Statement of Principles concerning albinism (Reasonable Hypothesis) (No. 31 of 2023)

The instrument organises a small set of tightly defined concepts that determine its operation. Those concepts are definitional (what albinism is for these purposes), evidential (what must exist to raise a reasonable hypothesis), temporal (when the condition arose in relation to service), and relational (how the factor must be linked to relevant service). All of these are given statutory text and dictionary entries.

Definition of the condition: The SoP fixes its operative meaning of “albinism” as a group of genetic disorders involving reduced pigmentation, optic‑nerve misrouting and other ocular abnormalities, and it explicitly includes oculocutaneous and ocular albinism (s 7(2)). Even though the ICD‑10‑AM assigns code E70.3 to albinism, the instrument clarifies that the statutory meaning for claims is the textual definition in s 7(2) (s 7(3)). The instrument also includes death caused by a terminal event or condition contributed to by the person’s albinism in the phrase “death from albinism” (s 7(5)), and it provides examples of terminal events in the Schedule (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function).

Evidential threshold: The instrument repeatedly frames itself around the statutory standard “reasonable hypothesis”. Section 9 directs that before it can be said that a reasonable hypothesis has been raised connecting albinism or death from albinism with relevant service, at least one factor from the instrument must exist. For this SoP the single listed factor is “inability to obtain appropriate clinical management for albinism” (s 9(1)). That is the minimal factual trigger that, if established and related to service as required by s 10, permits a link to be reasonably hypothesised.

Temporal and relational limits: Section 10 requires the factor(s) to be “related to the relevant service rendered by the person” (s 10(1)). Section 10(2) imposes an additional restriction on the sole s 9(1) factor: it applies only where the person’s albinism was suffered or contracted before or during the person’s relevant service, and did not arise out of the relevant service, and the inability to obtain appropriate clinical management materially contributed to or aggravated the albinism (s 10(2)). Thus the SoP distinguishes between conditions that pre‑existed or were present during service and conditions that arose out of service.

Interaction with other SoPs: Section 11 instructs decision‑makers that if a factor in this instrument refers to an injury or disease that is the subject of another SoP made under s 196B(2) of the VEA, the factors in that other SoP apply according to their terms. This makes the coverage of any particular factual scenario potentially subject to multiple SoPs and requires following the terms and order of application set out in the other instruments (s 11).

Definitions and scope: The Schedule defines “relevant service” by enumerating the VEA service types (operational, peacekeeping, hazardous, British nuclear test defence) and MRCA types (warlike, non‑warlike) that activate the SoP (Schedule, definitions). The Schedule also sets out “terminal event” examples (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function) that are relevant in death cases (Schedule).

Authority and commencement: The SoP is made under statutory authority (s 3), commenced 23 May 2023 (s 2), and repeals the prior albinism SoP (s 4). The RMA states as a factual premise that there is sound medical‑scientific evidence for linking albinism and death from albinism to relevant service (s 8), which is the technical justification for the RMA setting out these factors.

These concepts determine how claimants and decision‑makers frame evidence: what clinical condition is in issue, what factual gateway is required, when the condition must have existed relative to service, and how overlaps with other injury/disease Statements must be handled.

The instrument identifies three groups of affected persons by reference to the statutory application points and definitions contained in the Schedule. First, it affects persons who bring claims that fall under section 120A of the VEA or section 338 of the MRCA, because the instrument “applies to a claim to which section 120A of the VEA or section 338 of the MRCA applies” (s 5). The Schedule defines “relevant service” broadly to include operational, peacekeeping, hazardous, British nuclear test defence service under the VEA and warlike and non‑warlike service under the MRCA (Schedule, definitions). Thus the population potentially affected includes veterans and members of the Forces who have rendered those kinds of service such that claims under those parts of the VEA or MRCA are engaged.

Second, the instrument affects decision‑makers who apply the VEA and MRCA claims processes, because it provides the RMA’s Statement of Principles that must be taken into account in assessing whether a “reasonable hypothesis” connects albinism or death from albinism to relevant service (ss 3, 9). The SoP therefore governs the statutory facts that triage claims into the next stages of entitlement assessment. Decision‑makers must apply the definition of albinism in s 7(2) rather than relying solely on ICD coding (s 7(3)-(4)), must require at least one factor from s 9, and must ensure the factor is linked to relevant service per s 10.

Third, medical practitioners, hospitals and other health service providers are indirectly affected where their capacity, records and advice are relevant to establishing or rebutting the listed factor. The single factor in s 9(1) , inability to obtain appropriate clinical management for albinism , will necessarily involve evidence about the availability and content of clinical management, including what treatments, referrals, specialist appointments, or services were accessed or not, and why. The SoP imposes a factual focus on “clinical management” as the operative trigger for a reasonable hypothesis.

Additionally, families and estates are affected in death claims because the instrument includes “death from albinism” as a compensable outcome where the person’s death was contributed to by albinism via a terminal event or condition (s 7(5)); the Schedule lists terminal event examples. Executors and next‑of‑kin pursuing death benefits under the VEA/MRCA framework must therefore marshal evidence showing contribution by albinism to the terminal event.

Finally, the instrument affects lawyers, advocates and advisers who prepare claims, because it narrows the factual pathways available to raise a reasonable hypothesis: a claimant must show at least one of the instrument’s factors and its relation to relevant service (s 9, s 10). The repeal of the prior SoP (s 4) means advisers must use this instrument for claims after commencement on 23 May 2023 (s 2), not the 2015 instrument.

The instrument does not set out benefit rates, procedural timetables, or payment authorities. It confines itself to the medical‑scientific threshold and the factors that decision‑makers must consider to determine whether a reasonable hypothesis exists connecting albinism or death from albinism to relevant service (ss 3, 5, 9). Who ultimately pays or the mechanics of payment are matters governed by the VEA and MRCA and not detailed in this instrument.

This SoP itself creates duties for decision‑makers and establishes evidential rights (or thresholds) for claimants. It is not a benefits statute but an evidentiary instrument that determines which factual circumstances satisfy the “reasonable hypothesis” gateway in claims under specified provisions of the VEA and MRCA.

Duties on decision‑makers and the RMA: The instrument is made under the RMA’s statutory power (s 3) and sets the factors decision‑makers must use as the minimal requirements to say a reasonable hypothesis has been raised (s 9). Decision‑makers processing claims under s 120A of the VEA or s 338 of the MRCA must apply this SoP to test whether the minimal factors exist and are related to relevant service (s 5, s 9, s 10). The instrument therefore imposes a duty to treat the RMA’s specified factor(s) as the operative items to be assessed when raising a reasonable hypothesis for albinism or death from albinism.

Evidential threshold for claimants: The right conferred on a claimant is essentially procedural and evidential , if the claimant adduces evidence that a listed factor exists and that it is related to relevant service in the manner required by s 10, then a “reasonable hypothesis” can be said to have been raised (s 9). For this SoP the single factor is inability to obtain appropriate clinical management for albinism (s 9(1)). Thus claimants who can demonstrate that inability and its relation to service satisfy the minimal gateway necessary to progress a claim.

Temporal and causal constraints: The SoP places temporal limits on when that factor will operate. Section 10(2) restricts the s 9(1) factor to persons whose albinism was suffered or contracted before or during relevant service and explicitly excludes albinism that “arose out of” the relevant service. Decision‑makers therefore must determine when the condition was suffered or contracted and whether it arose out of service. The SoP also requires that the inability to obtain appropriate clinical management materially contributed to, or aggravated, the albinism (s 10(2)). The duty of the decision‑maker is to test for these elements when considering the factor.

Interaction with other SoPs: Section 11 imposes another duty on decision‑makers to apply other SoPs where there is overlap. If a factor in this SoP refers to an injury or disease covered by another SoP under s 196B(2) of the VEA, then the factors in that other SoP apply in accordance with its terms (s 11). This creates a duty to cross‑reference and give effect to other RMA determinations where applicable.

Interpretation of clinical definitions: Decision‑makers must use the textual definition of albinism in s 7(2) as the operative meaning for claims, not purely the ICD code. Although the ICD‑10‑AM code E70.3 is acknowledged (s 7(3)-(4)), s 7(3) makes clear the statutory meaning is the definition in s 7(2).

Rights of representation and evidence: While the instrument does not itself prescribe claim procedures, the factors and definitions it contains determine the rights claimants have to present medical evidence and to have that evidence judged against the RMA’s factors. For example, the inclusion of death from albinism where a terminal event was contributed to by albinism (s 7(5)) gives family members the scope to present evidence that a listed terminal event (Schedule) was materially contributed to by albinism.

What the SoP does not do: It does not set out benefit entitlements, payment mechanisms, or appeals processes. It does not change the statutory definitions of MRCA or VEA beyond their inclusion in the Schedule. It does not itself determine claims; instead it provides the medical‑scientific factors used by decision‑makers under the VEA and MRCA framework (ss 3, 5, 9). The legal duties and rights therefore are procedural and evidential: compliance with the SoP is a precondition for establishing a reasonable hypothesis in the claim processes to which it applies.

The instrument is a Statement of Principles and does not itself create criminal offences, penalties, or administrative sanctions. It is an evidentiary instrument made under s 196B(2) of the VEA (s 3) and is intended to guide entitlement determinations for claims under the VEA and MRCA (s 5). As such, its enforcement mechanism is administrative application by claims decision‑makers rather than penal sanction.

How the instrument is enforced in practice is therefore indirect: the SoP prescribes the minimum factor(s) required for a reasonable hypothesis to be raised (s 9), and claim determinations under the VEA/MRCA will rely on whether those factors are established. If a claimant cannot establish the required factor(s) and their relation to relevant service, the claimant will be unable to establish the “reasonable hypothesis” gateway. The material consequence is refusal of the claim on the merits, using the SoP as the evidentiary benchmark. The SoP does not itself set a remedy for non‑compliance; remedies, review rights, or internal administrative processes arise from the VEA and MRCA and from the broader administrative law framework, none of which the instrument itself prescribes.

There are no express inspection, audit, or reporting obligations imposed on medical practitioners, employers, or service providers in the SoP. The only operational enforcement outcome in the SoP is that its listed factor(s) will be treated as the necessary item(s) to consider when establishing a reasonable hypothesis; claim processing bodies and decision‑makers must apply the SoP in that sense (s 9). If decision‑makers misapply the SoP, the remedy would depend on the appeal and review mechanisms available under the VEA and MRCA and the general law, but the instrument contains no further penalty or enforcement provisions.

The instrument does not create any new obligations enforceable against third parties (for example health services or military authorities) to provide or fund clinical management. The stated factor , inability to obtain appropriate clinical management for albinism (s 9(1)) , is a factual element a claimant must establish. Whether a third party’s conduct gives rise to liability or a duty to provide services, or whether that conduct creates a compensable breach, is governed by relevant laws and policies outside this instrument and is not specified here.

In short, the SoP’s enforcement is administrative and evidentiary: it shapes claim outcomes by defining what must be proved to establish a reasonable hypothesis linking albinism or death from albinism with relevant service (ss 9-10). The instrument does not itself carry penalties or criminal sanctions.

This instrument is made under statutory authority in the VEA and is expressly designed to be applied within the claims framework of the VEA and MRCA. Section 3 records the enabling power (s 196B(2) of the VEA). Section 5 specifies application: the SoP applies to claims to which s 120A of the VEA or s 338 of the MRCA applies. The Schedule defines “relevant service” by reference to categories in the VEA and MRCA (Schedule, definitions), hence anchoring the SoP within that statutory architecture.

Relationship to other Statements of Principles: Section 11 provides a direct procedural rule for overlap with other SoPs made under s 196B(2) of the VEA. If a factor in this SoP refers to an injury or disease covered by another SoP, then the factors in that other SoP apply according to their terms (s 11). This requires decision‑makers to cross‑reference other RMA instruments where there is an overlap of medical conditions or where the factual element in s 9 is expressed elsewhere. The instrument thus does not operate in isolation; its factors may trigger, or be subsumed by, factors in other RMA SoPs.

Operational boundaries with VEA and MRCA claims: The instrument applies only to claims where the VEA and MRCA provisions specified are engaged (s 5). The SoP therefore operates as a subsidiary evidentiary rule within the VEA/MRCA statutory system. It does not itself amend the VEA or MRCA or re‑define their statutory entitlements; rather, it supplies the RMA’s medical‑scientific view that decision‑makers are to apply when testing whether a reasonable hypothesis connects a condition to relevant service (s 8).

Clinical coding and classification: Although the instrument acknowledges that albinism attracts ICD‑10‑AM code E70.3, it instructs that the statutory meaning for the SoP is the textual definition in s 7(2) rather than reliance on coding alone (s 7(3)-(4)). This interacts with clinical records and health data where ICD codes are used; decision‑makers cannot rely solely on an ICD code but must assess the condition against the definition provided by the SoP.

Temporal scope and causation: Section 10(2) draws a boundary between conditions that “arose out of” relevant service and those suffered or contracted before or during service. That distinction intersects with legal questions about causation in claims under the VEA and MRCA. The SoP’s language limits the applicability of the s 9(1) factor to pre‑existing or contemporaneous conditions that were not caused by service, which may affect how decision‑makers treat claims that allege service‑caused onset versus aggravation or material contribution.

Procedural and review frameworks: The SoP does not set out appeal, review or enforcement procedures; those are governed by the VEA, MRCA and general administrative law. The instrument therefore functions as a mandatory input into the decision‑making process required by those statutes. Any challenges to a decision that applied this SoP incorrectly will be determined against the statutory appeal and review routes in the VEA and MRCA framework, not by this SoP itself.

Repeal of prior instrument: Section 4 repeals the 2015 SoP on albinism. Therefore, the 2023 SoP replaces and interacts with the legal history of RMA determinations by supplanting prior RMA factors for albinism (s 4). Decision‑makers must therefore apply the 2023 text for claims from the date of commencement (s 2), rather than relying on the 2015 instrument.

In summary, the SoP is an administrative, medical‑scientific instrument that operates inside the VEA/MRCA statutory system, interacts with other RMA Statements of Principles under s 196B(2), directs how clinical definitions should be read in claims, and places temporal limits on the applicability of its factors. It does not itself create entitlements, payments or penalties; those remain functions of the parent statutes.

The instrument is short and its amendment history as recorded in the text is minimal and explicit. Key dates and changes in the instrument itself are:

• Made and dated: The instrument is signed and dated 24 April 2023 (front matter). It is made under the authority of subsection 196B(2) of the VEA (s 3).

• Commencement: The instrument commences on 23 May 2023 (s 2). That is the operative date on which the RMA’s Statement of Principles became the applicable statement for new and relevant claims under the specified VEA and MRCA provisions (s 5).

• Repeal of prior SoP: Section 4 expressly repeals the Statement of Principles concerning albinism No. 19 of 2015 (Federal Register of Legislation No. F2014L01823), which was originally made under s 196B(2) of the VEA. The repeal language is categorical: the 2015 instrument “is repealed” (s 4). The consequence is that, from commencement, the 2015 SoP no longer applies for the purposes of raising a reasonable hypothesis in claims falling within the scope of this instrument.

There are no notes in the instrument describing incremental amendments, transitional provisions, or grandfathering of claims decided under the 2015 instrument. The instrument contains no provision that preserves outcomes reached under the prior SoP. The absence of transitional text in the instrument means that, procedurally, decision‑makers must apply the 2023 SoP to claims to which it applies from its commencement date (s 2), and the 2015 instrument is no longer in force (s 4).

The instrument’s Schedule notes definitions, including cross‑references to the VEA and MRCA. There is no separate amendment log within the instrument recording prior variations or consultation history. The front matter records that the Common Seal of the RMA was affixed at the direction of the Chairperson (Professor Terence Campbell AM), and the document is identified as No. 31 of 2023 in the RMA’s series of Statements of Principles.

Because the instrument is made under s 196B(2) of the VEA, any future amendments would be made by the RMA under the same statutory power; no procedure for amendment is contained within this text. Users should therefore monitor RMA publications or the Federal Register of Legislation for any subsequent repeal or replacement instruments. The only historical change recorded in the instrument itself is the replacement of the 2015 SoP by this 2023 instrument (s 4), effective from the stated commencement date (s 2).

The instrument contains no case law, judicial references or express litigation history. It does not cite any decisions nor record any judicial challenges to previous RMA determinations. The text is a declarative administrative instrument setting medical‑scientific factors for application in claims; it is not itself a judgment or a litigation document.

Despite the absence of recorded litigation, the instrument establishes a framework that could be a focus for legal challenges or administrative review in practice. Potential legal contest points, grounded in the instrument’s own text, include:

• Interpretation of the definitional text of “albinism”: s 7(2) supplies the operative statutory definition for the SoP. Parties could contest whether particular clinical presentations fall within that definition, particularly where the clinical record relies on ICD coding (E70.3) or where mixed or atypical presentations are at issue. The instrument’s note that ICD coding is acknowledged but not determinative (s 7(3)-(4)) is likely to be central to any dispute where coding and textual description diverge.

• The “reasonable hypothesis” threshold and the sufficiency of evidence: Section 9 requires that at least one factor exist to raise a reasonable hypothesis linking the condition to relevant service. Legal challenges may focus on whether administrative decision‑makers applied the correct legal standard in evaluating evidence against s 9(1) and whether they properly assessed the existence and significance of “inability to obtain appropriate clinical management for albinism.”

• Application of s 10(2) temporal/cause limits: Disputes may arise about whether a person’s albinism was “suffered or contracted before or during” service or whether it “arose out of” service, because s 10(2) applies only where it was suffered or contracted before or during service and did not arise out of service. Factual disagreements over onset timing or causal origin could therefore be litigated or reviewed administratively.

• Overlap with other Statements of Principles: Section 11 requires application of other SoPs where a factor refers to an injury or disease that is the subject of another SoP. Parties might dispute which SoP’s factors take precedence, how to reconcile overlapping instruments, or whether the RMA correctly applied s 11 where a referenced factor overlaps with another SoP.

• Death cases and causation: The inclusion of “death from albinism” where a terminal event was contributed to by albinism (s 7(5) and Schedule) could provoke disputes about proximate causation and the significance of contribution. The Schedule’s list of terminal events provides examples but not an exhaustive list, which may be a point of interpretive contention.

The instrument itself does not reference how errors in applying the SoP are to be remedied. Remedies would arise under the procedural and review mechanisms contained in the VEA, the MRCA, and general administrative law. The instrument therefore leaves unresolved the procedural pathways for judicial review, merits review or correction; such routes are part of the institutional architecture in which the SoP operates rather than the instrument itself.

In short, the instrument contains no recorded litigation history. However, its definitional choices, evidential thresholds and cross‑instrument interaction points are the natural loci for administrative or judicial disputes if claimants or decision‑makers contest their application in particular cases.

This instrument is compact but contains several features that are easy to overlook and that materially affect claim strategy and decision‑making. These items are grounded in the text and should be treated as technical operational “gotchas” that advisers and claimants must manage.

Narrow list of factors: The SoP specifies only a single factor that must exist to raise a reasonable hypothesis: “inability to obtain appropriate clinical management for albinism” (s 9(1)). Because at least one of the listed factors must exist to raise a reasonable hypothesis (s 9), the presence or absence of evidence on this single narrow factor is decisive as a threshold matter. Claimants relying on other potential links between service and albinism that are not expressed as factors in this instrument will not have those routes available through this SoP.

Temporal limitation excluding conditions that “arose out of” service for s 9(1): Section 10(2) makes crystal clear that the s 9(1) factor applies only where the person’s albinism was suffered or contracted before or during relevant service, and did not arise out of the person’s relevant service. That means claims alleging that albinism itself arose out of service will not be able to rely on the s 9(1) inability to obtain clinical management factor. Understanding when a condition “arose out of” service, as distinct from being suffered or contracted before/during service, is therefore crucial. The SoP does not define “arose out of” further; this is an interpretive gap for decision‑makers and advisers.

Material contribution or aggravation requirement: Section 10(2) further restricts s 9(1) to circumstances where the inability to obtain appropriate clinical management materially contributed to or aggravated the albinism. Claimants must therefore identify not merely a lack of care, but show material contribution or aggravation. The SoP leaves the assessment of “material” to decision‑makers; there is no quantification or guidance on thresholds in the instrument itself.

Reliance on clinical management evidence: Because the operative factor is inability to obtain appropriate clinical management, evidence about availability, timeliness and appropriateness of clinical care is central. Clinical records, appointment histories, referrals, specialist availability and contextual reasons for lack of access will be the facts assessed. The SoP does not set standards for what constitutes “appropriate clinical management” or how lack of access is proved; that discretion falls to decision‑makers.

ICD code not determinative: The instrument notes that albinism attracts ICD‑10‑AM code E70.3 but makes the statutory meaning depend on s 7(2) rather than the code alone (s 7(3)-(4)). A mere record of an ICD code in a file will not, by itself, satisfy the condition; the specific clinical features in s 7(2) must be shown.

Death cases require demonstration of contribution to a terminal event: For death claims, s 7(5) includes deaths from a terminal event or condition that were contributed to by the person’s albinism. The Schedule lists examples of terminal events (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function). Advisers must therefore assemble evidence that albinism contributed to one of those terminal events (or another terminal event covered by the SoP’s definition) rather than relying on a bare cause‑of‑death certificate that does not show contribution.

Overlap with other SoPs: Section 11 means that if the operative factor refers to another injury or disease already the subject of a separate SoP, the factors in that other SoP apply. That can complicate claim preparation because it requires cross‑checking the RMA’s other instruments to find additional or alternative factors and may produce competing or cumulative evidentiary pathways. The SoP does not provide a flowchart or hierarchy for resolving overlaps; it simply instructs decision‑makers to apply the other SoP “in accordance with the terms of that Statement of Principles as in force from time to time” (s 11).

Repeal of the 2015 SoP: Section 4 repeals the earlier SoP. Practitioners must ensure they are using the 2023 instrument for claims from 23 May 2023 onwards (s 2). Decisions made under the earlier instrument are not addressed by transitional provisions in this text; advisers should note the absence of transitional language.

Limited scope: The instrument applies only to claims to which s 120A VEA or s 338 MRCA apply (s 5) and only to the enumerated categories of “relevant service” in the Schedule. Claims outside those statutory categories are unaffected by this SoP.

No procedural or remedial detail: The SoP provides no guidance on how to prove the factors, the standard of evidence beyond “reasonable hypothesis”, the procedural steps for claimants, or the remedies if a decision ignores the SoP. Those matters are governed by the VEA/MRCA and administrative law processes but are not set out here.

In sum, the main operational “gotchas” are the narrowness of the single listed factor, the temporal exclusion for conditions that “arose out of” service, the requirement of material contribution/aggravation, the need for clinical‑management evidence, and the necessity to cross‑check other SoPs where overlap exists (ss 9-11; Schedule). Advisors should structure evidence bundles and submissions to map directly to these textual elements.

Compliance for claimants and advisers means assembling and presenting evidence that directly addresses the instrument’s definitional and factorial requirements, and ensuring decision‑makers are asked to apply the 2023 SoP rather than the repealed 2015 instrument.

1. Confirm statutory applicability

• Verify that the claim is one to which section 120A of the VEA or section 338 of the MRCA applies (s 5). The SoP is only applicable within these claim types; if the claim does not fall under those provisions, this instrument will not govern the “reasonable hypothesis” test.

2. Use the operative definition of albinism

• Ensure clinical evidence is framed against the SoP’s definition in s 7(2): genetic disorder(s) of melanin biosynthesis, with typical features such as reduced hair/skin/eye pigmentation, misrouting of optic nerve fibres and other ocular abnormalities. Clinical records should document these features explicitly rather than relying only on ICD coding (s 7(3)-(4)).

3. Address the single listed factor directly

• The SoP requires at least one factor exists to raise a reasonable hypothesis and provides one factor: inability to obtain appropriate clinical management for albinism (s 9(1)). Evidence should be tailored to show a failure or inability to access appropriate clinical management: e.g. documented missed referrals, unavailability of specialists in theatre, delays in care attributable to service conditions, or records indicating inability to obtain prescribed interventions.

4. Meet the temporal and causation limits

• For s 9(1) to apply, show that the person’s albinism was suffered or contracted before or during the relevant service, and did not arise out of the relevant service (s 10(2)). Evidence of onset dates, paediatric or pre‑service records, and contemporaneous medical notes are therefore important. Where the claim alleges aggravation, include medical opinion linking lack of management to material contribution or aggravation of the albinism (s 10(2)).

5. Demonstrate material contribution or aggravation where required

• The SoP requires that inability to obtain appropriate clinical management materially contributed to, or aggravated, the albinism (s 10(2)). Obtain clinical expert opinions that connect the absence or inadequacy of management to measurable deterioration, increased risk, or progression of clinical features of albinism, and explain how the absence of management made a material difference to the condition.

6. Prepare for death claims using the terminal event rubric

• If the claim is for death from albinism, prepare evidence showing that death was from a terminal event or condition that was contributed to by albinism (s 7(5)). Use the Schedule’s examples (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function) as starting points; provide clinical causation opinions that explain how albinism contributed to the terminal event.

7. Check for overlap with other SoPs

• If any factor or piece of evidence refers to an injury or disease that is subject to another RMA SoP, those other SoP factors will apply in accordance with their terms (s 11). Cross‑check the RMA’s list of Statements of Principles to identify possible overlaps and prepare evidence that addresses both instruments’ factors where necessary.

8. Present contemporaneous records and expert opinions

• Because the SoP focuses on clinical management availability and on material contribution/aggravation, contemporaneous medical records, appointment logs, referral letters, military medical unit notes, and independent clinical expert reports will be the primary materials to marshal. Expert reports should map their conclusions explicitly to the SoP text: (a) identify the clinical features of albinism per s 7(2); (b) explain whether appropriate clinical management was obtained and, if not, why; (c) opine on material contribution or aggravation per s 10(2); and (d) in death cases, state contribution to the terminal event per s 7(5).

9. Ask decision‑makers to apply the 2023 SoP and note repeal of the prior SoP

• Cite the 2023 instrument (No. 31 of 2023) and its commencement date (23 May 2023, s 2) when lodging or arguing a claim, and note that the 2015 SoP has been repealed (s 4). Ensure that submissions and evidence are mapped to the 2023 factors and definitions rather than older language.

10. Record and articulate the link to “relevant service”

• The Schedule defines “relevant service” (operational service, peacekeeping service, hazardous service, British nuclear test defence service under the VEA; warlike and non‑warlike service under the MRCA). Ensure claim materials address which category of relevant service applies and how the inability to obtain appropriate clinical management or the contribution to the terminal event is tied to the relevant service.

11. Anticipate cross‑examination points

• Expect decision‑makers and reviewers to test (a) whether the clinical management that was unavailable was indeed the appropriate standard of care for albinism, (b) whether lack of management materially contributed or merely coincided with deterioration, and (c) whether the condition actually “arose out of” service in a way that would exclude application of s 9(1). Prepare supporting evidence accordingly.

12. Maintain chain of evidence for causal claims

• The instrument’s operative linkages require causal connections between lack of management and material aggravation or contribution. Build a coherent chronology, supported by medical opinion, that ties service events, absence of management, clinical progression, and (if relevant) terminal events together.

13. Keep the SoP text handy in submissions

• Submissions and expert reports should quote relevant sub‑sections (for instance, s 7(2), s 9(1), s 10(2), s 7(5), and Schedule definitions) and demonstrate directly how the evidence satisfies each textual threshold.

Complying with this SoP is therefore an exercise in targeted evidence gathering and focused legal argument: show the condition matches the statutory definition; prove inability to obtain appropriate clinical management; show temporal alignment and that the lack of management materially contributed to or aggravated the condition; and, for death claims, show contribution to a terminal event (ss 7-10; Schedule). Cross‑check other SoPs and apply the 2023 instrument from its commencement date (ss 2, 4, 11).