Statement of Principles concerning pilonidal sinus (Balance of Probabilities) (No. 28 of 2019)

Central legal concept: a Statement of Principles determined under subsection 196B(3) of the VEA identifies factual factors which, when established on the balance of probabilities and related to a person’s relevant service, permit a positive finding that an injury or disease is connected with service. Section 8 records the RMA’s medical‑scientific conclusion that pilonidal sinus and death from pilonidal sinus can be related to relevant service on the balance of probabilities. That is an evidentiary threshold rather than a prescriptive entitlement rule. The instrument does not itself award entitlements; it informs the causation component of claims under the VEA and MRCA (s 5).

Definitions determine the scope of the condition covered. The instrument defines pilonidal sinus as an inflammatory tissue reaction of the skin to an embedded hair manifested by development of a sinus or fistula; it includes pilonidal cyst and pilonidal fistula but excludes ingrown hair (s 7(2)). The RMA notes typical anatomical locations but adopts the textual definition for claim work (s 7(2), (3)). The statement treats death from pilonidal sinus as including death from a terminal event or condition that was contributed to by the person’s pilonidal sinus (s 7(5)). The Schedule provides operational definitions: BMI equals W/H2 (Schedule 1), being overweight or obese is BMI of 25 or greater, and cutaneous exposure to animal hair is defined as milking, shearing, grooming, clipping or slaughtering animals (Schedule 1).

Causation factors are site‑ and event‑specific. The RMA enumerates discrete, temporally framed factors that must exist before a connection to service can be established:

• For pilonidal sinus of the hand or foot, either work as a hairdresser/barber or cutaneous exposure to animal hair within six months before the clinical onset (s 9(1)(a)-(b)). The same pair of factors applies to clinical worsening (s 9(4)(a)-(b)).
• For pilonidal sinus of the sacrococcygeal region, either driving or being a seated passenger in a motorised vehicle averaging at least 20 hours per week for at least three months within the six months before clinical onset, or being overweight/obese within six months before onset (s 9(2)(a)-(b)). Parallel factors apply to clinical worsening (s 9(5)(a)-(b)).
• For sacrococcygeal and umbilical regions, inability to shower or bathe more than two times per week for a continuous period of at least four weeks within six months before onset or worsening (s 9(3), (6)).
• An additional, broader factor is inability to obtain appropriate clinical management for pilonidal sinus (s 9(7)).

Relationship and temporal rules constrain application. Any factor relied on must be related to the person’s relevant service (s 10(1)). Subsections 9(4) to 9(7) apply only to material contribution or aggravation where the person’s pilonidal sinus was suffered or contracted before or during relevant service but did not arise out of that service (s 10(2)). The instrument also instructs that where a listed factor refers to an injury or disease covered by another Statement of Principles, the other Statement applies according to its terms (s 11).

Operational notes: the instrument mentions the ICD‑10‑AM code L05 but clarifies that the statutory definition in s 7(2) controls (s 7(3)-(4)). The Schedule supplies the BMI formula and defines relevant service categories for the purposes of the instrument (Schedule 1).

Primary cohort: persons making claims under the sections of the VEA and MRCA specified in s 5. The instrument states it applies to a claim to which section 120B of the VEA or section 339 of the MRCA applies (s 5). The Schedule defines relevant service as eligible war service (other than operational service) under the VEA, defence service (other than hazardous service and British nuclear test defence service) under the VEA, or peacetime service under the MRCA (Schedule 1). Thus the instrument is targeted at veterans and members of the Forces whose service falls within those definitions when pilonidal sinus or death from pilonidal sinus is claimed to be connected to service.

Secondary cohorts and stakeholders include clinicians who provide the medical evidence required to establish the instrument’s factors, and administrative decision‑makers who will apply the Statement of Principles in individual claim determinations. The instrument engages employers and record‑keepers indirectly where occupational exposure is pleaded: for example hairdressers or barbers whose employment history may be used to establish a factor in s 9(1) and s 9(4), or transport employers whose roster or logbooks might bear on the driving 20 hours per week factor (s 9(2)(a), s 9(5)(a)). The instrument also affects persons whose personal circumstances intersect with the factors: those who are overweight or obese as defined by BMI 25 or greater (Schedule 1), persons exposed to animal hair by milking, shearing, grooming, clipping or slaughtering animals (Schedule 1), and persons with practical constraints on personal hygiene (“inability to shower or bathe more than two times per week for a period of at least four weeks” in the relevant period: s 9(3), (6)).

Family members or estates are affected where the instrument’s death from pilonidal sinus definition applies: the instrument includes death from a terminal event or condition that was contributed to by pilonidal sinus (s 7(5) and Schedule 1 definition of terminal event). Where death is claimed, claimants must show the contribution of pilonidal sinus to the terminal event. The instrument’s scope thus reaches beyond acute clinical disease to deaths in which pilonidal sinus formed part of the causal pathway.

Administrative actors within the veterans’ entitlements system will be affected in that decision documents must apply the RMA’s list of factors correctly and consider the cross‑reference provision in s 11 where a listed factor overlaps with another Statement. The RMA’s view of medical science as expressed in s 8 is the evidentiary underpinning for decisions; decision‑makers will therefore treat the enumerated factors as determinative for causation when established and related to relevant service, subject to the broader statutory and procedural framework in the VEA and MRCA.

Who is not covered: the instrument excludes conditions that fall outside the RMA’s textual definition of pilonidal sinus, for example ingrown hair is expressly excluded (s 7(2)(c)). Conditions that do not relate to the listed factors, or where the required temporal relation to relevant service cannot be shown, fall outside the automatic connection the Statement affords. The instrument does not create new entitlements for non‑veteran civilians, nor does it prescribe employment or public health obligations outside the claims context.

This instrument does not create positive duties in the manner of regulatory obligations or criminal prohibitions. Rather, it prescribes the factual foundations that, when established on the balance of probabilities and related to a person’s relevant service, will allow a decision‑maker to find that pilonidal sinus or death from pilonidal sinus is connected with the person’s service. The primary legal "right" the instrument confers is evidentiary: a claimant who establishes one of the specified factors (and satisfies the relationship to service requirement in s 10(1)) can, on the RMA’s medical‑scientific view, be treated as having met the causation connection on the balance of probabilities (s 8, s 9).

Practical obligations on claimants and practitioners flow from the need to establish those factors. For example:

• Where the factor is being overweight or obese, claimants or treating clinicians will need to establish BMI as 25 or greater within the six months before clinical onset or clinical worsening (s 9(2)(b), s 9(5)(b); Schedule 1). The instrument supplies the BMI formula, W/H2, where W is weight in kilograms and H is height in metres (Schedule 1). The practical duty is therefore to provide contemporaneous weight and height records or credible clinical notes applying the formula.
• Where the factor is occupational exposure such as work as a hairdresser or barber, the claimant must show that the occupation was carried out within six months before clinical onset or worsening (s 9(1)(a), s 9(4)(a)).
• Where the factor is cutaneous exposure to animal hair, the claimant must show activities such as milking, shearing, grooming, clipping or slaughtering animals within six months before onset or worsening (s 9(1)(b), s 9(4)(b); Schedule 1).
• Where the factor is prolonged seated driving, the claimant must establish an average of at least 20 hours per week for at least three months within the six months before onset or worsening (s 9(2)(a), s 9(5)(a)). Practically, that requires aggregation of driving or passenger hours over a relevant period.
• Where the factor is inability to shower or bathe more than twice weekly for a continuous four weeks within the six months before clinical onset or worsening, the claimant must provide evidence capable of satisfying that factual allegation (s 9(3), s 9(6)).
• The instrument includes inability to obtain appropriate clinical management as an independent factor (s 9(7)). Establishing this will require evidence that appropriate care was sought but not available, a factual showing that is open to contest.

Decision‑makers must also apply relationship rules. Every factor relied upon must be related to the relevant service rendered by the person (s 10(1)). Subsections 9(4) to 9(7) are limited to material contribution to, or aggravation of, pilonidal sinus where the condition pre‑existed relevant service or was contracted before or during but did not arise out of the service (s 10(2)). That constrains the situations in which these subsections can be invoked.

Rights of cross‑reference. If a factor in s 9 refers to an injury or disease covered by another Statement of Principles, the other Statement applies according to its terms (s 11). Practitioners must therefore check whether a factor connects to a different Statement and ensure the relevant Statement’s terms are followed.

No penalties or enforcement powers are created against persons for failing to comply. The instrument is evidence‑focussed; compliance consequences are procedural: inability to establish the enumerated factors reduces the likelihood of a favourable causation finding in a claim decision.

The Statement of Principles contains no penal provisions and confers no enforcement powers. It neither creates offences nor prescribes fines, imprisonment, administrative sanctions, or compliance orders. The instrument’s legal force is evidentiary: it specifies the factors that the Repatriation Medical Authority, on the evidence it considered, regards as sufficient to establish a causal connection between pilonidal sinus (or death from pilonidal sinus) and relevant service on the balance of probabilities (s 8, s 9).

Consequences for non‑establishment of factors are procedural rather than punitive. If a claimant cannot establish one of the listed factors, or cannot show that the factor was related to relevant service as required by s 10(1), the Statement provides no automatic finding of connection. That will affect entitlement outcomes under the VEA/MRCA framework; but the Statement itself does not prescribe the mechanics for award, denial, or review. Those procedures are governed by the VEA, MRCA and administrative processes external to the instrument. The instrument does not purport to set administrative review pathways, appeal rights, or time limits; those remain functions of the statutes under which claims are made.

Enforcement risks and decision uncertainty arise from evidential questions. Parties contesting causation in claims will focus on whether the specific temporal and factual requirements in s 9 and s 10 are satisfied. The instrument’s factors are precise in certain respects, for example the BMI threshold and the driving hours threshold, which gives decision‑makers objective anchors. Other factors are more factually and contextually contested, such as "inability to obtain appropriate clinical management" (s 9(7)) and "inability to shower or bathe more than two times per week" (s 9(3), (6)). Because the Statement does not prescribe evidentiary standards beyond the balance of probabilities and does not mandate specific documentary forms, claimants and administrators must rely on general evidentiary practice under the VEA/MRCA to prove these facts.

The Statement does guide decision‑making enforcement in the sense that if a listed factor is established and related to relevant service, then causation may be found without further medical complexity. Conversely, absence of those factors places a greater evidentiary burden on claimants to demonstrate connection by other means. The instrument also reserves space for interactions with other Statements of Principles: where a factor relates to another injury or disease covered by a different Statement, the other Statement applies according to its terms (s 11), which may entail alternative or additional causation factors.

This instrument is an RMA determination under subsection 196B(3) of the VEA (s 3) and is expressly aimed at claims under defined provisions of the VEA and the MRCA (s 5). It does not operate in isolation; its legal effect is to inform causation assessments within the statutory claims frameworks of those Acts. The instrument itself does not restate or amend the procedural or substantive entitlements found in the VEA or MRCA. It functions as an evidentiary tool decision‑makers will apply when determining whether pilonidal sinus or death from pilonidal sinus is connected with relevant service.

Interplay with prior RMA instruments is explicit. The instrument repeals the earlier Statement of Principles concerning pilonidal sinus No. 72 of 2010 (s 4). That repeal means the 2019 Statement replaces the prior causation factors in claims decided from its commencement date (s 2). Practitioners handling claims lodged around the repeal/commencement should note the 25 March 2019 operative date.

Interplay with other Statements of Principles is governed by s 11. If a factor listed in s 9 refers to an injury or disease that is itself the subject of another Statement of Principles, that other Statement applies according to its own terms as in force from time to time. Practically, this means decision‑makers must cross‑reference the relevant Statements and apply the applicable causation criteria in the other Statement if the factual factor invokes another injury or disease. The instrument therefore does not preclude reliance on adjacent RMA determinations; it defers to them where overlap exists.

The instrument also references international medical classification but limits its legal application to the textual definition provided. It notes that while pilonidal sinus attracts ICD‑10‑AM code L05, for applying the Statement the meaning is that given in s 7(2) (s 7(3)). The instrument defines “ICD‑10‑AM code” by reference to the 2017 Tenth Edition Australian Modification (s 7(4)). This means that codification alone is not determinative for claims; the statutory definition governs.

Because the Statement is confined to specifying causation factors, its relationship to other legal requirements such as evidentiary rules, procedural time limits, entitlement machinery, and review or appeal processes is indirect. Those aspects remain governed by the VEA and MRCA and associated administrative law. The Statement imposes no statutory duties that would directly interact with employment, workers compensation, public health, or criminal laws. Where factors such as occupational exposure or inability to obtain clinical management overlap with non‑VEA/MRCA regulatory regimes, the Statement does not address those regimes; it merely identifies factual scenarios that are relevant for RMA causation assessments.

This instrument supersedes and repeals the earlier RMA Statement of Principles concerning pilonidal sinus No. 72 of 2010 (s 4). The current instrument is dated 1 March 2019 and commences 25 March 2019 (s 2 and front matter). The text contains no other amendment records, transitional provisions or savings clauses beyond the explicit repeal. The Schedule and the main body provide the operative definitions and factors for application from the commencement date.

Because the instrument is a stand‑alone RMA determination under subsection 196B(3) of the VEA, further amendments would be made by subsequent RMA determinations or legislative change under the VEA. The instrument itself does not establish a periodic review schedule or sunset provision. The only amendment history recorded within the instrument is the repeal of the earlier 2010 Statement and the dates of making and commencement.

Practitioners should be attentive to the fact that s 11 contemplates the operation of other Statements of Principles "as in force from time to time." That phrase signals that other RMA determinations may be updated independently, potentially affecting the cross‑reference relationships in future. The 2019 Statement will therefore operate alongside the contemporaneously in force Statements; if those other Statements are amended later, their changed terms will govern any cross‑reference invoked under s 11.

No transitional arrangements are specified in the instrument for claims that straddle the repeal/commencement date. The instrument’s commencement clause simply sets the operative date (s 2). How decision‑makers treat claims with clinical events spanning the repeal date will be a matter for statutory interpretation and administrative practice under the VEA and MRCA rather than the instrument itself.

The instrument’s text contains no record of litigation or judicial consideration. It does not cite cases, nor does it provide any account of judicials tests or precedential authority being applied to it. As a Statement of Principles determined under subsection 196B(3) of the VEA, it is intended to be an administrative instrument used by decision‑makers in claims under the VEA and MRCA; disputes about its application will arise within the claim, review and appeal processes established by those statutes and the general administrative law framework.

Because the instrument neither creates penalties nor prescribes enforcement mechanisms, litigation issues that could arise from its application are procedural and factual. Potential litigation points, to the extent suggested by the instrument, include:

• Whether a claimant has established a specified factor within the temporal windows required by s 9 and whether that factor can be related to relevant service within the meaning of s 10(1).
• Whether subsections 9(4) to 9(7) are available in a particular case, given the constraint in s 10(2) that they apply only to material contribution or aggravation where the pilonidal sinus was suffered or contracted before or during relevant service but did not arise out of that service.
• Whether a factor pleaded in s 9 triggers the application of another Statement of Principles under s 11 and, if so, how that other Statement’s terms operate in the particular factual matrix.

The instrument itself does not define procedural avenues for resolving disputes about factual findings such as averages of driving hours, BMI at specified times, cutaneous exposure activities, or inability to obtain clinical management. Those procedural avenues are governed by the VEA, MRCA and the administrative review and judicial review regimes outside this instrument. The Statement therefore frames litigation risk and focus rather than providing rules for litigation itself.

Absent further authoritative decisions or cited cases in the text, there is no litigation history to report in connection with this particular Statement. Practitioners should monitor administrative decisions and judicial reviews of VEA/MRCA claim decisions for future jurisprudence on the application of these factors.

The instrument contains several precise thresholds, and those precise measures generate evidential and procedural "gotchas" that practitioners and claimants must watch for.

Temporal windows are tight and event‑specific. Many factors require events to occur within the six months before “clinical onset” or “clinical worsening” (s 9). Claimants must therefore identify and establish dates for clinical onset and clinical worsening. The instrument uses those clinical markers but does not define them; the lack of definition means disputes may arise about what constitutes clinical onset or clinical worsening in an individual’s medical record. Practitioners should be aware that the RMA’s factors are tied to those moments and not to broader or vaguer time frames.

Objective thresholds can be double‑edged. The BMI threshold of 25 or greater is an objective anchor (Schedule 1). That clarity benefits claimants who have contemporaneous weight/height records, but it disadvantages those without such records. The Schedule provides the BMI formula, W/H2, yet it does not specify whether self‑reported height and weight suffice or whether contemporaneous clinical records are required. Similarly, the driving threshold is numerical , an average of at least 20 hours per week for a period of at least three months within the six months before clinical onset or worsening (s 9(2)(a), s 9(5)(a)) , but the instrument does not prescribe how averages should be computed or what records are acceptable.

Subjective and open‑ended factors will be contested. The instrument lists “inability to obtain appropriate clinical management for pilonidal sinus” as a factor (s 9(7)) but provides no further elaboration. This phrase will require fact‑intensive proof: what constitutes "appropriate" clinical management, what attempts were made, whether systemic barriers or personal choices were determinative. Decision‑makers may treat this as a discretionary, contextual factor, opening space for adversarial dispute.

Hygiene criteria are factual and potentially intrusive. The inability to shower or bathe more than twice weekly for a continuous four weeks within six months before onset or worsening is a stated factor for sacrococcygeal and umbilical regions (s 9(3), s 9(6)). Proving a lack of showering/bathing frequency raises evidentiary challenges and privacy issues. The instrument does not indicate what evidence will suffice, nor does it explain whether temporary or involuntary inability (for example due to operational deployment conditions) is treated differently from voluntary behaviour.

Anatomical specificity matters. Factors differ by anatomical site. For hand or foot disease the RMA focuses on hairdressing and animal hair exposure (s 9(1), s 9(4)). For sacrococcygeal disease the RMA focuses on prolonged sitting and BMI (s 9(2), s 9(5)). For sacrococcygeal and umbilical regions it includes hygiene constraints (s 9(3), s 9(6)). Errors pleaders commonly make include asserting a factor relevant to a different anatomical site. Practitioners must align factual allegations to the anatomical site specified in s 9.

Cross‑reference traps. Section 11 requires application of another Statement of Principles if a factor in s 9 refers to an injury or disease covered by that other Statement. Failing to identify and apply the correct cross‑referenced Statement may lead to incorrect causation analyses. Practitioners must review the wider catalogue of RMA Statements to ensure proper cross‑application.

ICD code is not the definitional touchstone. The instrument states that while pilonidal sinus attracts ICD‑10‑AM code L05, the meaning for the Statement is the textual definition in s 7(2) (s 7(3)). Reliance on ICD coding alone without mapping the clinical presentation to the instrument’s definition can mislead claimants and clinicians.

Pre‑existing disease limitations. Subsections 9(4) to 9(7) only apply to material contribution or aggravation where the pilonidal sinus was suffered or contracted before or during relevant service but did not arise out of that service (s 10(2)). Practitioners must be careful when invoking these subsections; they are not available to establish an original disease that arose out of service.

No procedural or evidentiary templates. The Statement provides factors but not the form or type of evidence required to prove them. That absence leads to uncertainty about what decision‑makers will accept as sufficient proof, especially for behavioural factors and inability to obtain management. Practitioners should plan for the likely need to assemble robust documentary and clinical evidence.

Death causation complexity. The Statement includes death from pilonidal sinus where the pilonidal sinus contributed to a terminal event (s 7(5)). Establishing contribution to terminal events such as pneumonia or respiratory failure (Schedule 1) may require complex medico‑legal argumentation about proximate and contributory causes, beyond the straightforward establishment of a listed factor. The Statement does not prescribe an analytic method for apportioning contribution.

For claimants and advisers the instrument forecloses simple box‑ticking and demands evidentiary alignment with the specific factors and temporal rules. Compliance means assembling documentation and medical evidence mapped to the exact requirements of s 9 and demonstrating that any relied factor is related to the person’s relevant service as required by s 10(1). Below are concrete, source‑grounded steps informed solely by the instrument’s content.

1. Identify the anatomical site and event type

• Establish whether the claim concerns pilonidal sinus of the hand or foot, sacrococcygeal region, umbilical region, or death from pilonidal sinus. Each anatomical site has distinct factors in s 9. Also determine whether the claim concerns clinical onset or clinical worsening, as timing clauses differ for onset and worsening (s 9(1)-(6)).

2. Map factual allegations to the correct factor

• For hand/foot claims, prepare to prove one of: (a) employment as a hairdresser or barber within the six months before clinical onset/worsening (s 9(1)(a), s 9(4)(a)), or (b) cutaneous exposure to animal hair via milking, shearing, grooming, clipping or slaughtering animals in the six months before onset/worsening (s 9(1)(b), s 9(4)(b); Schedule 1).
• For sacrococcygeal claims, prepare to prove either: (a) average seated driving/passenger time of at least 20 hours per week for at least three months within six months before onset/worsening (s 9(2)(a), s 9(5)(a)); or (b) BMI of 25 or greater within six months before onset/worsening (s 9(2)(b), s 9(5)(b); Schedule 1).
• For sacrococcygeal and umbilical claims, prepare to prove inability to shower or bathe more than twice weekly for at least four continuous weeks within six months before onset/worsening (s 9(3), s 9(6)).
• Consider whether inability to obtain appropriate clinical management applies (s 9(7)) and be ready to document attempts to access care.

3. Establish timing: clinical onset and clinical worsening

• Precisely date the clinical onset and any clinical worsening in medical records. Because the instrument ties factors to events "within the six months before the clinical onset" or "within the six months before the clinical worsening" (s 9), contemporaneous clinical records establishing those dates are high value evidence. If dates are ambiguous in records, obtain treating clinician statements clarifying when onset and worsening occurred.

4. Produce contemporaneous objective evidence where thresholds are defined

• BMI: supply contemporaneous clinical measurements of height and weight or clinic notes from within the relevant six month window. Use the BMI formula provided in Schedule 1, W/H2, to calculate BMI and demonstrate that it equals or exceeds 25 for the period claimed.
• Driving hours: compile rosters, logbooks, vehicle records, employer statements or other documentation showing average weekly hours spent driving or as a seated passenger over the relevant three month period. Where employers maintain electronic or payroll records, secure copies covering the period.
• Occupational exposure: produce employment records, tax records, trade certificates, employer letters, or contemporaneous diaries showing work as a hairdresser or barber within the six month window (s 9(1)(a), s 9(4)(a)). For animal hair exposure, supply statements, rosters, or agricultural records demonstrating activities such as milking, shearing, grooming, clipping or slaughtering animals (Schedule 1).

5. Document personal circumstances for behavioural or access factors

• Hygiene constraints: obtain documentary evidence supporting an inability to shower or bathe more than twice weekly for the required four week continuous period. Where the inability arose from operational deployment, facility limitations, remote posting, or housing circumstances, obtain military records, deployment logs or facility reports corroborating the conditions.
• Inability to obtain appropriate clinical management: collate appointment records, referral letters, clinic correspondence, evidence of waiting lists, or communications showing attempts to obtain care and the reasons care was not delivered. The Statement provides no template; objective contemporaneous documentation of attempts to access care is therefore essential.

6. Relate factors to relevant service

• Every factor relied upon must be related to relevant service as defined in Schedule 1 (relevant service includes eligible war service, defence service excluding hazardous and British nuclear test defence service, or peacetime service under the MRCA). Establish the nexus between the factor and the service period. Provide service records, postings, and other documents that place the claimant in the environment or role alleged to have produced the factor during the relevant time window.

7. Address cross‑reference obligations

• If a factor refers to another injury or disease that has its own RMA Statement, apply the other Statement’s terms as required by s 11. Identify any cross‑referenced Statements early and compile evidence that satisfies both the pilonidal sinus Statement and the cross‑referenced Statement.

8. Prepare medico‑legal evidence

• Obtain treating clinicians’ reports that apply the instrument’s definitions and thresholds, explicitly stating dates of clinical onset and worsening, BMI calculations if applicable, and the clinician’s view about the causal relationship between the factor, the service, and the pilonidal sinus. For death claims, secure cause of death documentation and clinicians’ opinions about the contribution of pilonidal sinus to terminal events as contemplated by s 7(5) and the Schedule’s definition of terminal event.

9. Anticipate evidentiary challenges and prepare rebuttals

• For objective thresholds, retain source documentation; for subjective factors, seek corroboration from third parties and contemporaneous documents. Where imputations of personal behaviour are relevant (for example hygiene frequency), prepare sensitive but probative evidence that establishes the factual claim while attending to privacy concerns.

10. Draft pleadings and submissions aligned to the instrument

• When presenting the claim, structure the causation submission to align each pleaded fact with the precise subsection of s 9, cite s 10 regarding relation to relevant service, use the BMI formula in Schedule 1 where BMI is relied upon, and if applicable, identify any other Statement of Principles invoked under s 11. Use exact wording from the instrument to avoid mischaracterising factors.

11. Monitor for amendments and interplay

• Because s 11 ties application to other Statements "as in force from time to time", review contemporaneous RMA Statements for relevant changes. The current instrument repealed the 2010 Statement and commenced on 25 March 2019 (s 4, s 2); future RMA determinations may alter causation frameworks.

These steps convert the instrument’s textual factors into an evidentiary plan. The Statement provides clear thresholds for some elements and leaves others open to contextual proof. In every instance the claimant must show that the relevant factor occurred within the defined temporal window and was related to the person’s relevant service in the sense required by s 10(1).