Statement of Principles concerning hereditary haemochromatosis (Reasonable Hypothesis) (No. 23 of 2021)

The Statement codifies several core legal medical concepts for adjudication of claims under the VEA and MRCA. First, the operative definition of hereditary haemochromatosis is provided in medical terms: it is any genetic disorder of iron transport and metabolism leading to excessive iron accumulation and demonstrated either by documented parenchymal organ iron overload or clinical evidence of iron‑related organ or tissue dysfunction (s 7(2)). The instrument expressly recognises classical HFE‑gene type 1 and non‑classical non‑HFE types within that definition (s 7(2)(b)(i)-(ii)). The instrument also notes a catalogue of clinical disorders commonly associated with hereditary haemochromatosis as background, including hepatic fibrosis or cirrhosis, hepatocellular carcinoma, heart failure, diabetes mellitus and others, but the operative legal definition remains the two‑part requirement in s 7(2).

Second, the idea of a reasonable hypothesis is operationalised by listing minimum factors that must exist before a reasonable hypothesis connecting hereditary haemochromatosis or death from it with service can be said to be raised (s 9). These factors are concrete biological or service‑related circumstances: quantified alcohol exposure over a five year period prior to clinical worsening (sex‑specific thresholds in s 9(1)-(2)); coexistent hepatitis C infection or steatohepatitis at the time of clinical worsening (s 9(3)-(4)); and inability to obtain appropriate clinical management (s 9(5)). The instrument notes that clinical worsening typically manifests as hepatic fibrosis or cirrhosis (s 9 Notes), which ties the temporal trigger to recognisable hepatic pathology.

Third, the instrument draws a legal‑temporal boundary on when these factors can be used to establish contribution or aggravation: they apply only where hereditary haemochromatosis was suffered or contracted before or during relevant service, but not where it arose out of service (s 10(2)). That is, the Statement is framed for material contribution to or aggravation of a pre‑existing or contemporaneously manifest condition; it does not treat the listed factors as establishing that the condition arose as a result of service.

Fourth, the Statement recognises cross‑instrument interaction: where a listed factor refers to an injury or disease that is the subject of another Statement of Principles determined under s 196B(2) of the VEA, that other Statement’s factors apply in accordance with its terms (s 11). The instrument also ties terminology back to the VEA and MRCA by defining “relevant service” in the Schedule to include operational, peacekeeping, hazardous and British nuclear test defence service under the VEA and warlike and non‑warlike service under the MRCA (Schedule, relevant service).

Finally, the instrument leaves certain terms and evidentiary questions open to administrative determination. For example, it sets thresholds for alcohol consumption measured in mass of alcohol (kilograms) over five years and references the Australian Standard of ten grams of alcohol per standard drink for calculation (s 9 Notes). It does not define “appropriate clinical management” or prescribe the precise evidentiary standard for proving inability to obtain it (s 9(5)). The suite of concepts therefore combines specific, quantifiable thresholds with deliberately broad clinical formulations that require adjudication against contemporaneous medical records and service history.

This Statement affects three principal groups of persons and the decision makers who assess their claims. First, it affects veterans and members whose claims fall under section 120A of the VEA or section 338 of the MRCA, because the instrument applies to claims to which those provisions apply (s 5). The Schedule defines “relevant service” broadly to include operational, peacekeeping, hazardous and British nuclear test defence service under the VEA and warlike and non‑warlike service under the MRCA, so the affected population is the subset of serving or former members who rendered those classes of service and who either have hereditary haemochromatosis or died from it (Schedule, relevant service). Second, it affects clinicians and medical experts who provide assessments and records for claims, because the Statement requires clinical evidence tied to specific events , documented iron overload or clinical organ dysfunction (s 7(2)), evidence of clinical worsening (typically hepatic fibrosis or cirrhosis, s 9 Notes), the presence of hepatitis C or steatohepatitis at the time of worsening (s 9(3)-(4)), or the inability to obtain clinical management (s 9(5)). Third, decision makers within the Department and adjudicators who apply the VEA and MRCA will be affected in their assessment methodology because the Statement prescribes which factors, and which temporal relationships, will raise a reasonable hypothesis connecting the condition or death to service (s 9; s 10).

Who pays or bears costs under this instrument is indirect and administrative. The Statement itself does not create new monetary obligations or penalties; rather, it structures the evidentiary universe that influences whether claimants obtain entitlements under the VEA or MRCA. The claimant bears the practical burden of assembling evidence to show the existence of the factors in s 9 and their relationship to relevant service (s 10(1)). Clinicians will bear time and documentation costs in preparing records that establish documented iron overload, liver pathology consistent with clinical worsening, hepatitis C infection status at relevant times, or inability to obtain appropriate management. Decision makers must assess that evidence against the Statement’s definitions and temporal constraints; they bear administrative costs in applying this instrument to claims.

The Statement also concentrates the evidentiary focus. For example, the alcohol thresholds specified for males and females create a discrete, high‑threshold behavioural criterion that will particularly affect claimants with substantial documented alcohol exposure in the relevant five year window (s 9(1)-(2) and Notes). Claimants without those specific factors must rely on other listed factors such as coexisting liver disease or failure of access to clinical management. Because the Statement ties the notion of “death from hereditary haemochromatosis” to death from a terminal event contributed to by hereditary haemochromatosis, death claims will require linkage between the condition and the terminal event as defined in the Schedule (s 7(5); Schedule, terminal event). Where the factors in s 9 overlap with conditions covered by other Statements of Principles, the other Statements apply according to their terms, which can create procedural complexity in multi‑condition claims (s 11).

The Statement itself does not create duties in the sense of criminal or civil obligations; rather, it prescribes what must be established for a reasonable hypothesis of service connection to be raised in claims under the VEA and MRCA. Parties therefore have duties and rights in the claim context that the Statement informs.

Rights for claimants. A claimant has the right to have their hereditary haemochromatosis or death from hereditary haemochromatosis considered against the factors and definitions in this Statement when the claim is brought under section 120A of the VEA or section 338 of the MRCA (s 5). If one or more of the factors in s 9 exists and is related to the claimant’s relevant service, then, subject to s 10, a reasonable hypothesis may be raised connecting the condition or death with service (s 9; s 10). Where a factor refers to another injury or disease that is the subject of a different Statement of Principles, the claimant will be entitled to have that other Statement’s factors applied according to its terms (s 11).

Duties of evaluators and decision makers. Decision makers must apply the Statement as the authoritative list of factors that can raise a reasonable hypothesis of service connection for hereditary haemochromatosis and death from it. They must assess whether the condition meets the definition in s 7(2): documented iron overload in parenchymatous organs or clinical evidence of iron‑related organ or tissue dysfunction. They must also assess whether at least one of the s 9 factors existed in the relevant temporal relation to clinical worsening and whether that factor is related to relevant service (s 9; s 10). The Statement makes explicit that the factors set out in s 9 apply only to material contribution to or aggravation where hereditary haemochromatosis was suffered or contracted before or during, but did not arise out of, relevant service (s 10(2)). Decision makers therefore must determine timing of disease onset relative to service and whether the disease arose out of service.

Evidentiary duties. The Statement imposes a practical evidentiary duty on claimants to establish the presence of the listed factors. For alcohol exposure, the Statement specifies mass‑based thresholds over a five‑year window and a calculation method (Australian Standard of ten grams of alcohol per standard alcoholic drink) in its notes (s 9 Notes). For coexistent disease factors, the duty is to show hepatitis C infection or steatohepatitis at the time of clinical worsening (s 9(3)-(4)). For inability to obtain appropriate clinical management, the claimant must show that inability, but the Statement does not define “appropriate clinical management” or prescribe the evidentiary standard for inability (s 9(5)). These lacunae mean decision makers will exercise judgement in determining whether the available records satisfy the Statement’s requirements.

Interplay with other Statements. There is a duty to consult and apply other Statements where relevant: if a s 9 factor refers to an injury or disease covered by another Statement of Principles, then that other Statement applies in accordance with its terms (s 11). This creates a procedural duty to identify overlapping instruments and apply their factors as directed.

Administrative rights and limitations. By its terms, the Statement is an instrument made under s 196B(2) of the VEA (s 3) and therefore the RMA’s view that there is sound medical‑scientific evidence for the relationships asserted is framed as the Authority’s view (s 8). The Statement does not itself grant entitlements or impose penalties; rather, it sets the medical criteria that feed into entitlement decision‑making under the VEA and MRCA (s 5).

This Statement of Principles does not create offences, financial penalties or enforcement mechanisms within its text. It is a standards instrument made under the Repatriation Medical Authority’s statutory power (s 3), intended to guide the assessment of claims under other statutes. The instrument expressly applies to claims to which section 120A of the VEA or section 338 of the MRCA applies (s 5), and its practical enforcement is therefore procedural and adjudicative: decision makers in the claims system apply the Statement’s definitions and factors when determining whether a reasonable hypothesis exists linking hereditary haemochromatosis or death from hereditary haemochromatosis to relevant service.

Because the Statement does not prescribe sanctions, its effect is mediated through administrative outcomes in the VEA/MRCA claims processes. If a decision maker accepts that a claimant has established one or more of the factors in s 9 and that the factor(s) are related to relevant service and meet the temporal rule in s 10, that finding will inform the question of whether an entitlement exists under the VEA or MRCA. Conversely, failure to establish the s 9 factors, or a finding that the condition arose out of service (thereby excluding s 9 application under s 10(2)), will weigh against raising a reasonable hypothesis that the condition or death is connected to service. The instrument therefore enforces its standards indirectly by shaping the outcome of entitlements claims.

Administrative compliance risk. The Statement’s lack of definitional clarity for some terms creates enforcement‑adjacent risks. For example, the instrument uses the phrase “inability to obtain appropriate clinical management” as a factor (s 9(5)) but does not define “appropriate clinical management” or state what proof suffices to demonstrate inability to obtain it. That will require adjudicators to exercise evaluative discretion when enforcing the Statement’s standards in claims, potentially producing inconsistent outcomes unless internal procedural guidance supplements the instrument. Similarly, while the Statement references ICD‑10‑AM code E83.1 as the code typically associated with hereditary haemochromatosis, it expressly states that the operative meaning is s 7(2) and not the code alone (s 7(3)-(4)). Decision makers must therefore enforce the instrument using the statutory definition rather than relying solely on diagnostic coding.

Interaction with other enforcement regimes. Section 11 requires that where a s 9 factor refers to an injury or disease covered by another Statement of Principles, the other Statement’s factors apply as in force from time to time. Enforcement in these cross‑referenced situations therefore requires coordinative application of multiple Statements, placing a procedural enforcement duty on adjudicators to identify and apply such Statements correctly.

This Statement is made under subsection 196B(2) of the Veterans' Entitlements Act 1986 (s 3) and expressly applies to claims to which section 120A of the VEA or section 338 of the MRCA applies (s 5). Its legal effect is to provide the Repatriation Medical Authority’s specified medical and temporal criteria for adjudication under those statutes. It therefore operates as an instrument that informs the statutory decision‑making framework established by the VEA and MRCA; the Statement itself does not create or alter substantive entitlements in the VEA or MRCA but conditions the evidentiary standard for causation or contribution within claims brought under those statutes.

The Statement interacts with other Statements of Principles by design. Section 11 provides that if a factor in s 9 refers to an injury or disease that is the subject of another Statement determined under s 196B(2) of the VEA, then the factors in that other Statement apply in accordance with its terms (s 11). Practically, this means adjudicators must cross‑check whether conditions such as hepatitis C or steatohepatitis,listed in s 9(3) and (4),are themselves the subject of separate Statements. Where they are, the other Statements’ factors will govern how those conditions are treated as contributing causes. The instrument thus creates a modular network of Statements where overlapping pathologies are resolved by reference to the specific Statements that cover them.

The Statement also references the ICD‑10‑AM classification (s 7(3)-(4)). It recognises that hereditary haemochromatosis generally attracts code E83.1 in the ICD‑10‑AM, Tenth Edition (s 7(3)-(4)), but it expressly states that for the purposes of this Statement the operative meaning is the textual definition in s 7(2). Therefore the legal interaction with diagnostic coding is subordinated to the instrument’s textual definition. Decision makers should therefore treat coded diagnostic entries as evidence but not as the definitive legal test for whether the condition is hereditary haemochromatosis under this Statement.

The Schedule defines “relevant service” to include particular categories of service under the VEA and MRCA (Schedule, relevant service). This situates the Statement within the wider statutory schemes of the VEA and MRCA because only claimants whose service falls within those enumerated categories will have claims to which this Statement applies (s 5; Schedule, relevant service). The Statement therefore interacts with statutory definitions of service in the VEA and MRCA, and adjudicators must integrate those service‑classification rules when applying s 10’s requirement that factors be related to relevant service (s 10(1)).

Finally, the instrument repeals the previous haemochromatosis Statement (No. 21 of 2012) (s 4). That repeal means that claims and adjudications occurring after commencement must apply this instrument rather than the prior one. Where factors refer to other Statements, those Statements apply according to their current terms “as in force from time to time” creating an ongoing dynamic interaction between Statements as they are amended or replaced (s 11).

The instrument records a concise amendment history within its own text. It is the Statement of Principles concerning hereditary haemochromatosis (Reasonable Hypothesis) No. 23 of 2021 (s 1). It was dated 24 December 2020 on the face of the instrument and commenced on 25 January 2021 (s 2; instrument header). Section 4 expressly repeals the earlier Statement of Principles concerning haemochromatosis No. 21 of 2012 (Federal Register of Legislation No. F2012L00450), which was made under the same statutory power, subsection 196B(2) of the VEA.

No further amendments, schedules of amendment, or amendment dates other than those stated are recorded in the instrument as provided. Where the instrument refers to the applicability of other Statements of Principles, it directs that those Statements apply in accordance with their terms “as in force from time to time” (s 11). This language contemplates that other Statements may be amended independently and that their updated terms will govern the interaction with this Statement where there is overlap. The instrument itself sets no sunset, review date or amendment schedule; any modification to its terms would be effected by the Repatriation Medical Authority or by legislative change to the underlying statutory framework.

Because the instrument repealed the 2012 Statement, practitioners should be attentive to the change in formulations and factors between the two instruments. The instrument’s commencement date (25 January 2021) marks the transition point at which it replaces the earlier Statement for relevant claims (s 2; s 4). The instrument also refers to ICD‑10‑AM code E83.1 and specifies the edition and effective date of the ICD reference (Tenth Edition, effective date of 1 July 2017) (s 7(4)). That degree of specificity locates the instrument’s reference framework to a particular version of the diagnostic classification, although the text of the instrument makes clear that the statutory definition in s 7(2) is the operative meaning for legal purposes (s 7(3)).

No other amendment entries, transitional provisions, or saving clauses are present in the instrument text supplied. The absence of transitional rules in this instrument means that the repeal and replacement operate from the stated commencement date; questions about claims initiated prior to commencement will be resolved by reference to the prevailing statutory practice and any relevant instructions from the administering agency, but those are not recorded in this instrument.

The instrument text contains no record of litigation, judicial interpretations, or case citations. It does not cite or summarise any judgments or administrative appeals. The Repatriation Medical Authority frames its position as a view that there is sound medical‑scientific evidence linking hereditary haemochromatosis and death from hereditary haemochromatosis to relevant service (s 8), but the instrument itself provides no litigation or appellate history in its text.

Therefore, within the document there is no internal litigation history to report. Practitioners seeking precedential or appellate guidance on how particular provisions have been interpreted or applied would need to consult the judicial and administrative records outside this instrument. The instrument’s Section 11 anticipates use in conjunction with other Statements of Principles determined under subsection 196B(2) of the VEA, and those other Statements may have their own litigation histories, but no such material appears within this instrument.

Because the Statement interacts with claims under the VEA and MRCA (s 5), litigation about entitlement in individual cases might arise in administrative appeals or judicial review proceedings; however, any such litigation is not recorded in the instrument and cannot be inferred from it. The instrument therefore stands as an administrative standards document whose operational effect and potential areas of dispute will be generated in the claims process rather than within the instrument text itself.

The instrument contains several features that commonly produce evidentiary or procedural pitfalls in claims. These are concrete mechanisms within the Statement and should be anticipated by practitioners and claimants.

1. High, quantified alcohol thresholds with unusual units. The Statement requires, for males, consuming a total of at least 60 kilograms of alcohol within any five year period before the clinical worsening, and for females, at least 40 kilograms over any five year period (s 9(1)-(2)). The Notes provide the conversion basis: the Australian Standard of ten grams of alcohol per standard alcoholic drink (s 9 Notes). That means the thresholds translate to 6,000 standard drinks for males and 4,000 standard drinks for females over any five year window. These are very large totals and require careful calculation from contemporaneous records. Practitioners should not assume ordinary declarations of “heavy drinking” will equate to the instrument’s unitised thresholds without specific quantification.

2. Temporal trigger is “before the clinical worsening” and clinical worsening is not precisely defined. The Notes state that clinical worsening typically manifests as hepatic fibrosis or cirrhosis (s 9 Notes). However, the instrument does not provide a precise definition of clinical worsening or a threshold diagnostic test for it beyond that typical manifestation. That creates a factual question in each case about when worsening occurred and what constitutes sufficient clinical evidence of worsening. Decision makers will need to rely on medical records showing fibrosis or cirrhosis or equivalent clinical deterioration.

3. Requirement that the hereditary haemochromatosis was “suffered or contracted before or during (but did not arise out of) the person’s relevant service” (s 10(2)). This phrase imposes a boundary: the Statement’s factors are meant to address material contribution to or aggravation of an existing or contemporaneous condition, not conditions that “arose out of” service. Cases where the disease onset is plausibly attributable to service will therefore not be captured by the s 9 factors as mechanisms for material contribution or aggravation under this instrument, unless the disease was manifest before or during service but did not itself arise out of service. That is a potential evidentiary pitfall for claimants who assert service as the origin of the disease.

4. “Inability to obtain appropriate clinical management” is a listed factor but undefined (s 9(5)). The Statement does not specify what counts as appropriate clinical management or what evidence suffices to show inability to obtain it. That opens the door to administrative uncertainty and discretionary assessments by adjudicators. Claims that rely on this factor will be sensitive to the quality and contemporaneity of records showing attempts to obtain care, reasons for denial or unavailability, and whether the care sought was “appropriate” in the clinical sense.

5. Coexisting disease factors require presence at the time of clinical worsening (s 9(3)-(4)). For hepatitis C and steatohepatitis, the instrument requires that the infection or steatohepatitis be present at the time of clinical worsening. That means temporal proof of infection status proximate to the worsening event is necessary. A historical diagnosis that preceded the worsening by a long interval will be relevant only if it was present at the time of worsening.

6. ICD‑10‑AM coding is informational, not definitional (s 7(3)-(4)). Although the instrument acknowledges that hereditary haemochromatosis attracts ICD‑10‑AM code E83.1, it states the operative meaning is s 7(2). Practitioners should not assume a diagnostic code alone meets the Statement’s legal definition; they must show the specific documentary or clinical features identified in s 7(2).

7. Cross‑instrument complexity. Section 11 requires application of other Statements where a factor refers to a condition covered by another Statement. This can create multi‑instrument adjudication and the need to cross‑reference different instruments’ factors “as in force from time to time”, which can complicate proof and timing where different Statements have differing requirements.

8. Death claims require linkage to a terminal event contributed to by hereditary haemochromatosis (s 7(5); Schedule, terminal event). The Schedule lists proximate or ultimate causes such as pneumonia or cardiac arrest as terminal events. Death claims must therefore show that the terminal event was contributed to by hereditary haemochromatosis, adding an extra causal link beyond the diagnosis of the condition itself.

9. Repeal and transition risk. The instrument repeals the 2012 Statement (s 4) without including transitional provisions in the text. Practitioners should check administrative guidance about how claims spanning the repeal date are to be handled, because the instrument text alone does not specify transitional treatment.

10. Burden of proof and administrative discretion. The Statement sets factors and definitions but leaves several assessment tasks to adjudicators: evaluating whether alcohol consumption calculations are reliable, whether clinical worsening occurred at a certain time, whether the claimant could obtain appropriate management and whether factors are related to relevant service (s 9; s 10). That layering of factual evaluations can produce divergent outcomes depending on the quality of documentation and the adjudicator’s application of the Statement.

Each of these points is grounded in the instrument text and is a source of potential friction or evidentiary difficulty when applying the Statement in claims.

For claimants, clinicians and advisers preparing evidence for claims that involve hereditary haemochromatosis under the VEA or MRCA, compliance means assembling documentation and structuring submissions so that the decision maker can apply the Statement’s definitional and factor tests (s 5; s 7-s 10). Concrete steps derived from the instrument follow.

1. Establish the operative diagnosis per s 7(2). The Statement requires either documented iron overload in parenchymatous organs or clinical evidence of iron‑related organ or tissue dysfunction. Evidence to compile therefore includes:

   • Imaging, biopsy or laboratory records documenting iron overload in liver, heart or other parenchymal organs; and
   • Clinical notes describing iron‑related organ dysfunction such as hepatic fibrosis or cirrhosis, cardiomyopathy, diabetes mellitus attributable to iron overload, hypogonadism or other organ dysfunction listed in the instrument’s explanatory note (s 7(2) and note). Remember that, although ICD‑10‑AM code E83.1 is mentioned, the Statement’s legal meaning is the textual definition in s 7(2) (s 7(3)).

2. Document the timing of clinical worsening. The factors in s 9 are triggered by a five year window “before the clinical worsening of hereditary haemochromatosis” and the Notes state that clinical worsening typically manifests as hepatic fibrosis or cirrhosis (s 9 Notes). Clinical records showing onset or progression to hepatic fibrosis or cirrhosis, pathology reports, imaging reports, hepatology consultation letters and relevant blood tests should be included with dates that allow the decision maker to locate the relevant five year window.

3. For alcohol exposure factors, quantify consumption precisely. The Statement uses kilograms of alcohol over any five year period (s 9(1)-(2)) and provides the conversion basis (ten grams per standard alcoholic drink). Convert historical alcohol intake records and declarations into grams and standard drinks, and present a clear calculation over rolling five year periods to show whether the threshold is reached. For clarity and auditability, break down amounts by year and by source of evidence (medical records, military health records, workplace incident reports, contemporaneous diaries). Note the sex‑specific thresholds: 60 kg for males, 40 kg for females (s 9(1)-(2)).

4. For hepatitis C or steatohepatitis factors, show presence at time of clinical worsening. For s 9(3)-(4), provide virology reports, serology, HCV RNA testing, liver biopsy or imaging reports, histopathology or specialist letters that establish hepatitis C infection or steatohepatitis at the time clinical worsening occurred. Date the evidence so the adjudicator can match disease presence to the defined temporal trigger.

5. For inability to obtain appropriate clinical management (s 9(5)), assemble contemporaneous evidence of attempts to obtain care and reasons for denial or delay. Records could include referral letters, appointment scheduling attempts, correspondence showing unavailability or refusal of services, military medical service records, and clinical notes discussing lack of access to phlebotomy, chelation, specialist hepatology or other standard management for hereditary haemochromatosis. Because “appropriate clinical management” is not defined in the instrument, present clinical justification from treating specialists about what would have constituted appropriate care and explain how it was inaccessible.

6. For death claims, link the terminal event to hereditary haemochromatosis. The Statement includes death from a terminal event or condition contributed to by hereditary haemochromatosis (s 7(5)). Provide death certificates, coronial findings where applicable, treating clinician statements and post‑mortem reports demonstrating that the terminal event (as defined in the Schedule) was contributed to by hereditary haemochromatosis.

7. Demonstrate relationship to relevant service and timing. Section 10 requires that the existence of any s 9 factor must be related to relevant service rendered by the person (s 10(1)), and s 10(2) states the s 9 factors apply only to material contribution to or aggravation where the hereditary haemochromatosis was suffered or contracted before or during, but did not arise out of, relevant service. Evidence to compile therefore includes military service records showing dates of service, medical records from before, during and after service, and chronology mapping disease onset and clinical worsening to service dates. Where a claimant asserts that the condition was contracted or suffered before or during service, show contemporaneous clinical evidence of the condition in that period.

8. Where a s 9 factor refers to another disease that has its own Statement, include cross‑evidence. Section 11 requires that other Statements’ factors apply where relevant. If the factor references hepatitis C or another condition covered by a separate Statement, include the evidence that would satisfy that other Statement’s factors as well, or cite the other Statement where appropriate.

9. Present concise, dated chronologies and calculation worksheets. Because the Statement depends on temporal windows (five year rolling periods before clinical worsening), clear chronologies and calculation breakdowns help adjudicators apply the instrument without needless interpretation.

10. Anticipate adjudicator discretion and prepare to address it. The Statement leaves certain assessments to adjudicators, especially “inability to obtain appropriate clinical management” and the precise timing of clinical worsening. Provide treating specialist opinions that translate clinical facts into the language of the Statement, for example opining on whether a patient’s condition meets the s 7(2) definition and whether clinical worsening occurred at a stated date.

Following these steps aligns documentary and medical evidence to the explicit requirements of the Statement. Because the Statement replaces the 2012 Statement (s 4) and commenced on 25 January 2021 (s 2), ensure that submissions for claims brought after that date rely on this instrument’s provisions. Keep in mind that where factors overlap with other Statements of Principles, those Statements must be applied according to their current terms (s 11).