Statement of Principles concerning chronic myeloid leukaemia (Balance of Probabilities) (No. 58 of 2023)

The SoP rests on a small number of tightly defined legal and medical concepts that determine how a claim can be accepted as service-related. The primary concepts are definition of the disease, qualifying exposure factors, temporal thresholds, and the link to relevant service.

Disease definition: The instrument specifies a diagnostic definition of chronic myeloid leukaemia for these purposes: CML means a malignant neoplasm of blood characterized by predominant myeloid cell overpopulation and the presence of a Philadelphia chromosome or BCR-ABL1 gene or gene product (s7(2)(a)). The instrument explicitly excludes atypical chronic myeloid leukaemia, chronic eosinophilic leukaemia, chronic neutrophilic leukaemia, leukemoid reactions and myelomonocytic leukaemia (s7(2)(b)). The SoP also notes that, while ICD‑10‑AM code C92.1 ordinarily applies to CML, the legal meaning for the instrument is the statutory definition at s7(2) rather than the code (s7(3)-(4)).

Qualifying exposure factors: Section 9 lists three alternative factors, any one of which may suffice to establish connection on the balance of probabilities. The primary ionising-radiation threshold is a cumulative equivalent dose to bone marrow of at least 0.05 sievert, with exposure at least two years before clinical onset (s9(1)). The SoP also recognises ablative radioactive iodine therapy for thyroid cancer as a qualifying exposure, provided the first exposure was at least two years before clinical onset (s9(2)). Finally, inability to obtain appropriate clinical management is a non-exposure factor that, subject to limits, can be the basis of a finding (s9(3)).

Dose reconstruction methodology: The Schedule defines cumulative equivalent dose and requires calculation in accordance with the methodology set out in a Guide published by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) as in force on 2 August 2017 (Schedule 1). The Schedule states that cumulative equivalent dose excludes normal background radiation exposure in Australia and notes that example sources of exposure include nuclear weapons testing presence, diagnostic or therapeutic ionising radiation procedures, and being an aircrew (Schedule 1, cumulative equivalent dose definition and notes).

Temporal and causal link to service: Any factor relied upon must be related to the person’s relevant service (s10(1)). The instrument defines relevant service in the Schedule as certain categories under the VEA and MRCA (Schedule 1). The clinical-management factor (s9(3)) is constrained by s10(2): it applies only to material contribution to, or aggravation of, CML where the person’s CML was suffered or contracted before or during relevant service but did not arise out of that service.

Interaction with other SoPs: Section 11 provides that where a factor in s9 refers to an injury or disease for which there exists another SoP determined under subsection 196B(3) of the VEA, the factors in that other SoP apply according to their terms.

Standard of proof and RMA view: The instrument is framed to be used on the balance of probabilities for statutory claims, and the RMA records its view that the available sound medical‑scientific evidence supports that CML and death from CML can be related to relevant service (s8). The instrument therefore functions as an evidential and legal benchmark for decision-makers applying statutory tests in ss120B VEA and s339 MRCA (s5).

The instrument applies to persons making claims that fall under section 120B of the VEA or section 339 of the MRCA, that is, veterans and certain members of the Australian Defence Force whose claims engage those statutory provisions (s5). The Schedule defines “relevant service” to include eligible war service (other than operational service) under the VEA, defence service (other than hazardous service and British nuclear test defence service) under the VEA, and peacetime service under the MRCA (Schedule 1). Accordingly, the SoP targets claimants whose service falls within those categories. The instrument was made by the RMA and therefore is a determination that will be used by decision-makers who administer entitlements under the VEA and MRCA in assessing causation and service connection (s3, s5).

Diagnostically, the instrument’s disease definition affects which claimants may benefit from the SoP. The SoP requires demonstrable presence of the Philadelphia chromosome or BCR‑ABL1 gene or gene product as part of the CML definition (s7(2)(a)). Claimants whose haematological diagnosis lacks those markers, or whose condition is one of the explicitly excluded conditions listed at s7(2)(b), are removed from the class of persons to whom this SoP applies. The instrument also specifies that death from CML includes death from a terminal event or condition contributed to by the person’s CML (s7(5)), which affects dependants and estate interests where the terminal event contributed to by CML is the proximate or ultimate cause of death (Schedule 1, definition of terminal event).

Individuals seeking to rely on ionising radiation exposure must be able to show cumulative equivalent dose to bone marrow of at least 0.05 sievert, calculated in accordance with the ARPANSA Guide referenced in the Schedule (s9(1); Schedule 1). This raises a procedural and evidential burden on claimants who must establish exposures and their timing. Similarly, reliance on ablative radioactive iodine treatment requires evidence of the therapy and timing relative to clinical onset (s9(2)). The clinical-management factor (s9(3)) targets persons who, by the instrument’s terms, suffered or contracted CML before or during relevant service but where their condition did not arise out of service , those persons may assert material contribution or aggravation arising from inability to obtain appropriate management (s10(2)). Thus the SoP affects three distinct claimant groups: those with qualifying radiation exposures; those who received ablative radioactive iodine therapy; and those with pre-existing or pre-service CML who can show failure to obtain appropriate clinical management during relevant service.

Administrative actors charged with adjudication under the VEA and MRCA are directly affected insofar as they must apply this SoP when considering causation in claims that fall under s120B VEA or s339 MRCA (s5). The RMA is the author of the instrument and its Chairperson affixed the common seal (front page and s3), but the instrument itself does not detail which administrative body decides claims; it is designed to be applied by decision-makers under the VEA and MRCA statutory frameworks.

Finally, the Schedule’s reference to dose reconstruction methodology and examples of exposure sources identifies specific occupational and historical exposures (for example being present during testing or use of nuclear weapons, undergoing diagnostic or therapeutic procedures with ionising radiation, being aircrew) as potential contexts in which a claimant’s exposures may have arisen (Schedule 1, cumulative equivalent dose definition and notes). This affects claimants from those contexts who may now have a clear statutory pathway to link CML to service if they can establish the requisite dose thresholds and timing.

The Statement of Principles itself does not create positive duties in the manner of a statute imposing obligations on citizens; rather, it establishes legal and evidential benchmarks that decision‑makers must apply when determining whether chronic myeloid leukaemia, or death from it, is connected with relevant service for claims under the VEA and MRCA (s3, s5). The principal rights created or clarified by the instrument are procedural and substantive rights of claimants to have their CML considered within the terms of this SoP when seeking service connection under s120B VEA or s339 MRCA (s5).

For claimants, the SoP confers a right to have the listed factors assessed as the means of establishing causation on the balance of probabilities. Practically this means a claimant has the right to rely on one or more of the factors in s9 when arguing that their CML or death from CML is related to relevant service. Those factors are alternatives; only one need exist to support a finding, provided the factor is related to relevant service (s9; s10(1)). The SoP establishes the evidentiary criteria that must be satisfied for each factor: timing requirements (at least two years before clinical onset for radiation and radioactive iodine exposures; s9(1)-(2)), the dose threshold for ionising radiation (at least 0.05 sievert to the bone marrow; s9(1)), and the specific scope for clinical-management failures (s9(3), s10(2)).

Decision-makers applying the VEA and MRCA have a duty to apply the SoP where the relevant statutory provisions require it. The instrument was made under subsection 196B(3) of the VEA (s3), and s11 expressly provides that factors referring to an injury or disease covered by another SoP must be applied in accordance with that other SoP as in force (s11). This imposes a legal constraint on adjudicators: where a factor refers to another SoP, the terms of that other instrument govern the assessment of that factor.

The Schedule places a technical duty on those reconstructing radiation doses: cumulative equivalent dose must be calculated in accordance with the ARPANSA Guide "as in force on 2 August 2017" (Schedule 1). Thus there is a procedural framework and an implied duty for dose reconstruction to follow that methodology. The Schedule also defines that cumulative equivalent dose excludes normal background radiation exposure in Australia and must be calculated as an average over the mass of a specific tissue or organ where dose reconstruction requires combination of multiple sources (Schedule 1).

For persons contesting decisions, the SoP sets the standard of proof to the balance of probabilities when establishing that a factor exists and is related to relevant service. The RMA records its view that sound medical‑scientific evidence supports that it is more probable than not that CML and death from it can be related to relevant service (s8). That statement describes the evidential posture in which the SoP is intended to be applied. The instrument does not itself create appeal or review rights; those rights lie in the statutory frameworks of the VEA and MRCA, which the SoP is designed to inform (s5).

There are no penalties or criminal sanctions in the instrument for non-compliance; the legal effect is evidentiary and determinative within the compensatory statutes rather than punitive. Decision-makers are required to use the SoP as applicable, and claimants are required to produce or adduce evidence relevant to the factors listed if they wish to rely on them.

The instrument contains no express penal provisions, enforcement mechanisms, or civil penalties. It is a declaratory instrument that sets the medical and evidential criteria for connecting chronic myeloid leukaemia and death from CML to relevant service for the purposes of claims under the VEA and MRCA (s3, s5). Enforcement in practice takes the form of how decision-makers apply the SoP within the statutory decision‑making frameworks of the VEA and MRCA; the instrument itself does not specify administrative sanctions or enforcement procedures.

Because the SoP is made under subsection 196B(3) of the VEA (s3), its legal effect is to provide a statutory benchmark for causation determinations in claims under s120B of the VEA or s339 of the MRCA (s5). That means a decision-maker considering such a claim will use the factors and definitions in this instrument when determining whether the statutory tests for service connection are satisfied. The instrument places no direct penalties on claimants, medical practitioners, or third parties for failing to meet its tests. Instead, the practical consequence of failing to satisfy the SoP’s factors will be an adverse outcome on the claim, including refusal of entitlement or denial of service connection under the relevant Acts.

The Schedule requires that cumulative equivalent dose be calculated in accordance with the ARPANSA Guide as in force on 2 August 2017 (Schedule 1). That creates a technical requirement for dose reconstruction. In practice, forensic or occupational dose reconstruction undertaken by an administering agency, independent expert, or consultant that fails to apply the specified methodology risks producing evidence that decision-makers may not accept as compliant with the SoP’s requirements. The instrument does not itself prescribe remedial consequences for incorrect dose calculations, but adjudicators applying the SoP are bound to assess evidence against the instrument’s defined methodology.

Where a factor in s9 refers to an injury or disease subject to another SoP, s11 requires that the factors in that other SoP apply according to their terms. This cross-reference is an enforcement channel in the sense that it imports the terms of other SoPs into the analysis. Again, the instrument provides no internal sanctions; it prescribes which technical rules and definitions govern the assessment.

Because the SoP addresses causation and is used within compensatory statutes, enforcement and any remedial outcomes,acceptance of a claim, granting of entitlements, or denial,flow through existing administrative and statutory appeal mechanisms under the VEA and MRCA. The instrument itself does not establish new tribunal or court procedures, and it does not prescribe criminal or civil penalties for false claims or other misconduct; those matters remain governed by the broader legal framework in which the SoP is applied.

The instrument is explicitly made under and for use with the VEA and MRCA. Section 3 identifies the legislative authority as subsection 196B(3) of the VEA. Section 5 confines application of the SoP to claims to which section 120B of the VEA or section 339 of the MRCA applies. Section 11 provides a mechanism for interaction with other Statements of Principles: if a factor in s9 refers to an injury or disease that is itself the subject of another SoP determined under subsection 196B(3) of the VEA, then the factors in that other SoP apply in accordance with its terms (s11). Therefore this SoP is designed to operate within a network of SoPs as specified by the VEA.

The instrument also interacts with medical classification instruments by reference. Section 7(3)-(4) notes that while CML attracts ICD‑10‑AM code C92.1, the legal meaning for this instrument is the statutory definition in s7(2), and a reference to an ICD‑10‑AM code is a reference to the code as assigned in The International Statistical Classification of Diseases and Related Health Problems, Tenth Revision, Australian Modification, Tenth Edition, effective 1 July 2017 (s7(3)-(4)). This cross-reference clarifies that while diagnostic coding may be informative, the statutory definition in s7(2) controls application of the SoP.

Dose reconstruction and radiation science standards are incorporated by reference in the Schedule. The Schedule defines cumulative equivalent dose and requires that it be calculated in accordance with the methodology set out in the ARPANSA Guide referenced, as in force on 2 August 2017 (Schedule 1). That creates an operational interaction between this legal instrument and ARPANSA technical guidance. Where dose or exposure evidence is central to a claim, decision-makers and experts must reconcile medical evidence with the ARPANSA methodology specified in the Schedule.

The Schedule’s notes identify circumstances that may produce ionising radiation exposure, such as presence during or subsequent to nuclear weapons testing or use, undergoing diagnostic or therapeutic medical procedures involving ionising radiation, and being an aircrew (Schedule 1, cumulative equivalent dose notes). Where those factual contexts implicate other legal regimes,such as historical compensation schemes for nuclear test participants or specialised records held by other agencies,the SoP will intersect with those bodies of law and agency records, although the instrument itself does not directly address those regimes.

Section 10(1) requires that any factor relied upon must be related to the person’s relevant service. The Schedule defines “relevant service” in terms of categories under the VEA and MRCA (Schedule 1). That legal framing ties the SoP’s application to the statutory definitions and thresholds that determine whose service is captured by the VEA and MRCA. Therefore, the SoP’s practical operation will depend on how a claimant’s service is characterised under those Acts.

Finally, s11’s cross-reference clause means that where factors invoke other injuries or diseases already governed by separate SoPs, this instrument imports the terms and technical rules of those instruments. This creates a networked legal environment where multiple SoPs can interact, and where adjudicators must trace and apply the terms of each relevant SoP as in force.

This instrument expressly repeals the prior Statement of Principles concerning chronic myeloid leukaemia No. 48 of 2014 (Federal Register of Legislation No. F2014L00480) (s4). The instrument itself is dated 24 April 2023 and commences on 23 May 2023 (front page; s2). It was made under subsection 196B(3) of the VEA (s3) and bears the RMA’s common seal affixed at the direction of the Chairperson (front page).

The Schedule contains an incorporated reference to an external technical guide and fixes the version of that guide for the purposes of dose calculation: cumulative equivalent dose must be calculated in accordance with the ARPANSA Guide "as in force on 2 August 2017" (Schedule 1). By specifying that date, the instrument locks in a particular version of the methodology rather than leaving the methodology to the latest iteration; any future amendment to the ARPANSA Guide after 2 August 2017 will not automatically change this instrument’s required methodology unless the SoP itself is amended.

Section 11 provides a mechanism for the SoP to interact with other SoPs; changes to other SoPs determined under subsection 196B(3) of the VEA will therefore affect the operation of this instrument where cross-referenced factors are involved. In practice, if another SoP is amended, any factor in s9 that refers to an injury or disease covered by that other SoP will be applied under the terms of the other SoP as it is in force from time to time (s11). That design means the RMA can amend or replace other SoPs over time and those amendments will integrate into causation assessments involving cross-referenced factors.

Aside from the express repeal of the 2014 SoP, the instrument contains no internal amendment clauses, transition rules, or savings provisions. The commencement clause fixes the operative date (s2). Because this is a determinative instrument made under s196B(3) of the VEA, any future amendments or replacements of this SoP would themselves be effected by subsequent determinations of the RMA under the same statutory power and documented in the Federal Register of Legislation in the usual manner.

Users of the SoP should be attentive to the express dating of the ARPANSA methodology in the Schedule and to s11’s cross-reference to other SoPs, because those are the routes by which future legal or technical changes elsewhere (other SoPs, ARPANSA guidance) may alter how this SoP operates in practice.

The instrument itself contains no record of litigation. It is a Statement of Principles determined by the Repatriation Medical Authority; the text includes the RMA’s view and the definitions and factors it has determined, but it does not reference any judicial or tribunal decisions, precedent, or prior litigation history (see the whole instrument). The front matter records the RMA’s determination and the affixing of the common seal under the Chairperson’s direction, but it does not disclose any challenges or court proceedings relating to this SoP.

Because the instrument is made under s196B(3) of the VEA and is intended to be applied in claims under s120B of the VEA and s339 of the MRCA (s3, s5), the SoP will ordinarily be deployed in administrative decision-making and may be the subject of review or appeal under the review frameworks that govern VEA and MRCA decisions. The instrument, however, contains no narrative or factual account of any litigation involving prior versions (for example the repealed 2014 SoP) or of legal challenges to the RMA’s determinations.

For practitioners and researchers, the absence of litigation history in the text means two things. First, the SoP should be read as an authoritative RMA determination that will be applied by decision-makers unless and until it is successfully challenged or superseded. Second, because the instrument does not catalogue case law, anyone wishing to understand how tribunals or courts have applied prior or similar SoPs must search separately for administrative decisions and judicial reviews that interpret s196B instruments, the VEA and MRCA causation provisions, or the interaction of SoPs with claim adjudication.

In short, the instrument is silent about litigation. It neither records nor summarises any challenges or judicial interpretation. Any assertion about litigation outcomes or interpretive history would require reference to external case law or tribunal records, which are not contained in this instrument.

The instrument contains several technical features and limits that create potential pitfalls for claimants, their advisers, and decision-makers. These features are matters of textual detail in the SoP; they materially constrain who can rely on the instrument and how factors must be evidenced.

Narrow statutory disease definition. The SoP defines CML by reference to specific cytogenetic or molecular markers: the presence of a Philadelphia chromosome or BCR‑ABL1 gene or gene product is part of the statutory definition (s7(2)(a)). Conditions that may be clinically similar or historically grouped with CML are expressly excluded (s7(2)(b)). A claimant whose diagnostic record does not demonstrate the Philadelphia chromosome or BCR‑ABL1, or whose condition falls within one of the excluded entities, will not fit the statutory definition even if ICD coding might suggest C92.1 (s7(3)). The instrument explicitly states that the legal meaning is that given in s7(2) rather than the ICD code (s7(3)). That detail can be decisive if historical records are incomplete or use older diagnostic nomenclature.

Dose threshold and organ-specific requirement. The ionising-radiation factor requires a cumulative equivalent dose of at least 0.05 sievert to the bone marrow (s9(1)). The Schedule defines cumulative equivalent dose as the total dose received by the particular organ or tissue, calculated per the ARPANSA Guide (Schedule 1). This creates two potential pitfalls: (1) the dose must be to the bone marrow specifically, not merely a whole-body or generic exposure figure; and (2) the cumulative equivalent dose excludes normal background radiation exposure in Australia (Schedule 1), so background exposure cannot be used to meet the threshold. For persons with mixed-source exposures, the Schedule requires combination of dose estimates for each type of radiation and averaging over the relevant tissue mass, which can complicate reconstruction (Schedule 1).

Fixed methodological reference. The Schedule fixes calculation methodology to the ARPANSA Guide "as in force on 2 August 2017" (Schedule 1). If dose reconstruction experts use a different version of the methodology or a different technical standard, decision-makers may treat the evidence as non‑compliant with the SoP. The instrument therefore requires attention to the precise version of the ARPANSA Guide specified.

Timing threshold. The two-year minimum interval between exposure (radiation or first radioactive iodine exposure) and clinical onset is mandatory (s9(1)-(2)). Claims where exposure occurred less than two years before clinical onset cannot rely on those factors under this SoP. That timing requirement is a strict cut-off embedded in the instrument.

Scope limitation for clinical-management factor. The "inability to obtain appropriate clinical management" factor (s9(3)) applies only in a narrow set of circumstances. Section 10(2) clarifies that the factor is available only where the person’s CML was suffered or contracted before or during relevant service and did not arise out of that service, and where the inability to obtain appropriate management materially contributed to or aggravated the condition. Therefore claimants who allege lack of appropriate management but whose CML arose out of the relevant service cannot rely on s9(3). Establishing that the condition pre-existed or was contracted before or during service, but not arising out of it, will be a necessary and potentially contested factual finding.

Cross-references to other SoPs. Section 11 imports other SoPs where a factor refers to an injury or disease covered by another SoP. This can create complexity where the factor’s operation depends on technical definitions or thresholds contained in a different instrument; practitioners must trace and apply the terms of those other SoPs as they are in force.

Death definition and terminal events. The instrument includes death from CML as a compensable outcome if the death was contributed to by the person’s CML (s7(5)). The Schedule defines terminal event broadly to include causes such as pneumonia, respiratory failure, cardiac arrest, circulatory failure, and cessation of brain function (Schedule 1). Where a death certificate lists one of those proximate causes, claimants must be able to connect that terminal event back to the person’s CML in accordance with the SoP.

Record quality and historical exposures. Many of the factors require documentary, medical, or exposure records,radiation exposure records subject to dose reconstruction per ARPANSA methodology, treatment records establishing dates of ablative radioactive iodine therapy, and contemporaneous clinical management records. The instrument’s precise technical requirements mean that absent, incomplete, or inconsistent records can be fatal to a claim, especially where cumulative dose reconstruction is necessary.

No penalties or directions for failing to apply the methodology. The instrument does not set out procedural remedies if agencies deviate from the ARPANSA methodology or if dose reconstructions are contested. Disputes about methodology or factual findings will play out in the statutory decision-making and review processes under the VEA and MRCA, but the SoP itself provides no dispute resolution pathways.

In short, the key gotchas arise from the instrument’s technical and narrow definitions (molecular diagnostic requirement; organ-specific dose threshold), fixed methodological reference, strict timing windows, constrained availability of the clinical-management factor, and the need to integrate other SoPs where cross-referenced. Advisers must ensure documentary and expert evidence aligns precisely with the textual requirements of the SoP.

Compliance with this Statement of Principles is a matter of meeting the evidential and definitional requirements the instrument prescribes so that a decision-maker applying the VEA or MRCA can properly conclude, on the balance of probabilities, that chronic myeloid leukaemia or death from it is related to the person’s relevant service. The practical steps below map directly to the statutory text and the Schedule.

1. Confirm the diagnosis meets the statutory definition. Obtain and produce medical records that demonstrate CML as defined in s7(2)(a): documentation of a malignant myeloid neoplasm with a predominant overpopulation of myeloid cells, and laboratory evidence of a Philadelphia chromosome or BCR‑ABL1 gene or gene product. If the diagnostic record is silent on BCR‑ABL1 or Philadelphia chromosome testing, seek retrospective laboratory confirmation where possible. Ensure the condition is not one of the excluded entities listed in s7(2)(b).

2. Establish the relevant service classification. Determine whether the claimant’s service fits within the Schedule’s definition of relevant service: eligible war service (other than operational service) under the VEA; defence service (other than hazardous service and British nuclear test defence service) under the VEA; or peacetime service under the MRCA (Schedule 1). Documentary service records should be obtained to establish the correct legal category because s10(1) requires that any factor be related to the person’s relevant service.

3. For ionising radiation claims, prepare dose reconstruction evidence per the prescribed methodology. The SoP requires a cumulative equivalent dose to the bone marrow of at least 0.05 sievert, calculated in accordance with the ARPANSA Guide as in force on 2 August 2017 (s9(1); Schedule 1). Engage an expert or agency that will use the specified ARPANSA methodology and will calculate cumulative equivalent dose to the bone marrow specifically, excluding normal background radiation in Australia. Ensure the exposure(s) relied upon occurred at least two years before clinical onset (s9(1)). Where multiple radiation sources are involved, ensure the reconstruction combines dose estimates for each radiation type and averages over the relevant tissue mass in accordance with the Schedule.

4. For ablative radioactive iodine therapy claims, secure treatment records. Establish that the person underwent ablative radioactive iodine treatment for thyroid cancer, and verify dates showing that the first exposure occurred at least two years before clinical onset of CML (s9(2)). Medical oncology and hospital discharge summaries, operative notes, and nuclear medicine records will be the relevant documentary sources.

5. For claims alleging inability to obtain appropriate clinical management, document timing and causation constraints. The clinical-management factor applies only to material contribution to or aggravation of CML where the condition was suffered or contracted before or during relevant service and did not arise out of the service (s9(3); s10(2)). Assemble contemporaneous medical records demonstrating CML pre-existed or was present before or during service, and records or testimony showing that appropriate clinical management was unavailable, denied, or otherwise not provided during the relevant period. Establish that the lack of appropriate management materially contributed to or aggravated the condition.

6. Address temporal thresholds and onset date. For both the radiation and radioactive iodine factors, the SoP requires the exposure to have occurred at least two years before the clinical onset of CML (s9(1)-(2)). Prepare evidence of clinical onset timing, such as first abnormal blood test dates, first oncology clinic notes, or first date of diagnosis. Timelines will be crucial to establish whether the two-year rule is satisfied.

7. If a factor refers to another SoP, obtain and apply that SoP’s terms. Section 11 requires that where a factor in s9 refers to an injury or disease covered by another SoP, the factors in that other SoP apply in accordance with its terms (s11). Identify any cross-referenced conditions and secure the current versions of those SoPs to ensure compliance.

8. Prepare for technical scrutiny of records. Because the Schedule excludes background radiation and fixes the ARPANSA methodology to a particular version, ensure that experts explicitly state the methodology used and confirm conformity with the ARPANSA Guide as of 2 August 2017 (Schedule 1). Experts should provide clear statement of dose to bone marrow expressed in sieverts and an explanation of source combination and averaging over tissue mass where applicable.

9. Anticipate record gaps and plan mitigation. If historical exposure records are incomplete, collect alternative corroborative material such as service records indicating presence at nuclear test sites, aircrew flight logs indicating cumulative cosmic radiation exposure, or medical imaging histories that demonstrate diagnostic or therapeutic exposures. Where dose reconstruction requires estimation, ensure the expert’s methodology is transparent and linked to the ARPANSA Guide referenced in the Schedule.

10. Present causation in the statutory framing. The SoP is to be applied on the balance of probabilities (s8). In submissions to decision-makers, frame evidence to show that at least one factor exists, that it satisfies the description and timing in s9, and that it is related to the person’s relevant service (s10(1)). For clinical-management claims, additionally show that the condition pre-existed or was contracted before or during service and did not arise out of the service, and that inability to obtain appropriate management materially contributed to or aggravated the condition (s10(2)).

By aligning documentary, laboratory, and expert evidence with the SoP’s textual requirements,diagnostic molecular markers, organ-specific cumulative dose calculated under the ARPANSA Guide dated 2 August 2017, two-year timing thresholds, and the service relationship,the claimant maximises conformity with the instrument’s criteria. Decision-makers will apply the SoP’s definitions and factors when assessing causation under the VEA and MRCA (s3, s5), so compliance is primarily evidential and technical rather than procedural within the SoP itself.