Statement of Principles concerning open-angle glaucoma (Reasonable Hypothesis) (No. 49 of 2021)

The core legal concept in this instrument is the "reasonable hypothesis" standard for causal connection between a specified disease (open-angle glaucoma) and "relevant service". Section 9 expresses the threshold: before it can be said that a reasonable hypothesis has been raised connecting the disease or death with the circumstances of relevant service, at least one enumerated factor must exist (s 9). The instrument does not define "reasonable hypothesis" within its text; instead it sets objective biomedical markers and exposures that constitute the factual basis for raising that hypothesis.

Open-angle glaucoma is defined substantively in s 7(2) as an acquired, progressive optic neuropathy with characteristic optic disc abnormalities and associated visual field defects, occurring with an open iridocorneal angle and usually associated with raised intraocular pressure. The definition includes normal tension glaucoma and excludes congenital, infantile or developmental glaucomas (s 7(2)(a)-(c)). The Schedule cross-references and clinical descriptors are intended to be applied rather than reliance on the ICD code alone: s 7(3) emphasises that while the condition attracts ICD‑10‑AM code H40.1, the meaning in this instrument is the text definition in s 7(2); s 7(4) specifies the ICD edition referenced.

The instrument operates by listing specific exposure and disease-related factors that link the clinical condition to service. These factors fall into several categories:

• pharmacological exposure: systemic, inhaled, topical ocular or topical facial glucocorticoid therapy of specified doses and durations, including cumulative dose and average dose thresholds for systemic therapy (s 9(1), s 9(12); Schedule definitions including the table of equivalent glucocorticoid doses);
• inflammatory eye disease: uveitis, scleritis, episcleritis and sympathetic ophthalmia at time of clinical onset or worsening (s 9(2), (13), (6), (17); Schedule definitions);
• structural or space-occupying lesions of the eye: benign or malignant neoplasms or non-neoplastic lesions of the affected eye at onset or worsening (s 9(3), (14));
• neovascularisation of the iridocorneal angle due to conditions/procedures listed in the Schedule (s 9(4), (15)); the Schedule lists specified conditions or procedures such as diabetic retinopathy and retinal vascular occlusion;
• trauma and intraocular surgery (s 9(5), (7), (16), (18)); the Schedule defines trauma to include blunt/penetrating and chemical/thermal/radiation injury that results in intraocular inflammation, bleeding or tissue disruption;
• therapeutic radiation that included the eye in the radiation field (s 9(8), (19));
• systemic comorbidity markers: specific endocrine diseases within 12 months before onset or worsening (Schedule defined list) and cardiovascular/metabolic risk factors such as hypertension and dyslipidaemia (s 9(9)-(11), (20)-(22); Schedule gives precise lipid thresholds);
• non-clinical access factor: inability to obtain appropriate clinical management for open-angle glaucoma as a factor for raising a reasonable hypothesis of material contribution to or aggravation of the disease (s 9(23)).

Section 10 governs how those factors are related to "relevant service". Subsection 10(1) requires each factor to be related to the person's relevant service. Subsection 10(2) narrows the application of factors listed in subsections 9(12) to 9(23) to cases of material contribution to, or aggravation of, existing glaucoma where the condition was suffered or contracted before or during (but did not arise out of) the relevant service.

Section 11 creates a specific interaction rule: if any factor in s 9 relates to an injury or disease that is itself covered by another Statement of Principles determined under subsection 196B(2) of the VEA, then that other Statement applies in accordance with its own terms as in force from time to time (s 11). The Schedule provides the operational definitions and numeric thresholds that implement the factors listed in s 9.

The instrument thereby translates clinical exposures and diseases into discrete legal triggers for the "reasonable hypothesis" used by VEA/MRCA decision-makers. It externalises clinical judgement to a set of textually-specified factors and definitions.

This Statement directly affects three groups identified in the instrument.

First, it affects claimants under the VEA and MRCA frameworks: veterans, members of Peacekeeping Forces, members of the Forces under the VEA, and members under the MRCA whose claims involve open-angle glaucoma or death from open-angle glaucoma. The instrument applies to "a claim to which section 120A of the VEA or section 338 of the MRCA applies" (s 5). Those sections, not reproduced here, are the statutory hooks that bring the Statement into claim assessment. Practically, any person submitting a claim under those provisions where open-angle glaucoma or a contributing death is alleged will be litigating or being assessed against the criteria in this Statement.

Second, it affects the Repatriation Medical Authority and decision makers within the veterans’ compensation system. The Authority made the Statement under subsection 196B(2) of the VEA (s 3) and declares in s 8 that it is of the view that there is sound medical‑scientific evidence indicating a possible relationship between open-angle glaucoma and relevant service. The Authority’s determination sets clinical thresholds, diagnostic definitions and enumerated factors that Departmental decision-makers, medical advisors, and tribunals will use when considering whether a reasonable hypothesis has been raised.

Third, it affects medical practitioners who provide evidence in claims and administrators handling records. The Statement requires clinical facts and laboratory or prescription data to be matched to the instrument’s definitions. For example, Schedule 1 defines dyslipidaemia by specific laboratory cut-offs (HDL cholesterol < 1.0 mmol/L; LDL > 4.0 mmol/L; triglyceride ≥ 2.0 mmol/L; total cholesterol > 5.5 mmol/L) or by regular administration of lipid-lowering drug therapy. The Schedule defines cumulative and average dose thresholds for systemic glucocorticoid therapy and equivalent inhaled doses (for example, equivalent inhaled glucocorticoid defined by 1,600 micrograms of budesonide) and identifies topical ocular regimens. These are the data points practitioners must record and explain for claims. Medical records, medication charts, surgical records and radiotherapy field documentation will be relevant to establish the occurrence and timing of the factors listed in s 9.

Indirectly, the Statement affects insurers, rehabilitation providers, and legal representatives instructing on claims because it alters the evidential baseline for raising a reasonable hypothesis of service connection for glaucoma claims. Because s 11 requires that where a s 9 factor refers to an injury or disease that is covered by another Statement of Principles, that other Statement applies "as in force from time to time", the network of Statements in force affects the assessment of multi-factor causal chains. The instrument therefore interfaces with any other Statements that cover the diseases or procedures listed in its factors (for example, diabetic retinopathy or intraocular tumours listed in the specified list).

Finally, the instrument affects mortality claims to the extent death is from a terminal event or condition that was contributed to by the person's open-angle glaucoma. The Schedule defines "terminal event" by specific proximate causes (pneumonia, respiratory failure, cardiac arrest, circulatory failure or cessation of brain function), so estate administrators and legal advisers in death claims will need to consider how to evidence contribution by glaucoma to these terminal events (s 7(5); Schedule).

The Statement does not impose criminal sanctions or civil fines. It functions as a rules-based evidentiary instrument for entitlement determinations. The key legal duties and decision-making constraints it creates are administrative and evidentiary.

Duty to apply the Statement in relevant claims: The Statement applies to claims to which the statutory sections referenced apply (s 5). Decision-makers assessing such claims are required to take the Statement into account as the basis for whether a reasonable hypothesis connecting open-angle glaucoma (or death from it) with relevant service has been raised. The instrument itself does not recite the decision-maker’s full statutory duties under the VEA or MRCA; it provides the clinical test and definitions that constitute the evidentiary baseline.

Duty to look to the Schedule definitions: The Schedule contains the specific definitions that must be used to give effect to the factors in s 9. For example, the definition of "glucocorticoid therapy as specified" in the Schedule sets out multiple pathways that satisfy that factor (systemic therapy that meets cumulative and average dose criteria, inhaled protocols, topical ocular use daily for at least two weeks, intranasal over-maximum dosing, intraocular/periocular injection, etc.). Decision-makers must therefore ask whether the claimant’s clinical record meets those Schedule thresholds when applying the s 9 factors.

Duty to connect factors to relevant service: Section 10(1) requires that the existence of any factor in s 9 must be related to the person's relevant service. The instrument therefore imposes a linkage duty: it is not sufficient that a factor exists at any time; the causative or contributing element must be connected to the period or circumstances of relevant service. The instrument does not prescribe the evidentiary standard for proving that relationship beyond the reasonable hypothesis provision; the Statement supplies the medical triggers that can raise the hypothesis.

Duty to apply other Statements where relevant: Section 11 requires that where any s 9 factor refers to an injury or disease covered by a different Statement of Principles, that other Statement applies according to its current terms. Decision-makers must therefore incorporate other Statements into their analysis when the causal chain involves multiple covered conditions.

Rights of claimants: The Statement creates a structured pathway by which claimants can seek to raise a reasonable hypothesis. If a claimant can document at least one of the s 9 factors as related to relevant service, a reasonable hypothesis will be raised for the purposes of the VEA/MRCA process. The instrument gives claimants and their advisers clarity on the precise clinical and exposure evidence that should be adduced , for example, particular cumulative glucocorticoid doses, blood lipid levels, records of intraocular surgery, or documentation of therapeutic radiation fields that included the eye.

Administrative limits on rights: The instrument also narrows some claims. In particular, subsections 9(12) to 9(23) are limited (per s 10(2)) to material contribution to, or aggravation of, existing glaucoma where the glaucoma was suffered or contracted before or during but did not arise out of the person's relevant service. That textual limit creates a procedural restriction on how those factors can be used to found a new liability for a disease that arose after service.

Operational responsibility for evidence compilation: Although not framed as a statutory "duty" on claimants, the Statement’s specificity makes clear that claimants and treating practitioners bear the practical responsibility of compiling records that demonstrate the timing, dosing, laboratory values and anatomical or surgical details that match the Statement’s criteria. These are the concrete facts that decision-makers must find to exist for the Statement to operate.

This instrument is a Statement of Principles and does not itself create criminal offences, civil penalties or an enforcement regime. The text contains no express sanctions, monetary penalties, criminal liability, inspection powers or administrative fines. Its legal operation is to inform the assessment of entitlement under the VEA and MRCA by specifying the factors that raise a reasonable hypothesis connecting open-angle glaucoma (or death from it) with relevant service (s 8-9). That is an evidentiary and normative role rather than penal.

Enforcement in practice occurs through administrative decisions on claims. The Statement will be used by the relevant decision-makers and medical officers when deciding whether a claim satisfies the legal test required by the service compensation statutes to establish entitlement. For example, where a claimant adduces records that meet one or more of the s 9 factors and those records are connected to relevant service, the Statement provides the basis for the decision-maker to find that a reasonable hypothesis has been raised. The Statement itself does not prescribe or entitle any particular remedy; rather, it supplies the causal link used in statutory decision-making under the VEA/MRCA frameworks. The specific remedies, rates, or entitlements flow from the VEA or MRCA statutory regimes and not from this instrument.

Administrative review and judicial oversight mechanisms that apply to VEA/MRCA decisions remain the routes by which decisions based on this Statement can be challenged, but the instrument does not set those routes or their procedures. The Statement’s section 11 interaction rule requires decision-makers to apply any other applicable Statements of Principles "as in force from time to time," which creates a dynamic evidentiary environment for enforcement of entitlements; the practical effect is that enforcement is executed by administrative adjudication using the Statement as evidentiary law.

Because the instrument sets precise clinical thresholds, there is an indirect compliance enforcement effect: failure to provide medical records that match the Schedule’s definitions will prevent a claimant from raising a reasonable hypothesis, thereby resulting in denial of entitlement in administrative decision-making. The Statement therefore enforces evidentiary discipline through definition rather than by imposing penalties.

This Statement is made under subsection 196B(2) of the Veterans' Entitlements Act 1986 and explicitly applies to claims falling under section 120A of the VEA or section 338 of the Military Rehabilitation and Compensation Act 2004 (s 3, s 5). It therefore operates within and as part of the statutory compensation architecture established by those Acts. The instrument repeals an earlier Statement of Principles for open-angle glaucoma (No. 27 of 2012), replacing that prior instrument (s 4).

Cross-references to other Statements: Section 11 provides a direct interface mechanism with other Statements of Principles. If a factor in s 9 refers to an injury or disease that is the subject of another Statement made under subsection 196B(2) of the VEA, then the other Statement applies in accordance with its own terms as in force from time to time (s 11). That creates an integrated, cross-referential system where overlapping pathologies or procedural causes are assessed against their respective Statements rather than being double-counted or inconsistently interpreted.

ICD coding is explicitly subordinated to the instrument’s substantive definition. Section 7(3) and (4) state that while open-angle glaucoma attracts ICD‑10‑AM code H40.1 and the instrument references the ICD edition, the operative meaning for application is the text definition in s 7(2). This prevents decision-makers from applying a code as a legal shorthand in place of the instrument’s clinical criteria.

Interaction with clinical and procedural law: The Schedule’s definitions import concrete clinical thresholds into the legal assessment. For example, "dyslipidaemia" is defined by specific laboratory values or by the regular administration of lipid-lowering therapy. "Glucocorticoid therapy as specified" is defined by cumulative and average systemic doses, inhaled equivalents, topical ocular use, intranasal overdosing, intraocular/periocular injection, facial topical application, or high potency topical application over specified durations. These clinical thresholds interact with medical and pharmaceutical record-keeping and with professional standards for prescribing, because the presence or absence of the defined exposure will determine whether a reasonable hypothesis has been established for a claim.

Temporal and causal interaction with statutory causation: Section 10(2) introduces a statutory-temporal interaction: subsections 9(12) to 9(23) apply only to material contribution to, or aggravation of, open-angle glaucoma where the person’s glaucoma pre-dated or occurred during service but did not arise out of service. That restricts the ability to use those factors to found new disease-onset claims arising after service. The Statement therefore interacts with the broader statutory causation concepts in the VEA and MRCA (not reproduced here) by prescribing when certain exposure-factors can be used as the basis for contribution or aggravation findings.

Death claims: The instrument expressly extends to death from open-angle glaucoma where death was from a terminal event or condition contributed to by open-angle glaucoma (s 7(5)); Schedule defines "terminal event" by proximate causes like pneumonia, respiratory failure, cardiac arrest, circulatory failure or cessation of brain function. This creates an intersection between the medical cause-of-death recording regime and veterans’ entitlement law in death claims for which the instrument’s rules must be applied.

Repeal of prior Statement: By repealing the 2012 Statement (s 4), the instrument displaces prior definitional and evidentiary law for open-angle glaucoma claims. Decision-makers and practitioners must therefore apply the 2021 text rather than the prior instrument in any claims to which it applies. Section 11’s "as in force from time to time" language also means that interplay with other Statements is dynamic; changes to other Statements after 2021 can alter how the present Statement’s factors are interpreted in composite causal chains.

Overall, the instrument is an evidentiary rule within the statutory compensation framework. It interacts with the VEA and MRCA by identifying conditions and exposures that, if established and linked to relevant service, raise a reasonable hypothesis. It requires medical and administrative records to be aligned to its Schedule definitions and imposes cross-Statement application where overlapping injuries/diseases occur.

The instrument itself contains limited historical material, but what it records is precise. The Statement is titled "Statement of Principles concerning open-angle glaucoma (Reasonable Hypothesis) (No. 49 of 2021)" and is dated 23 April 2021 with commencement 24 May 2021 (s 1, s 2). Section 4 expressly repeals the earlier Statement of Principles concerning open-angle glaucoma No. 27 of 2012 (Federal Register of Legislation No. F2012L00457), which had been made under subsections 196B(2) and (8) of the VEA (s 4). The 2021 instrument therefore replaces the 2012 instrument.

No other amendments, versions, schedules or transitional provisions are included in the text provided. The instrument’s section 11 contemplates that other Statements of Principles may change over time because it requires application of other Statements "as in force from time to time" when a factor refers to a disease or injury covered by another Statement (s 11). That language implicitly accepts that the network of Statements is subject to future amendment, but the present instrument contains no amendments itself other than the repeal of the 2012 Statement.

The Schedule of Definitions in the instrument sets out precise clinical thresholds and equivalent dose tables. Those definitional features are integral components of the instrument and constitute the operative content for assessment from its commencement date.

Because the instrument is an administrative determination under the VEA, amendments to the VEA, MRCA, or to other Statements of Principles can change the practical operation of this Statement by altering the statutory framework or by changing referenced Statements. The instrument does not list subsequent legislative amendments, judicial decisions or administrative clarifications; any such materials would need to be checked in the official register, but they are not recorded in the instrument text itself.

In short, the recorded amendment history within the instrument is: creation dated 23 April 2021, commencement 24 May 2021, and repeal of the 2012 Statement of Principles (No. 27 of 2012) (s 2, s 4). No further amendments are contained within the document.

The Statement document does not contain or report any litigation history. It does not list cases, tribunal decisions or judicial reviews that interpret, apply, challenge or otherwise concern this particular Statement of Principles. The instrument is a legislative-administrative determination and the text does not include references to any judicial consideration.

Because the Statement operates as an evidentiary instrument within the VEA/MRCA claims process, disputes over its application can and likely will arise in administrative review or judicial proceedings. However, the instrument itself is silent on any prior or subsequent litigation. Section 11’s provision that other Statements of Principles "apply in accordance with the terms of that Statement of Principles as in force from time to time" anticipates that other Statements may have their own litigation histories that influence the interpretation of factors which cross-reference those Statements, but the present instrument provides no account of such cases.

Practitioners requiring the litigation history of this Statement , for example, tribunal or court decisions that have considered the meaning of "reasonable hypothesis," the interpretation of the Schedule definitions, or the operation of s 10(2) in relation to material contribution/aggravation , will need to consult administrative review records, tribunal decisions (such as Veterans’ Review Board files), and judicial databases. None of those records are included in, or referred to by, the Statement text supplied here.

For the present purpose the Statement should be treated as a primary source document that supplies the statutory medical criteria; questioners should not assume from the silence of the instrument that its elements have been tested in litigation. If a legal argument depends on a particular interpretive point, the absence of litigation references in the instrument means the argument may require independent research into VEA/MRCA decisions and judicial review outcomes.

This instrument contains several technical features and drafting choices that can trip up claimants, medical witnesses and decision-makers unless carefully attended to.

1. The operative definition trumps ICD coding: The instrument notes that open-angle glaucoma attracts ICD‑10‑AM code H40.1 (s 7(3)), but it requires application of the definition in s 7(2) rather than relying on the ICD code alone. Practically that means a diagnostic label on a medical record is insufficient; the record must demonstrate the clinical elements in s 7(2) (progressive optic neuropathy, optic disc abnormalities, visual field defects, open iridocorneal angle, usually raised IOP), or at least be consistent with them.

2. Timing and last-dose windows: For glucocorticoid exposure that has ceased, the instrument requires the last dose to have been received within three months before clinical onset (s 9(1)) or clinical worsening (s 9(12)). This creates a narrow temporal window; if records only show past use that ceased more than three months before onset, the s 9 glucocorticoid factor may not be available.

3. Multiple distinct definitions for glucocorticoid exposure: "Glucocorticoid therapy as specified" can be satisfied by several different exposure routes and dose regimes , systemic cumulative and average dose thresholds, inhaled equivalents, topical ocular use for two weeks, intranasal over-dosing for four weeks, high potency topical facial use for four weeks, intraocular/periocular injection, and more (Schedule). Practitioners must map prescription records, pharmacy dispensing histories and administration charts to the precise Schedule pathways. Failure to document route, dose, frequency and duration can mean a claimant cannot show a Schedule pathway was met.

4. Numeric thresholds that require specific lab data: Dyslipidaemia is defined by precise serum cut-offs (HDL < 1.0 mmol/L; LDL > 4.0 mmol/L; triglycerides ≥ 2.0 mmol/L; total cholesterol > 5.5 mmol/L) or regular administration of lipid-lowering drug therapy (Schedule). If medical records do not include those specific test results, the dyslipidaemia factor may not be established.

5. Scope-limited application for certain factors: Subsections 9(12) to 9(23) are only available for material contribution to, or aggravation of, glaucoma where the glaucoma was suffered or contracted before or during relevant service but did not arise out of it (s 10(2)). These factors therefore cannot be used to establish that glaucoma was contracted as a new disease out of service when their timing does not meet that condition. This is a common source of error when advisers attempt to use the same language for onset claims post-service.

6. "Inability to obtain appropriate clinical management" is a factor but undefined: Section 9(23) lists "inability to obtain appropriate clinical management" as a factor but does not define what constitutes inability or appropriate management in the Schedule. That opens an evidential question over what documentary proof suffices: appointment refusals, service access denials, geographical limitations, or other barriers. The instrument leaves this to interpretation by decision-makers.

7. Cross-Statement dependencies: If a s 9 factor refers to an injury/disease covered by another Statement (for example diabetic retinopathy in the specified list), section 11 requires application of that other Statement "as in force from time to time" (s 11). Practically this means claimants must identify and marshal evidence not only for the glaucoma Statement but also for relevant ancillary Statements; failing to do so may cause missed causal links.

8. Death claims require establishment of contribution: Death from open-angle glaucoma is included only where death was from a terminal event or condition that was contributed to by the person's glaucoma (s 7(5)). The Schedule defines terminal event in specific terms (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function). For a death claim, practitioners must show that the defined terminal event occurred and that glaucoma contributed to it. Causation will therefore involve mapping the medical cause of death to glaucoma’s role.

9. Trauma definition is functional not by mechanism alone: "Trauma" in the Schedule includes blunt/penetrating injury and chemical/thermal/radiation injury that result in intraocular inflammation, bleeding or tissue disruption. Merely showing an exposure that is described as "trauma" may be insufficient unless records document the required intraocular sequelae.

10. Repeal of prior Statement may change precedent: The 2012 Statement has been repealed (s 4). Any reliance on interpretations or practice generated under the old Statement should be checked against the 2021 text for differences.

These are concrete evidentiary and procedural pitfalls that arise from the Statement’s combination of precise clinical thresholds, temporal windows, cross-reference rules and occasional undefined terms. Successful claims and robust decision-making will require attention to those textual details.

Complying with this Statement for the purposes of raising a reasonable hypothesis in a VEA or MRCA claim requires assembling and presenting documentary evidence that maps directly to the instrument’s textual criteria. Below are practical actions for claimants, treating practitioners, and decision-makers grounded in the Statement’s provisions.

1. Establish relevant service: The Statement applies only to claims to which section 120A of the VEA or section 338 of the MRCA applies (s 5). Ensure the claimant’s service records that demonstrate relevant service (operational, peacekeeping, hazardous, British nuclear test defence, warlike or non-warlike service as defined in the Schedule) are lodged or linked to the claim. Section 10 requires the existence of any s 9 factor to be related to relevant service, so evidence must connect the exposure or disease to the period or context of service.

2. Document the clinical diagnosis against s 7(2): Provide ophthalmology reports, visual field tests, optic disc imaging (e.g., OCT), intraocular pressure readings and specialist letters that address whether the condition meets the instrument’s definition of open-angle glaucoma: progressive optic neuropathy with optic disc abnormalities, associated visual field defects, and an open iridocorneal angle; normal tension glaucoma is included (s 7(2)). Do not rely solely on ICD coding (s 7(3)-(4)).

3. Match timing for onset and worsening: For factors that pertain to clinical onset, supply contemporaneous records showing the exposure or disease existed before the recorded clinical onset. For factors that pertain to clinical worsening, document dates of worsening and show the relevant exposures fall within the required windows. For glucocorticoid exposures that have ceased, ensure the last dose is shown to be within three months before clinical onset or clinical worsening where required (s 9(1), s 9(12)).

4. Prove glucocorticoid exposure to Schedule thresholds: Where the claim relies on "glucocorticoid therapy as specified", compile prescribing records, administration charts, pharmacy dispensing histories and specialist notes that show route, cumulative dose, duration and average daily rate. For systemic therapy, the Schedule defines minimum cumulative doses and minimum average rates for named glucocorticoids (for example prednisolone cumulative 375 mg and minimum average rate 12.5 mg/day; see Schedule table). For inhaled agents, compile inhaler prescriptions and dosages and use the Schedule’s equivalent inhaled glucocorticoid definitions (e.g., 1,600 micrograms budesonide equals an equivalent inhaled glucocorticoid). For topical ocular, intraocular/periocular injections, facial topical application or high potency topical use, ensure notes record the frequency and duration (two weeks for topical ocular daily; four weeks for inhaled beclomethasone at 1,600 mcg or equivalent; four weeks for facial topical at above therapeutic doses etc.).

5. Provide laboratory and medication evidence for dyslipidaemia and endocrine disease: For dyslipidaemia, provide serum lipid panels showing specific cut-offs in the Schedule (HDL < 1.0 mmol/L; LDL > 4.0 mmol/L; triglyceride ≥ 2.0 mmol/L; total cholesterol > 5.5 mmol/L) or proof of ongoing lipid-lowering therapy. For specified endocrine diseases (Cushing syndrome, diabetes mellitus, eye disease associated with Graves’ disease, hypothyroidism), supply the diagnosis and timing relative to onset/worsening.

6. Evidence of eye-specific conditions, surgery, trauma and radiotherapy: For factors that rely on intraocular surgery, intraocular tumours, neovascularisation secondary to listed conditions, or trauma, compile the operation notes, surgical discharge summaries, ophthalmology letters, pathology reports and radiotherapy dosimetry that show the affected eye was the organ involved and when the procedure or exposure occurred relative to onset/worsening (s 9(3)-(9), (14)-(19)). For radiotherapy, include field maps demonstrating the affected eye was in the radiation field.

7. Address "inability to obtain appropriate clinical management": If relying on s 9(23), gather documentary evidence showing attempts to obtain treatment: referral letters, waiting lists, correspondence denying or delaying specialist care, records of service unavailability in theatre of service, or other objective proof of access barriers. Because the instrument does not define "inability" or "appropriate management," robust contemporaneous documentation will lend weight to the claim.

8. If a s 9 factor refers to another Statement, obtain that Statement and relevant evidence: For instance, if diabetic retinopathy is alleged as a causal factor (it is in the specified list), identify and obtain the current Statement of Principles that covers diabetic retinopathy and ensure the evidence meets that Statement’s criteria as well as this one (s 11). Section 11 requires application of those other Statements "as in force from time to time."

9. For death claims prepare cause-of-death documentation tied to glaucoma contribution: If claiming for death from open-angle glaucoma, obtain the death certificate, autopsy report if any, and medical evidence showing that the terminal event listed in the Schedule (pneumonia, respiratory failure, cardiac arrest, circulatory failure or cessation of brain function) occurred and that glaucoma contributed to the terminal event (s 7(5); Schedule).

10. Bundle evidence into a service-related causal narrative: Although the Statement sets out discrete factors, claims should present a coherent medical narrative that links the documented factor(s) to service and to clinical onset/worsening. This helps decision-makers to apply s 10(1)’s relation-to-service requirement when considering whether the presence of a factor raises a reasonable hypothesis.

11. Anticipate cross-checks and cross-evidence requirements: Given the instrument’s precision, expect decision-makers to seek dosage calculations, cumulative totals and average dose computations for systemic glucocorticoids, or equivalent dose conversions for inhaled agents. Prepare pharmacy records and practitioner endorsements to assist with those computations.

12. Keep copies of all primary-source clinical records: Because small gaps (e.g., missing dates, absence of dosage strength, no record of route) can defeat a Schedule pathway, retain and submit primary-source hospital discharge summaries, operation notes, specialist ophthalmology letters, pathology and radiology reports, pharmacy dispensing records and blood test results.

Following these compliance steps will align documentary evidence with the instrument’s textual thresholds and temporal rules, thereby maximising the chance that a decision-maker will find a reasonable hypothesis has been raised connecting open-angle glaucoma (or death from it) to relevant service.