Statement of Principles concerning Dupuytren disease (Reasonable Hypothesis) (No. 9 of 2019)

The SoP’s operative concepts are: the defined clinical entity, the “reasonable hypothesis” evidentiary threshold, enumerated factors linking disease to service, timing and causation distinctions, and cross‑reference to other SoPs. Dupuytren disease is defined clinically rather than by diagnostic code, although ICD‑10‑AM coding is acknowledged; the statutory definition is controlling (s7(2)-(4)). Death is covered when a terminal event or condition was contributed to by Dupuytren disease (s7(5) and Schedule 1 definition of terminal event).

The evidentiary function is explicit: “At least one of the following factors must as a minimum exist before it can be said that a reasonable hypothesis has been raised connecting Dupuytren disease or death from Dupuytren disease with the circumstances of a person’s relevant service” (s9). That establishes a binary threshold rule: a single listed factor, properly evidenced and tied to relevant service, satisfies the SoP’s minimum requirement for a reasonable hypothesis.

The factors themselves fall into categories:

• behavioural exposures: smoking expressed in pack‑years with commencement and cessation windows (s9(1), s9(14)); alcohol consumption quantified as at least 200 grams per week for specified durations (s9(2), s9(15)); alcohol use disorder (s9(3), s9(16));
• medical comorbidity or treatment: diabetes mellitus (s9(9), s9(22)), epilepsy (s9(10), s9(23)), psoriasis involving the palm (s9(11), s9(24)), cirrhosis or steatohepatitis (s9(4), s9(17)), vemurafenib treatment within two years (s9(12), s9(25)), high‑dose phenobarbital for epilepsy with duration and cessation windows (s9(13), s9(26));
• local triggers to the affected limb: trauma to hand/wrist/forearm within one year (s9(5), s9(18)), clinically significant palmar infection within three months (s9(6), s9(19));
• occupational/physical exposures: cumulative 10 000 hours of repetitive, strenuous or forceful hand activity, or hand‑held vibrating/percussive tool use, with a five‑year cessation window (s9(8), s9(21));
• bilaterality rules that require a specific temporal sequence for trauma or infection leading to bilateral disease (s9(7), s9(20));
• access to care: inability to obtain appropriate clinical management (s9(27)).

Definitions in Schedule 1 operationalise several terms that are critical to application: “pack‑years” is carefully quantified (tailor‑made cigarettes equal to 20 per day for a year equals 1 pack‑year; one cigarette approximates one gram of tobacco; one pack‑year equals 7 300 cigarettes or 7.3 kilograms of smoking tobacco by weight) (Schedule 1). “Trauma” is defined as a significant injury with symptoms and signs lasting at least seven days or of sufficient severity to warrant medical attention (Schedule 1). “Clinically significant infection” is exemplified by flexor tenosynovitis or a palmar abscess (Schedule 1). “Relevant service” is listed as the service categories under the VEA and MRCA (Schedule 1).

Finally, the SoP connects to other Statements of Principles: where a listed factor refers to an injury or disease for which another SoP has been determined, then that other SoP’s factors apply as in force (s11). That creates a cross‑referencing mechanism for composite causal chains, and requires decision-makers to consult the applicable SoP for secondary conditions referenced in this instrument.

Primary subjects are claimants to the Department of Veterans’ Affairs seeking connection between Dupuytren disease (or death from it) and their relevant service under the VEA or MRCA (s5). The categories of “relevant service” are explicitly listed in Schedule 1 as operational, peacekeeping, hazardous, British nuclear test defence service under the VEA, and warlike or non‑warlike service under the MRCA. Thus, current and former members of the Australian Defence Force who rendered those types of service, plus members of Peacekeeping Forces as referenced in s8, are the population to whom this SoP applies (s8, Schedule 1).

Secondary affected actors include the Repatriation Medical Authority, which made the SoP under statutory authority (s3); the Department of Veterans’ Affairs and other decision-makers who apply the reasonable hypothesis test under the VEA and MRCA instruments cited in s5; treating clinicians and medical experts whose records and opinions will be marshalled to establish factors listed in s9; and advisers such as lawyers, occupational physicians and rehabilitation providers assisting claimants to document exposures and diagnoses.

Who pays and who decides. The instrument does not create or alter benefit quantum or payment mechanisms; rather it provides an evidentiary rule used by decision-makers to determine whether a claim should proceed on the basis of a reasonable hypothesis. The decision-maker charged with adjudicating a particular claim under the VEA or MRCA will determine entitlement on the statutory frameworks of those Acts, applying this SoP to assess whether a reasonable hypothesis exists (s5). The Repatriation Medical Authority is the body making the SoP, not the payer. The Department of Veterans’ Affairs and MRCA decision-makers are the practical decision-makers using the SoP.

Practical impacts on individuals include the evidentiary requirements that must be met to satisfy the SoP’s minimum threshold. Claimants must produce, or enable the decision-maker to obtain, evidence supporting at least one factor in s9 that is related to their relevant service (s10(1)). Where the condition pre‑existed or was suffered during, but did not arise out of, service, a different subset of factors (s9(14)-(27)) apply and only for material contribution or aggravation (s10(2)). Clinical and occupational records, treatment histories, medication records (for vemurafenib or phenobarbital), trauma and infection documentation, and quantified smoking and alcohol histories are all potential evidentiary needs since the SoP lists precise thresholds and temporal windows.

Other actors with indirect but potential interest include insurers and employers when events involve occupational exposures overlapping with service, medical specialists who may be requested to assess onset/worsening dates and linkages, and coroners or mortality reviewers when death from a terminal event is alleged to have been contributed to by Dupuytren disease (s7(5) and Schedule 1 terminal event).

The instrument itself imposes no duties on private parties in the sense of criminal or civil obligations. Its operative effect is to structure how statutory decision-makers determine whether a reasonable hypothesis exists linking Dupuytren disease or death from it to relevant service (s9). Key legal duties and rights therefore arise in the claims context, as follows.

Claimant rights. A claimant seeking entitlements under the VEA or MRCA has the right to have their claim assessed against the criteria set out in this SoP where the claim concerns Dupuytren disease or death from it (s5). If the claimant can establish at least one of the listed factors, and that factor is related to relevant service (s10(1)), the decision-maker is required to treat that as the minimum for a reasonable hypothesis to be raised, subject to the statutory test and procedural rules in the VEA and MRCA.

Decision-maker obligations. Decision-makers must apply the SoP when assessing whether a reasonable hypothesis has been raised. The SoP defines the minimum factual basis: at least one factor listed in s9 must be present. Decision-makers will therefore examine evidence against the precise criteria and temporal requirements in s9 and the definitions in Schedule 1. They must also observe the relationship to service requirement in s10(1), and the limitation in s10(2) that subsections 9(14)-9(27) are relevant only where the disease was suffered or contracted before or during, but did not arise out of, service, and where material contribution or aggravation is claimed.

Evidentiary standard. The SoP sets out the factual matters that establish a reasonable hypothesis, not a conclusive presumptive causation. The phrase “reasonable hypothesis” is used in the VEA and MRCA frameworks to mark a particular threshold for proceeding with an entitlement claim. This instrument specifies the factors that satisfy the minimum requirement. It does not itself determine final causation or entitlement; that is for the adjudicative process under the VEA/MRCA.

Interplay with other SoPs. Where a factor in s9 refers to an injury or disease that is the subject of another SoP, the factors in that other SoP apply in accordance with its terms (s11). This creates an obligation on decision-makers to consult and apply cross‑referenced SoPs where a listed factor invokes another condition.

Documentation expectations. By specifying precise thresholds and windows, the SoP creates a de facto duty on claimants and their advisers to provide documentary evidence for dates of onset, cessation and exposure quantities, medication dosages and durations, and records of trauma or infection. For example, smoking must be evidenced as at least ten pack‑years, with commencement at least five years prior to clinical onset and specified cessation windows (s9(1), s9(14)). Phenobarbital exposure requires evidence of average daily dosing of at least 100 milligrams for two continuous years before onset, with a one‑year cessation window (s9(13), s9(26)). The SoP therefore converts clinical and exposure details into legal thresholds that must be met to raise the reasonable hypothesis.

Limitations. The SoP does not create rights to compensation by itself. It operates within the rights and duties established by the VEA and MRCA and is intended to be a medical/technical instrument aiding the statutory decision-making process (s3, s5, s8).

This instrument contains no penal sanctions, fines or criminal offences. It is a medical‑evidentiary instrument intended to guide administrative determinations under the statutory frameworks of the VEA and MRCA (s3, s5). There is no enforcement mechanism stated in the SoP itself; rather, enforcement and sanctioning, if any, would rest with the decision-making and appeal mechanisms provided by the VEA, MRCA and related administrative review processes, which are outside the text of this instrument.

Operational enforcement is therefore administrative and evidentiary. Decision-makers will enforce the SoP’s thresholds by accepting or rejecting that a reasonable hypothesis has been raised in a particular claim. Where a claimant cannot establish at least one of the s9 factors, the SoP provides a basis for rejecting that the reasonable hypothesis threshold has been met. Conversely, where a factor is proven and related to relevant service, the decision-maker must treat that as meeting the SoP’s minimum requirement for a reasonable hypothesis to be raised (s9). Any further enforcement actions, including entitlement grants, refusals, or litigation, are conducted under the VEA or MRCA procedural and merits review frameworks, which are not set out in this instrument.

There is no express penalty for false statements or fraudulent claims in the SoP. Claims made to the Department of Veterans’ Affairs continue to be subject to the general statutory and administrative controls applicable to those Acts. The SoP neither modifies those controls nor augments them with separate penalties.

Because the SoP cross‑refers to other Statements of Principles where relevant (s11), enforcement in relation to a listed factor that is itself an injury or disease covered elsewhere will also be shaped by how decision-makers apply that other SoP. The SoP’s role is confined to clarifying what factual matters will, as a minimum, raise a reasonable hypothesis for Dupuytren disease and death from it.

Finally, the SoP includes no inspectorate, auditing regime or reporting obligations. Its implementation depends on administrative adherence by the Repatriation Medical Authority in producing the instrument and by decision-makers in applying it to claims under the VEA and MRCA.

This Statement of Principles is made under subsection 196B(2) of the VEA and explicitly applies to claims to which section 120A of the VEA or section 338 of the MRCA applies (s3, s5). It therefore functions as a medical/evidentiary instrument within the statutory entitlements regime established by those Acts. The SoP does not amend substantive provisions of the VEA or MRCA, nor does it alter other statutory processes; it provides the medical thresholds decision-makers under those Acts should use when applying the statutory “reasonable hypothesis” test.

Cross-references to other SoPs are expressly accommodated. If a factor in s9 refers to an injury or disease covered by another Statement of Principles made under subsection 196B(2) of the VEA, then the factors in that other Statement apply according to its terms as in force from time to time (s11). This creates an interaction where a chain of causal inference may require decision-makers to consult multiple SoPs and apply them in combination. The statutory scheme thus allows an interconnected body of SoPs to be used as the evidentiary map for complex causation scenarios.

The instrument cites ICD‑10‑AM code M72.0 for Dupuytren disease but clarifies that for the purposes of the SoP the statutory textual definition in s7(2) is controlling (s7(3)-(4)). That reduces the risk of technical coding rules displacing the clinical description, while still acknowledging the international coding system. Decision-makers applying the SoP may therefore rely on clinical descriptions and codes, but must prefer the instrument’s textual definition over code labels where there is any discordance.

The SoP interacts with clinical practice and pharmaceutical regulation to the extent it identifies specific drugs and dosages. It lists vemurafenib treatment within two years before onset/worsening (s9(12), s9(25)) and phenobarbital exposure at or above 100 milligrams per day for epilepsy for at least two continuous years, with a one-year cessation rule (s9(13), s9(26)). These references may require decision‑makers to consider prescription records, clinical indications and timelines; they also link the SoP to the medical and pharmaceutical recordkeeping regimes that exist under general health regulation, though no direct statutory modification of those regimes is made.

There is an implicit interaction with occupational health and safety and workers’ compensation regimes where an exposure such as repetitive forceful activities or vibrating tool use is both service‑related and potentially occupational in a civilian context (s9(8), s9(21)). The SoP does not displace or harmonise with workers’ compensation laws; it simply provides a pathway for service members’ claims under the VEA/MRCA. Any double‑claiming or offsetting between regimes would be governed by the statutory rules of those other regimes, not by this SoP.

Finally, the SoP’s definitions and thresholds will influence evidentiary practice in appeals and review proceedings under the VEA and MRCA. Where the SoP cross‑refers to other SoPs, interaction requires up-to-date application of those instruments “as in force from time to time” (s11), creating a live legal ecosystem where multiple statutory instruments may be in play.

This instrument is titled “Statement of Principles concerning Dupuytren disease (Reasonable Hypothesis) (No. 9 of 2019)” and was dated 21 December 2018 with commencement on 28 January 2019 (s1, s2). It repeals the earlier Statement of Principles concerning Dupuytren’s disease No. 57 of 2010 (Federal Register of Legislation No. F2010L01676) that was previously made under subsection 196B(2) of the VEA (s4). No other amendments, revisions or incremental changes are recorded in the text of this instrument.

The repeal clause (s4) is explicit: the 2010 SoP is repealed by this instrument. The text does not set out transitional arrangements in express terms, nor does it include savings provisions for claims in process at the time of commencement; it simply states the 2010 instrument is repealed. The practical implication is that from 28 January 2019 the 2019 SoP is the operative Statement of Principles for new claims and for ongoing determination processes that must be decided under the instrument in force at that time, subject to the procedural rules of the VEA and MRCA.

There is no amendment chronology recorded within this text beyond the repeal of the 2010 instrument and the date of making and commencement. The instrument’s s11 envisages that factors may refer to other SoPs “as in force from time to time,” which means the SoP is intended to operate in a regulatory environment where other SoPs may be amended independently. The instrument itself does not contain an amendment power; it is made by the Repatriation Medical Authority under the statutory power in subsection 196B(2) of the VEA (s3).

Users relying on this SoP should therefore confirm whether later versions or superseding SoPs have been issued after the commencement date. The instrument as supplied records only its making, commencement and repeal of the earlier SoP. No history of prior amendments to this instrument is set out in the text provided.

The instrument contains no reference to any case law, judicial decisions or litigation concerning either the 2019 SoP or the prior 2010 instrument. It does not cite or summarise any tribunal or court decisions. The text confines itself to the medical definitions, factors and statutory basis for the SoP (s3, s7, s8, s9). Consequently, there is no litigation history recited within the instrument itself.

Practitioners should therefore be aware that any litigation history relevant to application of this SoP will need to be sourced from external materials: decisions of the Veterans' Review Board, the Administrative Appeals Tribunal, the Federal Court, or other tribunals and courts that have considered how the reasonable hypothesis test and SoPs operate in practice. Those materials are not part of the instrument’s text and are not summarised here.

The SoP does include internal cross‑referencing to other Statements of Principles and the underlying statutory framework of the VEA and MRCA (s5, s11, Schedule 1 definitions of VEA and MRCA), but it does not record prior administrative or judicial interpretations. Where s9 factors refer to injuries or diseases covered by other SoPs, litigation or tribunal decisions concerning those other SoPs could be relevant in practice, but are not documented in this instrument.

Because the instrument is an administrative medical instrument, dispute about its application would normally arise in statutory review and appeal channels contained in the VEA and MRCA, or in judicial review proceedings. The SoP itself does not provide any commentary about how courts or tribunals have treated its predecessors or similar instruments.

Several technical and evidentiary points in this SoP can surprise claimants and advisers unless specifically attended to.

1. Single‑factor minimum rule. The SoP requires that at least one of the listed factors exist to raise a reasonable hypothesis (s9). That is a low numerical threshold, but the listed factors often contain precise quantitative or temporal criteria that can be difficult to prove. A single factor satisfying the numerical threshold should be sufficient for the reasonable hypothesis test, but the factual proof must match the instrument’s precise formulations.

2. Textual definition controls over ICD code. Although Dupuytren disease is associated with ICD‑10‑AM code M72.0, the instrument makes clear that the statutory meaning is the textual clinical definition in s7(2) (s7(3)). Practically, an ICD code alone will not displace the need to show the clinical features described.

3. Temporal windows and commencement rules. Many factors require precise timing: smoking must have commenced at least five years before clinical onset and cessation within five years of onset if smoking has ceased (s9(1)). Alcohol thresholds require specified averages and durations before onset (s9(2)). Phenobarbital exposure requires continuous high dosing for two years before onset and cessation within one year for the factor to apply post‑cessation (s9(13)). Vemurafenib exposure is limited to within two years before onset/worsening (s9(12), s9(25)). Failure to document exact dates can be fatal to proof.

4. Pack‑year and alcohol quantification. The Schedule 1 definition of pack‑years converts smoking to grams and kilograms of tobacco, and counts 20 tailor‑made cigarettes per day for one year as one pack‑year (Schedule 1). Alcohol consumption is calculated using the Australian Standard of ten grams of alcohol per standard drink (s9 notes). Claims relying on self‑reported consumption should carefully map reported drinks to grams to meet the thresholds.

5. Cessation windows. Several factors contain explicit windows after cessation within which onset or worsening must have occurred. For example, smoking cessation must be within five years of clinical onset/worsening for that factor to apply post‑cessation (s9(1), s9(14)); activities or tool use must have ceased within five years of clinical onset/worsening (s9(8), s9(21)); phenobarbital cessation windows are one year (s9(13), s9(26)). Documentation of cessation dates is therefore as important as documentation of exposure dates.

6. Bilateral rules are sequenced and strict. For bilateral Dupuytren disease, trauma or infection factors require that Dupuytren disease first developed or first worsened on the side affected by the trauma/infection and then developed/worsened in both hands within the one‑year or three‑month windows respectively (s9(7), s9(20)). Proof must show the side‑sequence and timing, not just presence of trauma on either side.

7. Cumulative hourly threshold for physical work. The instrument requires a cumulative 10 000 hours of repetitive, strenuous or forceful activity, or hand‑held vibrating/percussive tool use, before onset or worsening (s9(8), s9(21)). That threshold requires occupational histories, task descriptions, and cumulative hour calculations. The SoP provides examples but does not specify how to compute hours from intermittent duties, so expert evidence may be needed.

8. “Clinically significant infection” and “trauma” are partially defined but retain clinical judgement. Schedule 1 gives examples of clinically significant infection and defines trauma by symptom duration or severity warranting medical attention. Decision-makers will still need to decide whether a specific record satisfies these definitions.

9. Relationship to service and aggravation limits. The factors in subsections 9(14)-9(27) apply only in claims of material contribution to, or aggravation of, Dupuytren disease where the disease was suffered or contracted before or during, but did not arise out of, service (s10(2)). That means those factors do not generally apply to new disease that first arose out of service. Advisers must evaluate whether the claimant’s medical history puts their case within the before/during but not arose out of category.

10. Access to care factor is open‑ended. Factor 9(27), “inability to obtain appropriate clinical management,” is potentially broad and may be difficult to quantify or prove. The instrument provides no further definition or temporal parameters. Expect case-by-case clinical assessment and potential contest over what constitutes “appropriate” and whether inability to obtain it caused onset or worsening.

11. Cross‑reference to other SoPs. When a factor refers to another injury or disease subject to its own SoP, that other SoP applies as in force (s11). This can add complexity where a listed factor invokes a chain of conditions requiring consultation of multiple SoPs and their respective thresholds.

12. No penalty or procedural detail in the SoP itself. The SoP sets medical thresholds but contains none of the procedural or appeals mechanisms that govern the operation of VEA or MRCA claims. Practitioners must align evidential strategy with the procedural rules of those Acts, not with anything further stated in this instrument.

For claimants, legal representatives and medical advisers, practical compliance means structuring evidence to match the SoP’s precise criteria and temporal requirements. Key steps are:

1. Establish the clinical diagnosis and dates. Obtain treating records, specialist reports and surgical notes that document the clinical characteristics defined in s7(2): fibroproliferative disease of palmar/digital fascia with nodules, cords, palmar skin puckering and any flexion contractures. Record the clinical onset date and, if relevant, dates of clinical worsening. For death claims, obtain cause of death records linking terminal events to Dupuytren disease where applicable (s7(5), Schedule 1 terminal event).

2. Quantify smoking exposure to pack‑years per Schedule 1. Collect contemporaneous medical notes, smoking histories, enlistment health records, general practice notes and any cessation treatment records. Convert cigarettes, pipe or cigar tobacco into the pack‑year metric provided in Schedule 1 (one pack‑year = 20 tailor‑made cigarettes per day for one year = 7 300 cigarettes = 7.3 kg of smoking tobacco). Establish commencement date (must be at least five years prior to onset for s9(1) and s9(14)) and cessation date if applicable, to check the five‑year cessation windows (s9(1), s9(14)).

3. Document alcohol consumption and alcohol use disorder. Where alcohol consumption is relied on, quantify average weekly intake using the Australian Standard of ten grams of alcohol per standard drink and demonstrate at least 200 grams per week for five consecutive years within the ten years before clinical onset or worsening (s9(2), s9(15)). For alcohol use disorder, obtain diagnostic records or treatment notes contemporaneous with onset or worsening (s9(3), s9(16)).

4. Evidence comorbidities and liver disease. Obtain diagnostic records for diabetes mellitus, epilepsy, psoriasis involving the palm, cirrhosis and steatohepatitis. For cirrhosis or steatohepatitis, show diagnosis prior to clinical onset or worsening as required (s9(4), s9(17), s9(9), s9(10), s9(11), s9(22)-(24)).

5. Medication records. Secure pharmacy dispensing records, hospital charts or specialist oncology notes showing dates and doses for vemurafenib (treatment within two years of onset/worsening) and phenobarbital (average at least 100 mg/day for continuous two years before onset with one‑year cessation caveat) (s9(12)-(13), s9(25)-(26)).

6. Trauma and infection documentation. For trauma to hand/wrist/forearm or clinically significant palmar infection, obtain emergency department notes, surgical records, wound management entries, imaging, or hospital admission records showing the event, date, severity and duration. Ensure the trauma meets the Schedule 1 definition (symptoms/signs at least seven days or severity warranting medical attention). For bilateral rules, document which hand first developed Dupuytren disease and the precise timing to satisfy the one‑year or three‑month windows (s9(5)-(7), s9(18)-(20), Schedule 1).

7. Occupational and activity histories for cumulative hours. For the 10 000‑hour cumulative threshold, assemble detailed employment and duties records, task descriptions, rosters, and statements that allow calculation of hours. Translate repetitive duties, tool use (list model/types), and sports participation into a cumulative hours estimate. Obtain supporting contemporaneous documents or supervisor statements where possible (s9(8), s9(21)).

8. Proof of inability to obtain clinical management. If relying on s9(27), collect evidence of attempts to access care, waiting lists, correspondence with providers or health services, referral records, and any official denials or limitations that prevented “appropriate clinical management”. Obtain treating clinician statements on the clinical impact of delayed or absent care.

9. Link to relevant service. Demonstrate that the established factor is related to the claimant’s relevant service category as defined in Schedule 1 (operational, peacekeeping, hazardous, British nuclear test defence service under the VEA; warlike or non‑warlike service under the MRCA). Produce service records, deployment records, occupational specialty listings and any in‑service medical records that tie exposures or injuries to service episodes (s10(1), Schedule 1).

10. Consider cross‑referenced SoPs. If a factor invokes another disease or injury that is covered by a separate SoP, obtain and apply the relevant SoP’s criteria in evidence gathering and submissions (s11). For example, if a factor refers to an injury that has its own SoP, that instrument’s thresholds must be met as well.

11. Prepare expert evidence where necessary. Where the SoP requires clinical judgments about timing, causation or qualification of injuries, a treating specialist or independent expert report will strengthen proof. Experts should address the statutory criteria directly, for example, confirming that an infection constituted a “clinically significant infection involving the palmar surface,” or that cumulative hours meet the 10 000‑hour threshold.

12. Anticipate challenges on quantification and timing. Given the SoP’s precise numerical and temporal requirements, prepare to respond to queries about how pack‑years were computed, how alcohol consumption was averaged, how cumulative hours were calculated, and how dates of onset and worsening were determined. Where records are incomplete, obtain contemporaneous third‑party statements and corroborative occupational records.

13. Record keeping and contemporaneous evidence. The SoP rewards contemporaneous documentation. Enlistment medicals, routine GP notes, occupational health assessments, specialist correspondence and pharmacy dispensing records are all likely to be persuasive. Lack of contemporaneous records will often require admissible secondary evidence and may increase the need for an expert to bridge gaps.

14. Keep abreast of other SoPs and statutory procedure. Because s11 requires application of other SoPs “as in force from time to time” where relevant, and because the SoP operates within the VEA and MRCA processes, claimants and advisers should monitor for updates to related SoPs and follow appeal and review procedures stipulated in the governing Acts.

In short, compliance requires mapping the claimant’s medical and exposure history precisely to the criteria of s9, documenting the relationship to relevant service under Schedule 1, and assembling medical, employment and service records capable of meeting the numerical, duration and temporal windows specified in the instrument.