Statement of Principles concerning conjunctivitis (Balance of Probabilities) (No. 77 of 2020)

The instrument centres on several interlocking legal and medical concepts. These concepts structure how an applicant proves that conjunctivitis is connected with relevant service for Veterans' Entitlements Act or MRCA claims.

• Scope of condition. Conjunctivitis is framed clinically as inflammation of the conjunctiva, and the text expressly includes blepharoconjunctivitis and keratoconjunctivitis (subsection 7(2)). Subsections 7(3)-(4) link that clinical description to specific ICD‑10‑AM codes (H10, H13.1, H13.2, H16.2) in the ICD edition specified. The instrument therefore combines a clinical definition with an administrative coding reference.
• Balance of probabilities. The SoP is framed as a balance of probabilities instrument. Section 8 records the RMA’s view that, on the sound medical‑scientific evidence available, it is more probable than not that conjunctivitis and death from conjunctivitis can be related to relevant service. The criteria listed in section 9 are the factors the RMA considers must be present to satisfy that evidentiary standard.
• Enumerated causal factors. Section 9 contains an extensive list of discrete factors that, if present and related to relevant service, suffice to establish connection on the balance of probabilities. These factors fall into definable groups: pre‑existing ocular disease or dysfunction (e.g. blepharitis, nasolacrimal duct disorder), infectious aetiologies, allergic or sensitising exposures, irritant chemical or mustard gas exposure, foreign body or trauma, topical medications, systemic drug therapy from a specified list, immunocompromised states, diabetes mellitus, therapeutic radiation in the field of the eye, and inability to obtain appropriate clinical management.
• Temporal windows. Many factors impose tight temporal constraints for evidential linking to clinical onset or clinical worsening. For example, ocular or periocular exposure to an allergen, irritant or mustard gas, foreign body contact, or conjunctival injury must have occurred within 24 hours before clinical onset or clinical worsening (see subsection 9(5), 9(12), 9(13), 9(14), 9(15), and mirrored provisions for “clinical worsening” in subsections 9(23), 9(30)-9(33)). Topical medication requires application within 48 hours of onset or worsening (subsections 9(9), 9(27)). Specified systemic drugs must have been taken for at least seven days before onset or worsening (subsections 9(10), 9(28)).
• Drug causation rules. The instrument distinguishes a specified list of drugs (the Schedule 1 specified list) which, if taken continuously for at least seven days before onset/worsening, count as a factor (subsections 9(10), 9(28)). Separate provisions address drugs associated in the individual with conjunctivitis where timing and clinical response to withdrawal or rechallenge are relied upon (subsections 9(11), 9(29)).
• Special relationship rules. Section 10(1) requires any factor in section 9 to be related to the person’s relevant service. Section 10(2) limits subsections 9(19)-9(37) to situations where conjunctivitis pre‑existed service or was suffered/contracted before or during service but did not arise out of service; in those circumstances, the factors operate only to establish material contribution or aggravation of conjunctivitis.
• Cross‑SoP application. Section 11 sets the mechanism for cross‑reference: if a factor in this SoP is an injury or disease already covered by another SoP, then the terms of that other SoP apply.

Definitions in Schedule 1 are integral to how those concepts operate. The Schedule defines critical terms such as allergen, infection of the conjunctiva, injury to the conjunctiva, irritant substance, immunocompromised states and the specified lists of drugs and conditions. The 2022 amendment added the definition of “sensitising exposure to an allergen” and inserted subsection 9(5A) to capture sensitisation‑type allergic causation where the initial exposure is asymptomatic but re‑exposure within two weeks triggers clinical disease.

These elements show the instrument is a detailed, medicalised evidentiary map: it converts a clinical picture into a set of discrete, timebound, and definitional nodes that claimants and decision‑makers must traverse to establish service connection on the balance of probabilities.

The instrument affects three clear groups, directly and indirectly, as identified in the text.

1. Claimants seeking entitlements under the VEA or MRCA. Section 5 expressly states the instrument applies to a claim to which section 120B of the VEA or section 339 of the MRCA applies. That group comprises veterans or members of the Forces who assert that their conjunctivitis, or death from conjunctivitis, is connected with their “relevant service” as defined in the Schedule (relevant service means eligible war service, defence service or peacetime service under MRCA). For claimants, the SoP prescribes what medical and exposure facts, on balance, the RMA considers sufficient for a positive nexus.
2. Medical practitioners and experts who provide statements, reports or certificates for claims. The SoP places a premium on evidence that clinical onset or clinical worsening is temporally connected with one or more enumerated factors. Treating clinicians and medico‑legal experts will need to record or opine about the timing of onset or worsening, presence of the specific conditions listed in the Schedule, exposures within defined windows (24 or 48 hours; seven days for systemic drugs), immunocompromised status per the Schedule, and the course of drug therapy and response to withdrawal or rechallenge where drug causation is asserted (section 9; Schedule).
3. Decision‑makers and administrators implementing VEA and MRCA claims. While the instrument does not itself create entitlements, it is the RMA’s medical guidance used by decision‑makers assessing causation under the statutory tests (s 5, s 8). Departments and tribunal members will apply the SoP’s factors, the definitions in Schedule 1, and the relationship rules in section 10 when determining whether, on the balance of probabilities, conjunctivitis is connected with relevant service.

Other affected parties include insurers or third parties involved in care where proof of service connection interacts with other compensation arrangements, though the instrument itself does not engage third‑party liability or offset rules. The SoP’s emphasis on narrow temporal exposures will make older service claims more dependent on contemporaneous clinical records. Factors such as “inability to obtain appropriate clinical management” (subsection 9(37)) bring in non‑clinical evidence , service location, availability of medical care, and contemporaneous reports , into the causation analysis.

The Schedule lists particular drugs and conditions (for example, dupilumab, isotretinoin, chemotherapy for cancer) whose presence affects causation findings. Claimants who were exposed to those specified drugs or who had immunosuppressive therapies or chronic renal failure are the cohort to which those particular evidentiary hooks will be applicable. The 2022 amendment that added the concept of “sensitising exposure to an allergen” widens the set of allergic mechanism claims by recognising sensitisation and delayed re‑exposure as a valid causal pathway, affecting veterans with allergic histories.

Finally, the instrument has indirect administrative cost implications for the Department charged with adjudicating claims. Its detailed, timebound factors create evidentiary tasks: collecting drug histories, exposure histories, records of clinical onset/worsening and documentation of immunocompromised states. The instrument therefore affects the record‑keeping and evidentiary collection responsibilities of providers and claimants.

The Statement of Principles is not a statute of obligations and penalties; instead it creates a framework that imposes practical duties on decision‑makers, claimants and medical advisors through evidentiary requirements, and it clarifies what medical facts will satisfy the RMA’s view of causation on the balance of probabilities.

Rights and entitlements

• Right to have the SoP applied. A person making a claim to which s 120B of the VEA or s 339 of the MRCA applies is entitled to have the RMA’s Statement of Principles considered as the RMA’s relevant medical view when assessing connection between conjunctivitis and relevant service (s 5, s 8). The SoP defines what facts, if established and related to service, will satisfy the medical causal link on the balance of probabilities.
• Right to rely on cross‑referenced SoPs. Where a factor in this SoP refers to another injury or disease that itself has an SoP, the other SoP applies in accordance with its terms as in force from time to time (s 11). This provides a right to consolidated medical standards where conditions overlap.

Practical duties

• Duty to establish at least one factor and relation to service. The core evidentiary duty for claimants is to demonstrate, on the balance of probabilities, that at least one of the factors in section 9 existed and was related to their relevant service (section 9; section 10(1)). The instrument places the burden of proof implicitly on the claimant to adduce sufficient evidence to meet that test.
• Duty to show timing for exposure or treatment. Many factors stipulate precise temporal windows (for example, ocular allergen/irritant exposure within 24 hours before onset or worsening; topical medication within 48 hours; systemic “specified list” drugs for at least seven days). This requires contemporaneous or retrospective evidence that establishes timing of exposures and of clinical onset/worsening (section 9).
• Duty of precise medical description. Claimants and treating clinicians must identify the specific medical conditions named in the Schedule (for example, blepharitis, disorder of nasolacrimal duct or gland, ectropion, keratoconjunctivitis sicca, Sjögren syndrome) where those are relied upon as factors (section 9; Schedule 1).
• Duty to relate factors to relevant service. Even where a listed factor is present, section 10(1) requires that factor to be related to the person’s relevant service. The instrument thereby creates a two‑stage duty: show the factor and then show a link between that factor and relevant service.

Evidence and proof standards

• Balance of probabilities standard. The instrument explicitly frames the RMA’s view on causation as “more probable than not” (s 8). Decision‑makers therefore apply the ordinary civil standard of proof when using this SoP.
• Clinical response evidentiary tests for drug causation. For drugs associated with conjunctivitis in a particular individual, the SoP requires evidence of improvement within seven days of discontinuing or tapering the drug, or redevelopment on rechallenge, where treatment continued for at least seven days before onset (subsection 9(11); analogous subsection 9(29) for worsening). This establishes a clinical response test that will require charted changes and prescribing records.

No enforcement duties in the instrument

• The SoP contains no duties to report, no penalties, and imposes no regulatory obligations on clinicians beyond the evidentiary realities of record‑keeping. It is an evidentiary tool for decisions under the VEA and MRCA, not a stand‑alone regulatory regime.

In summary, the practical “duties” created by the SoP are duties of proof and documentation for claimants and medical advisers, and duties of application for decision‑makers who must apply the SoP’s factors and definitions to decide whether the causal threshold is met.

The instrument itself contains no penalty provisions, criminal sanctions or administrative fines. It is a Statement of Principles made under subsection 196B(3) of the Veterans' Entitlements Act 1986 (s 3) designed to define medical causation requirements used in claims processing. Consequently:

• No direct sanctions. There are no provisions within this document that impose penalties on individuals or organisations for non‑compliance; the instrument functions as an evidentiary framework rather than an enforcement statute.
• Administrative enforcement through claims process. The SoP will be used by administrators applying the VEA and MRCA to determine whether a claimant has shown, on the balance of probabilities, that conjunctivitis or death from conjunctivitis is connected with relevant service (s 5). Enforcement in practice is administrative and adjudicative: an adverse determination that the SoP is not satisfied will result in the claimant not obtaining relevant entitlements under the VEA or MRCA. The document does not itself prescribe appeals or review mechanisms; those are situated in the principal Acts and their review regimes.
• Decision‑maker duties. Tribunals and departmental decision‑makers will apply the SoP as part of the body of evidence when considering connection to service. Any enforcement action is therefore indirect, in the sense that the SoP shapes entitlement decisions which then produce consequences (acceptance of a claim, payment of benefits, or refusal).
• No prosecutorial or compliance roles. The RMA’s role in producing the SoP is to set the medical standard; it does not prosecute or otherwise enforce compliance. The instrument does not create inspection or investigatory powers.
• Evidence thresholds create practical enforcement effects. Though not penalties, the tight temporal windows (for example, exposures within 24 hours, topical medication within 48 hours, systemic drug exposure for seven days) and the requirement for linking factors to relevant service in section 10(1) operate as a practical enforcement mechanism: claims that lack proof of those precise facts will fail to satisfy the SoP and thus may be denied under the applicable statutory claims processes. This gives the SoP indirect sanctioning force through evidentiary exclusion, but that is an administrative outcome rather than a formal penalty.

For claimants, the implication is that failing to produce sufficient contemporaneous clinical records, drug histories, or credible exposure evidence is likely to result in an adverse decision; there is no remedial provision in the SoP itself to relax evidentiary time windows. For decision‑makers, the SoP offers a clear standard to apply but requires accurate application of the definitions in Schedule 1 and proper assessment of whether a factor was related to relevant service (s 10(1)). Any disputes over application will be resolved through the statutory appeal and review mechanisms of the VEA and MRCA; this instrument does not modify or specify those processes.

The Statement of Principles is a subordinate instrument produced under the Veterans' Entitlements Act framework and operates within the statutory architecture of veteran entitlements and compensation. The instrument supplies the RMA’s medical view for application under the principal Acts. Key interactions, as stated in the text, are as follows.

Primary statutory linkages

• Authority and purpose. The instrument is made under subsection 196B(3) of the VEA (s 3). This situates the SoP as an RMA product intended to inform decisions under the VEA and MRCA.
• Applicability to claims. Section 5 states the instrument applies to a claim to which section 120B of the VEA or section 339 of the MRCA applies. Those sections in the principal Acts establish the statutory tests for connection between injury/disease and service; the SoP therefore functions as an evidentiary matrix for those statutory provisions. The SoP does not replace or amend the statutory tests; it provides the RMA’s view of what meets the medical requirement under those statutory standards.

Interplay with other SoPs

• Cross‑referencing other Statements of Principles. Section 11 provides a mechanism for interaction with other RMA SoPs: if a factor in section 9 refers to an injury or disease already covered by another SoP determined under subsection 196B(3) of the VEA, then the factors in that other SoP apply according to its terms as in force from time to time. This creates an integrated universe of SoPs where overlapping or referenced conditions defer to their own authoritative texts. Practically, this requires decision‑makers to consult multiple SoPs when a factor straddles conditions.

Administrative and classification law implications

• Use of ICD‑10‑AM codes. Subsections 7(3)-(4) tie the SoP’s definition of conjunctivitis to ICD‑10‑AM codes H10, H13.1, H13.2 or H16.2 in The International Statistical Classification of Diseases and Related Health Problems, Tenth Revision, Australian Modification (ICD‑10‑AM), Tenth Edition, effective 1 July 2017. This locks the SoP’s administrative identification of the condition to a specific edition and copyrighted source. Decision‑makers, clinicians and coders must therefore align coding and diagnostic labels to the edition specified in the instrument when applying it.
• Evidence standard within statutory processes. The SoP frames causation on the balance of probabilities (s 8). That evidentiary standard is the civil standard used in VEA/MRCA proceedings; the SoP’s factors are therefore applied within those legal processes rather than in isolation.

No changes to benefit entitlements or appeal mechanisms

• The SoP does not itself create, modify or limit rights of appeal, review jurisdictions, or the terms of monetary entitlements under the VEA or MRCA. It is a medical standard applied by decision‑makers under those Acts. Any change to appeal routes, offsets, or payment rates would need to be effected by amendment to the principal Acts or their subordinate instruments; the SoP does not purport to do so.

Copyright and external instrument dependence

• The instrument expressly references a copyrighted external standard, the ICD‑10‑AM Tenth Edition (subsection 7(4)). This creates a legal dependence on an external classification product for administrative identification of the condition. Any later changes to ICD‑10‑AM coding would not be reflected in this SoP unless the RMA or the instrument is amended; the endnotes record amendment history but the SoP text remains tied to the edition specified.

In sum, the SoP interacts with the VEA and MRCA as the RMA’s medical input into statutory causation assessments. It requires claimants and decision‑makers to align diagnostic coding to a specified ICD edition and to consult other SoPs where factors overlap. The instrument does not alter statutory remedies, appeals or benefit structures; it is an input to those existing statutory mechanisms.

The instrument includes an explicit amendment history in the endnotes and the front matter. The compilation is dated 19 September 2022 and includes amendments up to Amendment Statement of Principles concerning conjunctivitis (Balance of Probabilities) (No. 91 of 2022) (F2022L01131), with that amendment’s day of commencement recorded as 19 September 2022.

Key entries in the endnotes show:

• Original registration and commencement. Statement of Principles concerning conjunctivitis (Balance of Probabilities) (No. 77 of 2020) was registered 3 November 2020 (F2020L01397) and commenced 30 November 2020, as set out in the legislation history (Endnote 3).
• Amendment No. 91 of 2022. Amendment Statement of Principles concerning conjunctivitis (Balance of Probabilities) (No. 91 of 2022) was registered 29 August 2022 (F2022L01131) and commenced 19 September 2022 (Endnote 3). The amendment specifically added subsection 9(5A) and the definition of “sensitising exposure to an allergen” to Schedule 1, as recorded in the amendment history table (Endnote 4). The amendment therefore recognises a sensitisation mechanism for allergic conjunctivitis claims, explicitly allowing an initial asymptomatic exposure to be relevant to a later symptomatic exposure within two weeks.
• Other annotated changes. The amendment history table in the endnotes also records that Section 2 was repealed by Legislative Instruments Act provisions (rep LA s 48D) and Section 4 was repealed (rep LA s 48C). Those notations reflect technical legislative housekeeping annotated in the compilation but do not affect the operative sections provided in the instrument text as compiled. The endnotes explain the role of the compilation and modifications that might not be shown in the compiled text.
• Compilation details. The front matter explains this document is a compilation that reflects amendments in force on the compilation date (19 September 2022) and explains that uncommenced amendments are not shown in the text and are underlined in endnotes where relevant.

Operational effect of the amendment

• The substantive operational change effected by No. 91 of 2022 was the insertion of subsection 9(5A) and the Schedule definition of “sensitising exposure to an allergen”. This modifies the scope of allergic causation recognised by the SoP by creating a pathway where an earlier asymptomatic exposure can be treated as a valid sensitising event if subsequent re‑exposure within two weeks produces clinical onset. The Schedule’s note clarifies the initial sensitising exposure may have been systemic or cutaneous and may have occurred months to years earlier, while the symptomatic event must occur within two weeks of re‑exposure. The amendment therefore introduces a temporally structured allergic mechanism that decision‑makers must now consider.
• The endnotes explain that misdescribed amendments are annotated where relevant; none of the amendments to the substantive criteria are presented as misdescribed in the endnotes.

For practitioners, the key historical points are that the SoP took effect in late 2020 and was updated in 2022 to broaden allergic mechanisms. The instrument’s compilation and endnotes are the authoritative sources for tracing those changes; any further amendments would be recorded in later compilations or on the Legislation Register.

The compiled instrument contains no references to judicial decisions, appeals or case law within its text. The instrument is an RMA‑issued Statement of Principles and the text does not name any cases or litigation outcomes. The endnotes provide only legislative amendment history and an abbreviation key; they do not list any litigation or tribunal decisions.

Practical implications of the absence of litigation references

• No embedded precedents. Because the SoP text contains no case law citations, users should be aware that application and interpretation of the SoP may generate litigation or tribunal decisions outside the instrument. Those decisions, if they exist, would be found in administrative decision records, tribunal or court databases and are not recorded in the instrument itself.
• Administrative review and tribunal routes remain external. The SoP supplies medical criteria; disputes over its application or over whether evidence satisfies its factors will be resolved within the normal VEA or MRCA statutory review and appeal processes. The instrument does not record outcomes of such proceedings.
• Need for case law search outside the instrument. For practitioners seeking to understand how tribunals or courts have applied this specific SoP in practice, or how section 10(2) limitations have been interpreted, a jurisdictional case search of VEA/MRCA decisions and tribunal determinations will be required because the instrument’s text is silent on litigation history.

In short, there is no litigation history within the compiled instrument. Any jurisprudence interpreting or applying this Statement of Principles must be sought and cited from external decision reports and is not supplied in this instrument.

This SoP contains several technical features that commonly trip up claimants, clinicians and decision‑makers. These are practical pitfalls that arise from the instrument’s structure, definitions and temporal requirements.

1. Narrow temporal windows for exposure‑based factors. Many exposure factors require proof of an event within very short windows: 24 hours for ocular/periocular allergen exposure, irritant exposure, mustard gas exposure, foreign body contact and conjunctival injury; 48 hours for topical medication application; at least seven days of systemic specified drug therapy prior to onset or worsening (section 9). For historical claims, and particularly for claims concerning service some years earlier, establishing these narrow windows is materially difficult without contemporaneous clinical entries or service records that note exposures and timing.
2. “Clinical onset” and “clinical worsening” are used but not defined. The SoP repeatedly uses the terms “clinical onset” and “clinical worsening” as temporal markers (section 9), but the instrument does not define them in Schedule 1. That leaves decision‑makers requiring either clinical interpretation or reliance on treating clinicians to fix the onset time. The lack of a statutory or dictionary definition creates uncertainty and litigation risk around how precise the timing must be, how onset is ascertained retrospectively, and what documentary or testimonial evidence suffices.
3. Relationship to “relevant service” requirement. Section 10(1) mandates that any factor in section 9 must be related to the relevant service. It is not sufficient to show a listed factor exists; claimants must exhibit a link between the factor and service. The SoP does not prescribe how that relationship is to be established; this will depend on medical and factual evidence. For example, proving that an infection present at the time of service was acquired in service locations or that a drug exposure occurred during service requires corroborative records.
4. Limits on material contribution/aggravation for pre‑existing conditions. Subsection 10(2) restricts subsections 9(19)-9(37) to situations where conjunctivitis was suffered or contracted before or during service but did not arise out of service; those factors then apply only to material contribution or aggravation. This is a nuanced rule: if the person’s conjunctivitis arose out of service, those subsections will not apply to establish material contribution or aggravation. Practically, claimants and advisers must map the timing of initial disease onset relative to service precisely to determine which subsections operate.
5. Drug causation tests require clinical response evidence. For systemic drugs not on the specified list but claimed to be causative in an individual, the SoP requires evidence of improvement within seven days of discontinuation or redevelopment on rechallenge, with the drug having been used for at least seven days prior to onset (subsection 9(11)). Where rechallenge is not ethically or practically possible, the absence of documented improvement on withdrawal may be decisive. The SoP therefore tilts causation findings in favour of claims with well‑documented prescribing changes and clinical responses.
6. “Inability to obtain appropriate clinical management” is a listed factor. Subsection 9(37) treats lack of access to appropriate care as a factor, which brings non‑clinical evidence such as service location, availability of medical facilities, and contemporaneous reports into play. The SoP does not specify standards for what constitutes “appropriate” management, leaving a gap that decision‑makers must resolve on a case‑by‑case basis.
7. ICD‑10‑AM edition locking. The SoP ties the diagnostic codes to the ICD‑10‑AM Tenth Edition effective 1 July 2017 (subsections 7(3)-(4)). If coding practice changes or later editions alter codes or mappings, practitioners must be attentive to the edition named in the SoP; maps to later codes will require amendment of the SoP or interpretative work.
8. Definition reliance and specificity. Several terms that matter for causation are defined narrowly in Schedule 1: “infection of the conjunctiva” (bacterial, viral, rickettsial, parasitic or fungal), “injury to the conjunctiva” (includes thermal, electrical and chemical burns and blunt or penetrating trauma), “immunocompromised state as specified” (lists examples such as chemotherapy, chronic renal failure, HIV infection). Claimants relying on a condition not specifically captured by these definitions may fail to satisfy the specific wording of the SoP even if a clinician deems the condition contributory.
9. Sensitising exposure rule complexity. The 2022 amendment added subsection 9(5A) and a Schedule definition that a “sensitising exposure to an allergen” can be asymptomatic and may have occurred months to years earlier, provided the symptomatic event occurs within two weeks of re‑exposure. The two‑week re‑exposure window is strict, but the instrument also allows for initial sensitising exposures that are remote. This interplay is conceptually complex and may be misapplied if the timing of initial exposures or re‑exposures is not clearly recorded.
10. No penalties but real administrative consequence. Although no penalties are imposed by the instrument, failure to meet the SoP’s factors effectively prevents a finding of service connection under the VEA/MRCA process and therefore precludes entitlement. That makes the SoP a gatekeeping instrument in practice.

These “gotchas” mean that precise record‑keeping, careful use of the Schedule definitions, and well‑documented timelines are essential. Medical statements that fail to address the temporal and definitional specifics required by the SoP are at risk of being disregarded as insufficient to meet the RMA’s criteria.

Compliance with the Statement of Principles is not a statutory reporting obligation but a practical requirement for claimants, treating clinicians and advisers aiming to establish service connection under the VEA or MRCA. The SoP prescribes what must be proven on the balance of probabilities. The following operational checklist maps the SoP’s requirements into actionable steps and evidentiary priorities.

For claimants and advocates

1. Identify the relevant SoP factors you will rely upon. Read section 9 and the Schedule 1 definitions carefully to determine which listed factor(s) apply to the claimant’s clinical history: blepharitis, conjunctival infection, specified list of conditions (nasolacrimal duct disorder, ectropion, exophthalmos, lid retraction), chronic dry eye conditions, allergy/irritant exposure, systemic or topical drugs, immunocompromised state, radiation exposure, foreign body or trauma, or inability to obtain appropriate management (section 9; Schedule 1).
2. Establish timing of clinical onset and worsening. The SoP requires timing tied to “clinical onset” and “clinical worsening” for many factors (section 9). Obtain treating records, contemporaneous reports, unit medical logs, incident reports and witness statements that place the onset/worsening in time. Where onset/worsening is not recorded contemporaneously, collect corroborating accounts and clinical notes that reconstruct timing.
3. Document exposures within the SoP’s temporal windows. For exposure factors requiring evidence within 24 or 48 hours, seek contemporaneous service incident reports, occupational exposure logs, pharmacy dispensing records, or clinician notes documenting exposure. For systemic drugs on the specified list, secure prescription and dispensing records demonstrating at least seven days’ continuous therapy before onset/worsening (subsections 9(10), 9(28); Schedule list).
4. For drug‑related claims, document clinical response to withdrawal or rechallenge. If the claim relies on an individual drug‑association (subsections 9(11), 9(29)), obtain records showing improvement within seven days of stopping or tapering the drug, or documentation of redevelopment on rechallenge. Where rechallenge is not feasible, detailed clinical notes of expected recovery timelines and alternative explanations will be important.
5. For allergic/sensitising claims, document exposure history. Use the 2022 sensitising exposure rule (subsection 9(5A) and Schedule definition) to establish initial sensitising exposure and a re‑exposure within two weeks of symptomatic onset; record both systemic/cutaneous exposure history and timing of re‑exposure.
6. For immunocompromised or comorbidity factors, secure diagnostic and treatment records. Schedule 1 sets out what constitutes an “immunocompromised state as specified” (for example, immunosuppressive drug use, malignancy, chronic renal failure, HIV, severe malnutrition, transplantation). Provide diagnostic lab results, treatment regimes, dialysis records, chemotherapy logs and pathology reports as applicable.

For treating clinicians and experts

1. Use SoP language in reports. Address the SoP factors specifically. State whether the patient had blepharitis, infection of the conjunctiva, one of the specified list conditions, signs of chronic lubrication deficiency, documented exposure events, specific drug exposures and their duration, and whether the patient was immunocompromised as defined (section 9; Schedule 1).
2. Anchor opinions to clinical onset/worsening timing. Provide a clear clinical timeframe for onset and any subsequent worsening. If the timing is uncertain, explain the basis for any retrospective determination and the degree of certainty.
3. For drug causation, document temporal relationship and response. Indicate when the drug was started, duration of use, any cessation or tapering and the clinical response within the seven‑day window, or note outcomes of rechallenge where applicable (subsections 9(11), 9(29)).
4. Where cross‑SoP conditions are raised, cite the other SoP. If a factor refers to a condition covered by another Statement of Principles, include diagnosis and opinion about that other condition and reference the relevant SoP, as section 11 requires the other SoP’s factors to apply according to its terms.

For decision‑makers and administrators

1. Confirm SoP applicability to the claim. Ensure the claim is one to which section 120B VEA or section 339 MRCA applies and apply the SoP as the RMA’s medical guidance (s 5, s 8).
2. Apply the two‑part test. First determine whether at least one factor in section 9 is established on the balance of probabilities. Second determine whether that factor is related to the person’s relevant service (section 10(1)). If subsections 9(19)-9(37) are relied upon, confirm the conjunctivitis was suffered or contracted before or during service but did not arise out of service so that the material contribution/aggravation rule in section 10(2) applies.
3. Use the Schedule definitions precisely. Where claims hinge on defined terms such as “infection of the conjunctiva”, “injury to the conjunctiva”, “immunocompromised state as specified” or the “specified list of drugs”, apply the dictionary meanings set out in Schedule 1.
4. Where factors cross other SoPs, consult those documents. Apply section 11 by reading across to the other SoP terms where a factor references another injury or disease with its own SoP.
5. Be mindful of coding edition. When verifying diagnostic codes, align them to the ICD‑10‑AM Tenth Edition effective 1 July 2017 as specified in subsections 7(3)-(4); do not substitute later editions without an amendment to the SoP.

Practical record‑keeping and evidence gathering tips

• Pharmacy and prescribing records are often decisive for drug‑related factors. Seek unit pharmacy logs, civilian dispensing records, and hospital charts.
• Incident and occupational exposure reports help establish 24‑hour exposure windows.
• Where “inability to obtain appropriate clinical management” is asserted, gather service logs, referral denials, evacuation reports or contemporaneous complaint records to demonstrate lack of access.
• For immunocompromise and chronic conditions, produce laboratory data, treatment regimens and specialist reports that align with Schedule 1 definitions (for example, dialysis records for chronic renal failure, oncology treatment plans for malignancy).

In short, compliance is achieved by mapping the claimant’s medical and exposure history to the precise phrasing and definitions of the SoP, documenting timeframes carefully, and, where necessary, layering cross‑SoP references. The SoP is a rules‑based toolkit; success depends on meeting its discrete factual and temporal conditions as established in the instrument.