Statement of Principles concerning retinal burn (Balance of Probabilities) (No. 26 of 2023)

The instrument turns a medical concept , acute photic injury to the retina , into a legal concept for compensability under veterans' schemes. Central definitions and conceptual boundaries are in s 6 and the Schedule 1 Dictionary.

Retinal burn is defined as "an acute photic injury to the retina of the eye from optical radiation passing through the eye’s optical system" (s 6(2)(a)). Optical radiation is noted to include ultraviolet light, visible light and infrared light (note to s 6(2)). The definition then enumerates examples that are treated as retinal burn: arc welding radiation, atomic bomb flash, direct gazing into the sun and non-therapeutic laser exposure (s 6(2)(b)(i)-(iv)). The definition also lists specific exclusions: electrical injury to the eye (including lightning), external burns where retinal injury is only a component of simultaneous internal and external eye burns, intended or accidental retinal burns from operating microscope optical radiation, ionising radiation apart from ultraviolet light, and temporary visual effects such as dazzle, glare, after images and flash blindness (s 6(2)(c)(i)-(v)).

Two legal thresholds structure causation. First, the standard of proof is balance of probabilities, invoked in the instrument title and explained as the RMA's view that it is "more probable than not" that retinal burn and death from retinal burn can be related to relevant service (s 7). Second, s 8 establishes a requirement that at least one enumerated factor must exist for an accepted causal link to relevant service. Those factors are exposure-linked clinical phenomena, namely ocular exposure to laser, arc welding radiation, nuclear explosion radiation, or sun-viewing that resulted in a visual field defect or scotoma at the time of clinical onset, plus a separate factor of inability to obtain appropriate clinical management for retinal burn (s 8(1)-(5)).

Temporal and service relationship constraints are in s 9. Each factor in s 8 must be related to the person's relevant service (s 9(1)). The inability-to-obtain-management factor in s 8(5) is limited to claims of material contribution to, or aggravation of, retinal burn where the burn pre-existed or occurred during service but did not arise out of service (s 9(2)).

The instrument links to other Statements of Principles through s 10. If a factor in s 8 refers to an injury or disease that is covered by another Statement of Principles made under s 196B(3) of the VEA, then the factors in that other Statement apply as in force from time to time. This creates a mechanism for overlapping or related conditions to be considered under the terms of their own SOPs.

"Relevant service" is defined in the Schedule to mean eligible war service (other than operational service), defence service (other than hazardous service and British nuclear test defence service) under the VEA, or peacetime service under the MRCA. The dictionary also defines "terminal event" by reference to proximate or ultimate causes of death including pneumonia, respiratory failure, cardiac arrest, circulatory failure and cessation of brain function (Schedule 1). These definitions calibrate the instrument's reach in relation to types of service and forms of death that can be linked to retinal burn.

This instrument targets two discrete groups of actors: claimants (veterans and members of the Forces) who seek statutory benefits where retinal burn is alleged to be connected to relevant service, and administrators and decision-makers (the RMA and responsible agencies) who apply Statements of Principles in adjudicating those claims.

Claimants: The instrument applies to persons making claims that are within the scope of section 120B of the VEA or section 339 of the MRCA (s 4). The Schedule defines "relevant service" narrowly: eligible war service other than operational service, defence service other than hazardous service and British nuclear test defence service under the VEA, and peacetime service under the MRCA (Schedule 1). That definition means persons whose service consists of operational deployments, hazardous service, or British nuclear test defence service are not captured by the "relevant service" concept used here, for the purposes of this instrument. A claimant must show at least one of the enumerated factors in s 8 and that the factor is related to relevant service (s 8, s 9). Where the retinal burn pre-dated service or occurred during service but did not arise out of service, the claimant can rely only on the inability-to-obtain-appropriate-clinical-management factor in s 8(5), and then only as to material contribution or aggravation (s 9(2)).

Service organisations and clinicians: The instrument affects the evidence and records that service medical facilities, treating clinicians and others may need to produce and retain. The s 8 factors pivot on clinical phenomena , a "visual field defect or scotoma" contemporaneous with the clinical onset of retinal burn , and on particulars of exposure events (laser, arc welding radiation, nuclear flash, sun-viewing). Clinicians and medical officers will need to document clinical onset, the presence of scotoma or visual field defect, and the temporal relationship to exposure to support or contest claims.

Decision-makers and agencies: The RMA uses the instrument to inform the legal-medical standard for causation. The instrument also instructs adjudicators to apply other Statements of Principles where a factor in s 8 refers to an injury or disease already the subject of another SOP (s 10). Administrators adjudicating claims under s 120B VEA or s 339 MRCA must therefore (a) interpret the s 8 factors against the claimant’s evidence; (b) determine whether those factors are related to the person's relevant service (s 9); and (c) integrate other SOPs where relevant (s 10). The RMA’s view in s 7 constitutes the medical‑scientific basis for causation; administrators will use that view as the starting point for applying statutory causation tests.

Other affected parties: Employers or supervisors within defence or allied civilian workplaces that expose personnel to lasers, welding arcs or sun-gazing activities may be affected indirectly, because occupational records, protective equipment logs, training records and incident reports could become material evidence in claims. The instrument does not regulate workplace safety directly; it determines when retinal burn is a compensable connection to relevant service.

Who does not fall within scope: The instrument excludes specific injury types from the definition of retinal burn (s 6(2)(c)), so persons whose ocular injury is an electrical injury, external burn with internal/external components, microscope operating radiation injury, injury from ionising radiation other than UV, or temporary visual disturbances, are excluded from claims under this SOP and will need to look elsewhere for coverage if eligible.

This instrument does not itself create administrative duties in the way a statute does, but it prescribes the causal and evidentiary framework that creates operational duties for claimants, clinicians and decision-makers in the determination of entitlement claims. Rights and duties arise from how the instrument is used under the VEA and MRCA.

Claimant duties and obligations (practical, evidentiary): To establish on the balance of probabilities that retinal burn is connected with relevant service, a claimant must establish at least one of the factors in s 8 and that the factor is related to relevant service (s 8, s 9(1)). Practically this gives rise to an obligation on claimants to produce evidence that supports the existence of an exposure event described in s 8(1)-(4) or evidence relevant to s 8(5). The instrument makes clear that the clinical threshold is a "visual field defect or scotoma" at the time of the clinical onset of the retinal burn (s 8(1)-(4)), so claimants need clinical documentation that ties a particular exposure to such findings at the time of clinical onset. For pre-existing injury claims (s 9(2)), claimants relying on s 8(5) will need to establish both the prior retinal burn and the inability to obtain appropriate clinical management that materially contributed to or aggravated the condition.

Clinical and record-keeping duties (practical): Treating clinicians and health services have a practical duty to document the nature and timing of ocular injuries, the presence of visual field defects or scotomas, and any contemporaneous history of exposure to lasers, welding arcs, solar viewing or nuclear flash. The instrument’s notes highlight that arc-welding retinal burns may be masked by corneal and conjunctival burns and that laser exposure risks increase with magnifying devices (s 8 notes), signalling the evidentiary importance of detailed clinical records.

Adjudicator duties: Decision-makers applying the VEA and MRCA must use the RMA's Statement of Principles as the medical-scientific basis for causation determinations (s 7). They are obliged to check that at least one of the s 8 factors is present and related to the person’s relevant service (s 8, s 9). Where a factor in s 8 also refers to an injury or disease covered by another SOP, adjudicators must apply the other SOP’s factors as in force from time to time (s 10). The RMA’s instrument thus creates administrative duties to align determinations with the specified factors.

Rights: Claimants have the procedural right to have their retinal burn claims assessed against this Statement of Principles under the statutory framework referred to in s 4. If a claimant can establish a qualifying factor and relevant service link on the balance of probabilities, that will satisfy the causal element as defined in this instrument. The instrument also recognises death as attributable to retinal burn when a terminal event was contributed to by the retinal burn (s 6(3)), giving claimants or dependants a route to have death considered as service-connected where the causal chain includes retinal burn.

Limits on duties and rights: The instrument creates boundaries. Exclusions listed in s 6(2)(c) remove certain conditions from this SOP’s scope. The inability-to-obtain-care factor in s 8(5) is narrowly available only where the retinal burn was suffered or contracted before or during (but did not arise out of) relevant service, and then only as to material contribution or aggravation (s 9(2)). The standard of proof is balance of probabilities (s 7), which is less than a criminal standard but still requires a preponderance of evidence.

Discretion points: The instrument leaves scope for evaluative judgment. Determining whether a "visual field defect or scotoma" existed at the time of clinical onset, whether exposure was of the type specified, whether inability to obtain appropriate clinical management existed and whether a factor is related to relevant service all involve factual assessments that decision-makers must carry out. The instrument does not prescribe documentary formats or precise evidentiary thresholds beyond the enumerated factors and definitions.

The Statement of Principles itself does not prescribe penalties, criminal sanctions or administrative fines. It is a medical-legal instrument used by the RMA to guide causation assessments in veterans' entitlements and compensation claims under the VEA and the MRCA. Enforcement consists of how decision-makers apply the instrument in adjudicative processes established by those Acts.

Operational enforcement mechanism: The instrument functions as a binding medical-scientific reference for determinations made under the statutory provisions cited in s 4 (section 120B of the VEA and section 339 of the MRCA). When an entitlement decision is made under those Acts, adjudicators will rely on the RMA's Statement of Principles to assess whether retinal burn is connected with relevant service. If a claimant cannot establish the presence of at least one of the factors in s 8 and the required service relationship in s 9, the claim will not meet the causal standard set by this SOP and is likely to be refused on causation grounds.

Administrative review and appeals: The instrument does not itself set out appeal or review pathways. Remedies and procedural enforcement are instead governed by the VEA, the MRCA and related administrative review schemes. A claimant who disagrees with an entitlement decision that turns on the application of this SOP would pursue review or appeal routes available under those Acts. The instrument does not modify or create new appeal rights; it supplies the medical framework that tribunals and courts will treat as the RMA’s contemporaneous clinical view.

Discretion and risk of inconsistent application: The instrument leaves fact-intensive judgments to decision-makers, creating a risk of variance in application across cases. For example, adjudicators must determine whether a specified exposure caused a "visual field defect or scotoma" at the clinical onset (s 8). The instrument’s notes and exclusions (s 6(2)(c), s 8 notes) flag clinical complexities such as masking of retinal onset by corneal burns in arc-welding cases and increased laser risk from magnifying devices. These complexities can lead to disputes about whether the factual preconditions in s 8 are satisfied.

No criminal enforcement in the instrument: There is no civil penalty regime or criminal sanction referenced in the instrument. It neither establishes regulatory offences nor directs agencies to impose penalties. Its effect on a claimant’s entitlement is procedural and evidentiary: it operates as a gate for recognizing service-connection for retinal burn and deaths attributable to it.

Documentation enforcement: Where entitlement depends on the application of the instrument, timely and probative medical documentation is practically enforceable , that is, claims without appropriate documentation of scotoma or exposure will likely fail to establish the necessary factors. The instrument thereby channels enforcement through evidentiary burdens in the entitlement process rather than through separate penal measures.

The Statement of Principles is explicitly a tool for use within the framework of the VEA and the MRCA. Section 3 records that it is made under subsection 196B(3) of the VEA, and s 4 states that it applies to claims to which section 120B of the VEA or section 339 of the MRCA applies. The instrument therefore functions as an evidentiary and causation standard within those Acts’ decision-making processes, rather than as an autonomous statutory right or obligation.

Interaction with other Statements of Principles: Section 10 creates an express interaction rule. If a factor in s 8 refers to an injury or disease that is the subject of another Statement of Principles made under subsection 196B(3) of the VEA, then the factors in that other Statement apply "in accordance with the terms of that Statement of Principles as in force from time to time." This is a formal cross-reference mechanism that allows overlapping medical conditions to be governed by the more specific or separately developed SOP wherever applicable. It means adjudicators must identify when an s 8 factor implicates another SOP and then apply the factors of that other instrument rather than duplicating or substituting their own medical judgment.

Relation to definitions and exclusions: The instrument’s Dictionary (Schedule 1) defines "relevant service" in a particular way (eligible war service other than operational service; defence service other than hazardous service and British nuclear test defence service; and peacetime service under the MRCA). That definition limits which service types can be the basis for a positive causal link under this SOP. Where a claimant’s service falls outside the Schedule’s definition of relevant service, entitlement decisions under the VEA or MRCA still turn on the statutory tests in those Acts, but this particular SOP’s factors will not provide the causal gateway it otherwise would.

Exclusions that channel claimants elsewhere: The instrument excludes certain injury mechanisms from the retinal burn definition (s 6(2)(c)), for example electrical injury to the eye, operating microscope radiation, ionising radiation apart from ultraviolet light, and external burns where retinal burn is only a component. Those exclusions mean that claims arising from those mechanisms will not be adjudicated as retinal burn under this SOP; claimants and decision-makers must look to other parts of the VEA/MRCA framework, or to other SOPs, for relevant causal rules.

Interface with statutory causation regimes: The instrument states that it is to be used in claims to which s 120B VEA or s 339 MRCA apply. The precise statutory causation regimes, procedural rules and appeal paths in those sections are not reproduced in the instrument. Adjudicators must therefore apply the SOP within the broader statutory tests and administrative processes in the VEA and the MRCA. The SOP supplies RMA’s medical-scientific view that informs the causation element of those statutory tests.

Administrative and evidentiary interaction: The instrument's requirements (presence of specified exposure-related clinical findings, or inability to obtain appropriate clinical management in limited circumstances) interact with evidentiary procedures in claims processing. For example, the SOP’s reliance on a "visual field defect or scotoma" at clinical onset requires adjudicators to examine contemporaneous clinical records, exposure documentation and material evidence of service circumstances. Records kept under other laws or regulations , Defence instructions, occupational health records, safety incident reports , may therefore become relevant evidence in applying the SOP, even though the SOP does not itself compel their production.

No change to other legal liabilities: The instrument does not alter criminal, civil or workplace liability regimes. It does not modify duties under occupational health and safety law, nor does it create new tortious liabilities. Its effect is confined to the medical-causation element of entitlement decisions under the VEA and the MRCA.

The instrument itself presents a very short amendment history because it is a single Statement of Principles instrument dated and numbered within 2023. The body of the instrument identifies the following provenance and temporal markers.

• Instrument title and number: The instrument is the Statement of Principles concerning retinal burn (Balance of Probabilities) (No. 26 of 2023) (page header and s 1).
• Date: The instrument is dated 24 April 2023 (cover text). The signature block indicates the Common Seal of the Repatriation Medical Authority was affixed at the direction of Professor Terence Campbell AM, Chairperson (cover text).
• Commencement: The instrument commences on 23 May 2023 (s 2).
• Authority: The instrument is made under subsection 196B(3) of the Veterans' Entitlements Act 1986 (s 3).

The instrument contains no in-text amendments, transitional provisions, repeal clauses, or references to prior versions of an SOP on retinal burn. It also does not list earlier Statements of Principles that have been revoked or replaced. There is no internal text indicating amendment dates after commencement or that the instrument supersedes a prior SOP. The Schedule 1 dictionary contains only definitions and no historical notes.

Because the instrument is described as No. 26 of 2023, this numbering indicates its place in a sequence of instruments made in that calendar year, but the instrument itself does not provide a legislative timeline beyond the date and commencement provision cited above. There are no schedules of amendment, no marked changes, and no footnotes indicating subsequent modification.

Users seeking the instrument’s amendment history beyond what is in the instrument will need to consult the legislative register or the RMA’s published instruments list for any later instruments that expressly amend, replace or revoke it. The instrument’s s 10 cross-reference contemplates that other SOPs may be varied "as in force from time to time", which acknowledges that related SOPs may be amended, but this instrument contains no amendment record itself.

The instrument does not record any litigation history. There are no cases, judicial decisions, tribunal determinations, or appeals referenced in the text. It does not cite authority to prior judicial pronouncements, nor does it reproduce any extracts from decisions.

Because Statements of Principles are instruments used by tribunals and decision-makers, they may be the subject of argument in review proceedings under the VEA and the MRCA. However, the instrument itself contains no account of litigation that has tested it in courts or administrative tribunals. It does not assert that it has been considered or endorsed by any judicial body, nor does it purport to summarise case law.

Practitioners seeking litigation history that relates to retinal burn causation or the application of RMA Statements of Principles will need to search tribunal and court databases for decisions that reference this specific instrument (No. 26 of 2023) or that address retinal burn causation issues in the context of the VEA and MRCA. The instrument provides the operative text that decision-makers will use; any litigation history will be found outside the instrument in administrative review determinations and judicial records.

In the absence of cases cited within the instrument, this instrument must be treated as a primary RMA medical statement with no internal record of adjudicative testing. This is relevant for practitioners who evaluate how a court or tribunal might receive or interpret the RMA’s statements, because appellate or judicial treatment might refine or challenge how the SOP’s factors are applied. As of the instrument’s own text, no such judicial consideration is recorded.

1. Narrow causal factors required: The instrument requires at least one of the factors listed in s 8 to be present, and each factor specifies that the exposure must have resulted in "a visual field defect or scotoma of the affected eye at the time of the clinical onset of retinal burn" (s 8(1)-(4)). Claims that rely on exposures but lack contemporaneous clinical documentation of a scotoma or visual field defect at clinical onset risk failing under this SOP. The phrase "at the time of the clinical onset" tightly couples exposure with documented clinical manifestation.

2. Exclusions carve out common mechanisms: The definition of retinal burn expressly excludes electrical injury to the eye (including lightning), external burns where retinal burn is only a component, operating microscope radiation injuries, ionising radiation apart from ultraviolet light, and transient visual disturbances (s 6(2)(c)). If an ocular injury arises from one of these mechanisms, the claimant cannot use this SOP to establish retinal burn as a service-connected condition and must look elsewhere.

3. Differences between "suffered or contracted" and "arise out of": The inability-to-obtain-appropriate-clinical-management factor in s 8(5) is available only where the person's retinal burn "was suffered or contracted before or during (but did not arise out of) the person's relevant service" and then only for material contribution or aggravation (s 9(2)). That is a narrow pathway for pre-existing or non-service-origin conditions; it does not apply where the retinal burn "arose out of" service. Practitioners must categorise the temporal and causal relationship precisely.

4. Masking of retinal onset in arc-welding injuries: The instrument’s note to s 8(2) warns that arc welding retinal burns are often associated with corneal and conjunctival burns (Welder’s flash), and that the clinical onset of the retinal burn would have occurred at the time of the arc welding flash but may have been masked by corneal and conjunctival symptoms. This creates an evidentiary complexity: contemporaneous documentation may record only corneal symptoms, and retrospective linkage to retinal onset may be contested.

5. Operating microscope radiation excluded: Retinal burns that are intended or accidental consequences of operating microscope optical radiation are excluded (s 6(2)(c)(iii)). Operators or surgical staff with ocular injury from microscope exposure cannot rely on this SOP.

6. Ionising radiation limitation: The instrument excludes ionising radiation apart from ultraviolet light (s 6(2)(c)(iv)). Where ocular injury is attributable to ionising radiation other than UV, alternate legal and medical mechanisms must be sought.

7. Scope of "relevant service": The Schedule’s definition of "relevant service" excludes operational service, hazardous service and British nuclear test defence service in respect of different VEA categories, and limits MRCA coverage to peacetime service in the context of this SOP. Practitioners must check the claimant’s service classification before relying on this SOP.

8. Death linkage restricted to contribution by retinal burn: Death is included only "from a terminal event or condition that was contributed to by the person's retinal burn" (s 6(3)). The Dictionary defines "terminal event" as proximate or ultimate causes such as pneumonia, respiratory failure and cardiac arrest. An asserted death-from-retinal-burn claim must demonstrate that the retinal burn contributed to such a terminal event.

9. Cross-application to other SOPs: Section 10 requires that if an s 8 factor refers to an injury or disease covered by another SOP, the other SOP’s factors apply. This can complicate cases where exposures (for example, arc welding or laser injuries) are the subject of separate, more detailed SOPs. Practitioners must identify whether a referenced exposure is governed elsewhere and then apply the correct instrument's factors.

10. Ambiguity in "inability to obtain appropriate clinical management": The instrument does not define "inability to obtain appropriate clinical management," nor does it specify what evidence satisfies this factor. The discretionary assessment of what constitutes "appropriate" care, and whether it was unavailable, creates an evidentiary and administrative risk in s 8(5) cases.

11. Notes create interpretive nuances but not legal rules: The instrument’s notes (for example, the laser and arc welding notes in s 8) explain medical risk factors such as laser power, irradiance and duration of exposure and the increased risk with magnifying devices. Those notes are explanatory and may inform adjudicators, but they do not themselves create additional qualifying factors outside the text of s 8.

12. Standard of proof remains balance of probabilities: The instrument is framed as "Balance of Probabilities" and s 7 records the RMA’s view on the medical-scientific evidence. Practitioners should not conflate this with stricter standards; however, meeting the balance-of-probabilities requirement still requires the factual showings listed in the SOP.

For claimants (veterans, members of the Forces, and their representatives)

• Establish that your claim falls within the statutory remit outlined in s 4. The SOP applies to claims to which section 120B of the VEA or section 339 of the MRCA applies. Confirm the claimant’s service type against the Schedule 1 definition of "relevant service" before relying on this SOP.
• Demonstrate at least one qualifying factor in s 8. For exposures to laser radiation, arc welding radiation, atomic bomb flash, or viewing the sun, the claimant should obtain and supply clinical documentation showing a "visual field defect or scotoma of the affected eye at the time of the clinical onset of retinal burn" (s 8(1)-(4)). Where the retinal burn predates service or occurred during service but did not arise out of service, consider whether inability to obtain appropriate clinical management is relevant under s 8(5) and s 9(2).
• Gather contemporaneous clinical evidence. The instrument’s causal nexus is temporal: it requires evidence that the exposure coincided with clinical onset. Effective clinical records include ophthalmological notes, specialist reports, visual field testing records and any documentation that records scotoma or relevant visual defects at the relevant time. Because the instrument emphasises the timing "at the time of the clinical onset", contemporaneous notes carry particular weight.
• Collate exposure evidence. Obtain incident reports, service logs, occupational records, statements from witnesses, maintenance and usage logs for welding or laser equipment, and details showing whether protective equipment was used. The SOP’s notes identify technical exposure variables (power, irradiance, duration) and risk enhancers (magnifying devices for lasers, masking of retinal signs by corneal burns in welding exposures); practical evidence that speaks to these variables will aid causal linkage.
• If relying on s 8(5) inability-to-obtain-management, document attempts to obtain care. Record dates and descriptions of care sought, referrals, denials, facility closures, or lack of access. Ensure the evidence focuses on whether lack of appropriate management materially contributed to or aggravated the retinal burn, and that the retinal burn was suffered or contracted before or during (but did not arise out of) relevant service (s 9(2)).
• Anticipate exclusions. If the injury arose from electrical injury, operating microscope radiation, ionising radiation other than ultraviolet light, or is a temporary effect (dazzle, glare, after images, flash blindness), this SOP excludes it (s 6(2)(c)). For those cases, seek reference to other SOPs or legal avenues.

For medical practitioners and service medical officers

• Document clinical onset and findings clearly. Given the SOP’s emphasis on a visual field defect or scotoma at the time of clinical onset, clinicians should record the timing of first symptoms, objective test results and any linkage to an exposure event. Note whether corneal/conjunctival symptoms could have masked retinal signs, especially in arc-welding incidents.
• Record exposure details. Where an ocular injury follows occupational or service exposures, record the nature of the exposure (laser, arc welding, sun-gazing, nuclear flash), whether protective equipment was used, whether magnifying devices were involved, and the approximate power/duration where known. This information is material under the SOP’s explanatory notes.
• Preserve contemporaneous records. Because the SOP looks to evidence at "time of clinical onset," contemporaneous documentation is decisive. If follow-up reports differ, keep original records intact and available for claims assessment.

For adjudicators and administrators

• Apply the SOP as the RMA’s medical-scientific basis. Section 7 records the RMA’s view on the available evidence. For claims within s 4’s scope, use the SOP’s factors as the causal gate. Require proof of at least one s 8 factor and establish that the factor is related to the person’s relevant service (s 8, s 9).
• Check for overlap with other SOPs. If an s 8 factor refers to an injury or disease already the subject of another SOP, apply that other SOP’s factors as in force from time to time (s 10). Practically, this requires cross-referencing the RMA’s instrument list to identify governing SOPs.
• Address evidentiary ambiguities explicitly. Where clinical records are equivocal about timing, scotoma presence, or exposure, seek further medical opinion or clarification. Pay particular attention to arc-welding cases where corneal burns may have masked retinal onset, and to laser-exposure cases where indirect reflections or use of magnifying devices may be relevant.
• Interpret "inability to obtain appropriate clinical management" cautiously and document reasoning. The SOP provides no definition; adjudicators should require evidence of attempts to obtain appropriate care and assess whether lack of care materially contributed to or aggravated the condition in line with s 9(2).
• Record findings and reasons. Because the SOP informs entitlement decisions, administrative records should set out how the SOP’s factors were applied to the evidence and how the balance of probabilities was reached.

Practical evidence checklist (consistent with instrument content)

• Ophthalmology/medical notes documenting visual field defect or scotoma, with dates tied to clinical onset.
• Visual field test results, specialist consultations and contemporaneous emergency or clinic records.
• Incident reports, service logs, occupational records relating to welding, laser use, sun-viewing events, or nuclear exposures.
• Records of protective equipment use or lack thereof.
• Medical records demonstrating attempts to obtain care and any documented inability to obtain appropriate treatment (for s 8(5) cases).
• Death records and clinical notes connecting retinal burn to a terminal event where a death claim is advanced (s 6(3) and Schedule 1 definitions of terminal event).

Finally, maintain awareness that this instrument is a statement of medical-scientific opinion formulated by the RMA and that adjudicative determinations under the VEA and MRCA must be made in accordance with statutory processes and evidentiary rules in those Acts.