Statement of Principles concerning animal envenomation (Balance of Probabilities) (No. 2 of 2026)

The instrument revolves around a compact set of concepts that determine whether animal envenomation, or death from it, can be related to relevant service for the purposes of compensable claims. The core definitional point is animal envenomation, which the instrument defines in substantive rather than purely code terms: it means experiencing the toxic or hypersensitivity effects of contact with animal venom (s 7(2)). The instrument also ties that definition to ICD-10-AM coding, observing that animal envenomation attracts codes T63, X20-X27 and X29, but clarifies that the statutory meaning is the definition in s 7(2) (s 7(3)) and cites the Tenth Edition of ICD-10-AM effective 1 July 2017 (s 7(4)).

Death from animal envenomation is treated to include death from a terminal event or condition to which the envenomation contributed (s 7(5)); terminal event is defined in the dictionary to include discrete proximate or ultimate causes such as pneumonia, respiratory failure, cardiac arrest, circulatory failure and cessation of brain function (Schedule 1). Thus the link to death is not limited to immediate fatal venom effects, it extends to terminal events for which envenomation was a contributing cause.

Causation is framed in probabilistic terms. The RMA states that, on the sound medical‑scientific evidence available, it is of the view that it is more probable than not that envenomation and death from envenomation can be related to relevant service (s 8). The instrument then prescribes the factual factors which, if established, constitute the necessary causal link on the balance of probabilities: internal absorption of venom from a bite, sting or injection within three days before clinical onset (s 9(1)); external contact with venom from a snake or scorpion at the time of clinical onset (s 9(2)); internal absorption of venom from a tick of the family Ixodidae within 12 days before clinical onset (s 9(3)); and inability to obtain appropriate clinical management for animal envenomation before clinical worsening (s 9(4)).

Two relationship rules limit how those factors operate in the service context. First, any factor in s 9 must be related to the person’s relevant service (s 10(1)). Second, the clinical-worsening factor in s 9(4) applies only to material contribution to, or aggravation of, animal envenomation where the envenomation was suffered or contracted before or during, but did not arise out of, the person’s relevant service (s 10(2)). The Schedule then defines relevant service as specific categories under the VEA and MRCA (Schedule 1).

Finally, the instrument provides a rule for overlap with other Statements of Principles: where a s 9 factor refers to injury or disease covered by another Statement determined under subsection 196B(3) of the VEA, the factors in that other Statement apply in accordance with its terms (s 11). The instrument thus inserts itself into a broader matrix of RMA Statements and cross‑references them as applicable.

This Statement of Principles directly affects persons making claims under the VEA or MRCA by defining when animal envenomation, or death from it, can be related to relevant service. The instrument expressly applies to claims to which section 120B of the VEA or section 339 of the MRCA applies (s 5). The Schedule defines relevant service as certain categories of VEA or MRCA service: eligible war service (other than operational service), defence service (other than hazardous service and British nuclear test defence service) under the VEA, and peacetime service under the MRCA (Schedule 1). Accordingly, veterans, members of the Forces and other persons whose service fits those statutory categories will be the primary subjects of decisions that use this Statement as the medical causation standard.

Other actors are affected indirectly. The Repatriation Medical Authority is the decision-making body that determines Statements of Principles under subsection 196B(3) of the VEA, and this instrument is made under that head of power (s 3). Medical practitioners preparing clinical evidence for claims will have to map clinical findings and timelines to the factors the instrument prescribes, for example as to the timing of internal absorption of venom (s 9(1)-(3)) and clinical onset. Adjudicators and decision-makers within agencies that process VEA and MRCA claims will apply this Statement to determine whether a claimant has established the required causal connection. Because the instrument references ICD-10-AM codes (s 7(3)-(4)) and provides a detailed list of organisms that constitute venomous animals (Schedule 1), forensic clinicians and medicolegal report writers will need to align diagnostic coding and species identification to the Statement’s definitions.

There are also indirect systemic effects on record-keeping, clinical referrals and operational practices for defence units and health services that treat or document envenomation events. The instrument’s time limits for causation (three days for bites/stings/injections, immediate timing for spitting or spraying by snake or scorpion, 12 days for Ixodidae ticks) place evidentiary expectations on claimants and clinicians to document exposure, clinical onset and any deficiencies in obtaining appropriate clinical management (s 9). Finally, because the Statement repeals the 2016 instrument (s 4), persons and practitioners who relied on the earlier Statement need to note the change in the authoritative causation standard from 19 January 2026 (s 2, s 4).

This instrument primarily prescribes the factual and medical conditions that must be present for the Repatriation Medical Authority to view animal envenomation and death from animal envenomation as connected to relevant service on the balance of probabilities. The instrument itself does not create administrative duties, financial entitlements or procedural rights beyond setting the causation standard; it operates as a determinative medical framework under the RMA’s statutory power (s 3, s 8). The critical operational duty for decision-makers is to apply the factors set out in section 9 and the relationship rules in section 10 when assessing causation in applicable claims (s 9, s 10).

For claimants, the practical obligation implied by the instrument is evidentiary: establishing one or more of the factors in section 9, and showing that the existence of the factor is related to the person’s relevant service (s 9, s 10(1)). Section 9 lists four alternative factors, each with concrete temporal or exposure predicates that must be met on the balance of probabilities. For example, a claimant relying on internal absorption from a bite, sting or injection must demonstrate that internal absorption occurred within three days before clinical onset (s 9(1)). A claimant relying on a tick-related causal connection must show internal absorption from a tick of the family Ixodidae within 12 days before clinical onset (s 9(3)). A claimant asserting that external contact with venom caused the condition must show contact with venom from a snake or scorpion at the time of clinical onset (s 9(2)). A claimant invoking the inability to obtain appropriate clinical management must show that inability before clinical worsening (s 9(4)).

The Statement creates a narrower handling for clinical worsening claims. Section 10(2) restricts the application of the clinical-worsening factor in s 9(4) to material contribution or aggravation where the relevant envenomation was suffered or contracted before or during, but did not arise out of, the person’s relevant service. This is a right/limitation rule: it permits a claim based on failure to obtain appropriate care to qualify only in that defined circumstance.

The instrument gives decision-makers a definitional toolkit in the Schedule. Relevant service, MRCA and VEA are defined terms, as are venomous animal and terminal event (Schedule 1). The list of venomous animals is extensive and includes particular taxa and examples (Schedule 1). The instrument does not specify procedural rights, appeal routes, compensation quantum, or timelines for processing claims; these matters lie in the underlying legislation the instrument supports. The Statement therefore functions as an authoritative medical standard to be applied by decision-makers under their statutory responsibilities, rather than a freestanding corpus of rights and duties.

The Statement of Principles contains no express penalty provisions or criminal, civil, or administrative sanctions. The instrument is a determinative medical standard made under subsection 196B(3) of the VEA (s 3) and is descriptive of the medical-factual conditions that must be established for a causal relationship to relevant service to be recognised for claims that fall under section 120B of the VEA or section 339 of the MRCA (s 5). It does not itself create enforcement mechanisms, fines, criminal offences, licensing conditions, or privative clauses.

Enforcement in a practical sense flows from the application of the Statement to claims: decision-makers processing VEA or MRCA claims will apply the factors in section 9 and the relationship rules in section 10 to determine whether animal envenomation or death from it is connected to relevant service. Where the prescribed factors are not established on the balance of probabilities, a causation finding under this Statement will not be satisfied. The instrument does not specify what administrative outcome follows a negative finding; those outcomes are governed by the primary statutory schemes (VEA and MRCA) and their decision‑making processes, which are not reproduced in this Statement.

Because the Statement repeals an earlier RMA Statement (No. 82 of 2016) (s 4), compliance with the current Statement is the standard that will be applied to relevant claims from its commencement date (s 2). The instrument itself does not specify transitional enforcement arrangements or retrospective application. Consequently, the only enforcement‑adjacent consequences contained in the instrument are practical: claimants who cannot adduce evidence meeting the s 9 factors or the relationship requirements in s 10 will, as a matter of the Statement’s terms, lack the RMA‑framed causal connection required under this instrument.

In short, the Statement establishes the medical causation yardstick; it does not create penal or enforcement structures. Any enforcement or rights of review deriving from application of the Statement must be found in the VEA, MRCA and administrative law pathways outside the text of this instrument.

The instrument is explicitly made under the VEA power to determine Statements of Principles, subsection 196B(3) (s 3). It is designed to operate as the RMA’s medical standard for causation in claims covered by section 120B of the VEA and section 339 of the MRCA (s 5). The Schedule defines MRCA and VEA as the shorthand for the Military Rehabilitation and Compensation Act 2004 and the Veterans' Entitlements Act 1986 respectively (Schedule 1). Accordingly, the Statement is an interpretive and evidentiary tool that fits into the statutory architecture created by the VEA and MRCA; it does not replace or restate those Acts’ procedural, entitlement or review provisions.

The Statement cross‑references clinical coding standards, specifying that while animal envenomation attracts ICD-10-AM codes T63, X20-X27 and X29, the instrument’s operative meaning of animal envenomation is the substantive definition in subsection 7(2) (s 7(2)-(3)). It also identifies the relevant ICD-10-AM edition by date and publisher (s 7(4)). That cross-reference ties the Statement’s clinical descriptors into nationally standardised diagnostic coding systems used in health records and medicolegal reports.

Section 11 governs interaction with other Statements of Principles. If a factor in section 9 refers to an injury or disease covered by another Statement determined under subsection 196B(3) of the VEA, the factors in that other Statement apply in accordance with its terms (s 11). This is an explicit rule for overlap or dependency among RMA Statements, indicating that the RMA intended the Statements to operate together rather than in isolation where injuries or diseases overlap.

The Schedule’s definition of venomous animal contains a taxonomic list of organisms and a specific exclusion: it excludes animals whose toxins are distributed within their bodily tissues and cause toxic effects after ingestion (Schedule 1). That exclusion establishes a boundary with other legal or medical frameworks concerning poisoning by ingestion, and thus with determinations that may involve non-envenomation toxin exposure.

Finally, the Statement repeals the previous RMA Statement on animal envenomation (No. 82 of 2016) (s 4). The instrument does not provide transitional rules or indicate whether the repealed Statement continues to operate for older claims; in the absence of transitional language the repeal is absolute as drafted. How that interacts with entitlements, retrospective claims or claims lodged around the commencement date will therefore depend on how the VEA and MRCA process determinations and any procedural rules not contained in this instrument.

The instrument records a limited amendment history within its own operative text. It replaces a prior RMA Statement of Principles concerning animal envenomation, specifically Statement No. 82 of 2016 (Federal Register of Legislation No. F2016L01666), by express repeal (s 4). The making and dating of this instrument are recorded: the Repatriation Medical Authority determined the Statement on 19 December 2025 (cover page) and the instrument commences on 19 January 2026 (s 2). The instrument does not list any intermediate amendments, schedules of amendments, or transitional provisions within its text beyond those entries.

The Schedule also identifies the ICD-10-AM edition relied on for code references, namely the Tenth Edition of The International Statistical Classification of Diseases and Related Health Problems, Australian Modification, effective 1 July 2017 (s 7(4)). That citation functions as a cross-reference point and indicates the diagnostic coding vintage the RMA used in framing the Statement. No other external amendment or amendment mechanism is set out in the instrument itself.

Because the Statement is promulgated under subsection 196B(3) of the VEA (s 3), further amendments to these medical causation standards would be made by the RMA under the same statutory power. The instrument, however, contains no forward-looking amendment clause, sunset provision, or express transitional treatment of claims lodged before the commencement date. The only recorded historical movement in the instrument is the replacement of the 2016 Statement with this 2026 Statement (s 4), the making date of 19 December 2025, and the commencement date of 19 January 2026 (s 2).

Users of the Statement should therefore treat the 2016 instrument as formally repealed from the commencement date and the 2026 Statement as the operative RMA causation standard for animal envenomation after that date, subject to any procedural rules in the VEA and MRCA that are not reproduced in this instrument.

The instrument itself does not record any litigation history. It is a Statement of Principles determined by the Repatriation Medical Authority under subsection 196B(3) of the VEA (s 3), and it contains no references to judicial decisions, reviews, or proceedings. The only historical legal instrument referenced within the text is the prior RMA Statement concerning animal envenomation (No. 82 of 2016), which is expressly repealed (s 4). No case names, decisions, or judicial interpretations are included in the instrument.

The absence of litigation references in the text means that the Statement should be treated as an administrative medical standard rather than a summary of adjudicated legal points. The RMA frames the Statement on the basis that, on the medical‑scientific evidence available, it is more probable than not that animal envenomation and death from animal envenomation can be related to relevant service (s 8). The instrument, however, does not record whether or how that position has been tested in tribunals or courts.

Practitioners and decision-makers therefore have to rely solely on the Statement’s terms, definitions and cross-references (including ICD-10-AM codes and the Schedule) when applying it to claims. Any case law interpreting or challenging RMA Statements, the VEA’s causation provisions, or the application of these factors would need to be sourced outside this instrument, because the instrument contains no litigation history or judicial commentary.

There are several tightly framed, technical features of this Statement that create sharp evidentiary and conceptual boundaries claimants and advisers must note.

1. Narrow temporal windows and specific exposure mechanisms. The factors in s 9 establish strict timing and exposure predicates. Internal absorption from a bite, sting or injection must occur within three days before clinical onset (s 9(1)). Tick-related internal absorption is limited to ticks of the family Ixodidae occurring within 12 days before clinical onset (s 9(3)). External contact is limited to spitting or spraying by snakes or scorpions at the time of clinical onset (s 9(2)). These are alternative and discrete pathways; failing to show the specific timing or mechanism in respect of the chosen factor will mean that the particular s 9 factor is not satisfied.

2. Clinical onset and documentation expectations. The instrument repeatedly uses the term clinical onset as the temporal anchor for causation (ss 9(1)-(3)). Demonstrating the date and nature of clinical onset and linking it to an identifiable exposure will be central to meeting the balance-of-probabilities test. The Statement does not define clinical onset further; practical proof will therefore rest on contemporaneous clinical records, which are not discussed in the instrument but are implicitly required by the temporal predicates.

3. Clinical-worsening limitation. The inability-to-obtain-appropriate-clinical-management factor (s 9(4)) is expressly constrained by s 10(2). It applies only to material contribution to, or aggravation of, animal envenomation where the envenomation was suffered or contracted before or during, but did not arise out of, the person’s relevant service. That is a narrow carve-out and may exclude situations where envenomation arose directly out of service activities.

4. Taxonomic scope and an exclusion. The Schedule’s definition of venomous animal is broad and provides numerous examples (Schedule 1). Importantly, the definition expressly excludes animals that cause toxicity via ingestion of bodily tissues containing toxins. That exclusion separates envenomation from toxin ingestion cases. Claimants whose exposure involved ingestion of toxic animal tissues will not fall within the instrument’s operative definition.

5. Death linkage uses terminal events. Death from animal envenomation includes deaths from terminal events or conditions to which envenomation contributed (s 7(5)). Terminal events are explicitly defined and include conditions such as pneumonia and respiratory failure (Schedule 1). Thus a causal chain where envenomation contributes to a terminal event can fall within the Statement, but proof of contribution to that terminal event will be required.

6. Repeal without transitional language. The instrument repeals the 2016 Statement (s 4) and commences on a stated date (s 2). It contains no transitional provisions addressing how claims spanning the repeal/commencement dates are to be handled. That omission can create practical uncertainty where a claim was assessed under the earlier Statement.

7. No penalties or procedural detail. The Statement does not contain penalty, appeal or adjudicative process detail. It is a medical standard. Consequences of not meeting a s 9 factor are not set out here, they derive from the VEA and MRCA processes.

Each of these points follows from explicit text in the Statement and the Schedule, and they materially constrain how an envenomation claim can be framed and proved under the RMA’s current causation standard.

Compliance in the context of this Statement means mounting evidence and submissions that establish, on the balance of probabilities, at least one of the factors in section 9 and that the factor is related to the person’s relevant service as defined in the Schedule. The Statement places defined, concrete evidentiary predicates on a claimant’s case; meeting those predicates will be the pathway to satisfying the RMA’s causation yardstick.

Key practical steps, drawn from the Statement’s text, are:

1. Identify the relevant factor in s 9 and plan evidence accordingly. Section 9 lists four alternative factors, each with distinct proof points: internal absorption from a bite, sting or injection within three days before clinical onset (s 9(1)); external contact from spitting or spraying by snake or scorpion at time of clinical onset (s 9(2)); internal absorption from an Ixodidae tick within 12 days before clinical onset (s 9(3)); and inability to obtain appropriate clinical management before clinical worsening (s 9(4)). A claimant should not present diffuse assertions; they should select and substantiate the precise s 9 factor relied upon.

2. Document clinical onset with contemporaneous records. The instrument anchors causation to clinical onset (ss 9(1)-(3)). To meet the timing thresholds, clinical records that establish onset dates, symptom evolution, and clinical diagnoses will be central. Where clinical onset is ambiguous, expert medical evidence that links presentation to exposure timing will be necessary.

3. Capture exposure details. For bites, stings, injections, spitting or spraying, and tick attachment, contemporaneous notes, incident reports, photographs, eyewitness statements and species identification if available will assist in satisfying the mechanistic element of the chosen factor. The Schedule’s detailed list of venomous animals (Schedule 1) should guide efforts to identify the organism.

4. If relying on clinical-worsening because of lack of appropriate care, establish the sequence and service relationship. Section 10(2) restricts s 9(4) to cases where the envenomation was suffered or contracted before or during, but did not arise out of, relevant service. Documentation should show timing of envenomation relative to service, attempts to obtain care, the nature of care not obtained, and evidence of clinical worsening materially attributable to that gap.

5. Use ICD-10-AM coding consistently with the Statement. The instrument references specific ICD-10-AM codes but defines animal envenomation substantively in s 7(2). Medical records, diagnostic coding and medicolegal reports that align clinical impressions with both the Statement’s definition and the cited ICD-10-AM codes will reduce friction.

6. Be aware of the exclusion for toxin ingestion. If the exposure involved ingestion of animal tissues that distribute toxins internally rather than envenomation, the Schedule excludes that scenario. Advisers should not conflate ingestion poisoning with envenomation under this Statement (Schedule 1).

7. Address death cases via terminal event linkage. For death claims, gather medical and coronial material showing contribution of envenomation to a recognised terminal event (s 7(5), Schedule 1).

8. Note the repeal and commencement dates when preparing or supplementing existing claims. The 2016 Statement is repealed (s 4) and the new Statement commences on 19 January 2026 (s 2). Where a claim spans the repeal date, advisers should identify which standard the decision-maker proposes to apply and ensure evidence is framed to satisfy the 2026 Statement’s predicates.

9. Frame expert opinions to map explicitly to the Statement. Medical experts instructed should be asked to express opinions in terms of the s 9 factors and the relationship-to-service requirements in s 10. Experts should state whether they consider the factor established on the balance of probabilities and explain the basis of that view in terms the Statement uses.

The instrument itself is silent on procedural timelines, appeal avenues and entitlement administration; compliance steps therefore focus on aligning factual and medical evidence with the Statement’s defined factors and relationship rules so that decision-makers applying the VEA and MRCA causation framework can reach their determinations using the RMA’s stated standard.