires a specific method for calculating cumulative equivalent dose; Schedule). Some thresholds are quantitative (hours, sieverts, concentrations, gram totals), creating a technical evidentiary requirement that may be difficult where records are incomplete.\n- Implementation risk and administrative discretion: Decision‑makers will often need technical assessments (dose reconstructions, occupational exposure estimates, or clinical proof of chronic conditions). The ARPANSA guide is incorporated by reference for radiation dose calculation (Schedule definition of \"cumulative equivalent dose\"), which delegates technical method choice to an external standard in force on a particular date. That introduces a dependence on up‑to‑date technical methodology.\n- Who is concentratedly affected: The SOP specifically lists industries and agents (e.g. aluminium, coal gasification, iron/steel foundries, auramine/magenta production, rubber manufacture, boiler/chimney cleaning, paving/roofing, painters, arsenic in drinking water), so claimants who worked in these occupations gain a clearer pathway to accepted claims (section 9 and Schedule definitions). This concentrates benefits in identifiable occupational groups.\n- Substitution and strategic effects: Because only one listed factor is required, claimants and advisors may rely on the most readily provable factor (for example a smoking history or a recorded medical treatment) rather than attempting to prove complex occupational exposure levels. Conversely, where claimants cannot meet the quantitative thresholds, they may need to pursue more expensive expert evidence.\n- Trade‑offs and opportunity costs: The SOP reduces the need for bespoke causation proof when its specified criteria are met, speeding decisions for claimants with covered exposures but also creating fixed thresholds that exclude borderline or undocumented exposures. The Commonwealth bears the cost of any additional acceptances that result where thresholds are met.\n\nDetails worth noting (precision in the text)\n\n- Time lags: Many factors require that first exposure occurred at least 10 years before clinical onset; some require 5 years or 4 years or 1 year depending on the factor (see section 9 and Schedule definitions).\n- Exclusions: The aromatic‑amine factors explicitly exclude exposure from cigarette smoke or hair dyes (note to subsection 9(5) and 9(6)).\n- Diagnostic coding: Although the SOP notes relevant ICD‑10‑AM codes (subsection 7(3)), it specifies that the definition in subsection 7(2) controls for the instrument’s purposes.\n- Death: \"Death from malignant neoplasm of the bladder\" includes death from terminal events (terminal events are defined in the Schedule) that were contributed to by the bladder cancer (subsection 7(5) and Schedule).\n\nBottom line\n\n- This SOP sets out a list of defined exposures, medical conditions and treatments, with specific quantitative and timing thresholds, that if present and linked to a veteran’s or member’s relevant service allow decision‑makers to accept that bladder cancer (or death from it) is connected to service on the balance of probabilities. It replaces the prior SOP and clarifies definitions and measurable criteria that shape how claims for bladder cancer are assessed (sections 4, 7–11 and Schedule 1)."}},"importantCases":[],"_links":{"self":"/api/acts/statement-of-principles-concerning-malignant-neoplasm-of-the-bladder-balance-of-probabilities-no-84-","history":"/api/acts/statement-of-principles-concerning-malignant-neoplasm-of-the-bladder-balance-of-probabilities-no-84-/history","analysis":"/api/acts/statement-of-principles-concerning-malignant-neoplasm-of-the-bladder-balance-of-probabilities-no-84-/analysis","conflicts":"/api/acts/statement-of-principles-concerning-malignant-neoplasm-of-the-bladder-balance-of-probabilities-no-84-/conflicts","importantCases":"/api/acts/statement-of-principles-concerning-malignant-neoplasm-of-the-bladder-balance-of-probabilities-no-84-/important-cases","documents":"/api/acts/statement-of-principles-concerning-malignant-neoplasm-of-the-bladder-balance-of-probabilities-no-84-/documents"}}