Statement of Principles concerning retinal burn (Reasonable Hypothesis) (No. 25 of 2023)

The Statement defines a small set of interlocking legal-medical concepts the RMA will apply when assessing claims. Core concepts and their legal significance in this instrument are:

• Retinal burn (s6(2)): legally defined as "an acute photic injury to the retina of the eye from optical radiation passing through the eye’s optical system" (s6(2)(a)). The definition contains inclusions and exclusions (s6(2)(b)-(c)). Named inclusions are arc welding radiation, atomic bomb flash, direct gazing into the sun and non-therapeutic exposure to lasers (s6(2)(b)(i)-(iv)). Explicit exclusions include electrical injury to the eye (including lightning), external eye burns where retinal burn is only a component, intended or accidental retinal burns from operating microscope optical radiation, ionising radiation apart from ultraviolet light, and transient visual disturbances such as dazzle and flash blindness (s6(2)(c)(i)-(v)). The Note at s6 clarifies optical radiation includes ultraviolet, visible and infrared light.

• Death from retinal burn (s6(3) and Schedule definition of "terminal event"): the instrument treats death as part of the condition where a terminal event or condition was contributed to by the retinal burn; a terminal event is defined in the Schedule and lists proximate or ultimate causes such as pneumonia, respiratory failure, cardiac arrest, circulatory failure or cessation of brain function.

• Relevant service (Schedule): the instrument applies only where the factor(s) are related to "relevant service", a term defined to include operational, peacekeeping, hazardous and British nuclear test defence service under the VEA, and warlike and non‑warlike service under the MRCA.

• Reasonable hypothesis and factors (s7-s8): the RMA states the scientific basis for a relationship to service (s7). Section 8 enumerates the minimum factual factors the RMA regards as necessary to raise a "reasonable hypothesis": ocular exposure to laser radiation, arc welding radiation, nuclear explosion radiation, or viewing the sun with the naked eye or an optical instrument, each producing a visual field defect or scotoma of the affected eye at the time of the clinical onset; and inability to obtain appropriate clinical management for retinal burn (s8(1)-(5). Each factor is qualified by clinical notes in the instrument about exposure intensity, protection, and circumstances (s8 notes).

• Interaction with other SOPs (s10): when a factor refers to an injury or disease already covered by another Statement of Principles made under subsection 196B(2) of the VEA, the factors in that other SOP will apply according to their terms. This creates a rule for resolving overlapping medical causalities among SOPs.

These concepts define the evidentiary and definitional boundary for decision-makers. The RMA’s technical definition focuses on optical radiation as the causal mechanism, limits coverage to specified exposures and clinical findings, and excludes other mechanisms and transient phenomena. The Schedule's definitions anchor "relevant service" and "terminal event", which are determinative for scope. The RMA's enunciation of minimum factors establishes what a claimant must at least show to satisfy the "reasonable hypothesis" threshold when invoking this SOP.

This instrument affects persons who lodge entitlement claims under the VEA or MRCA that involve retinal burn or death from retinal burn, and the decision‑makers who assess those claims. The application clause specifies that it applies to a claim to which section 120A of the VEA or section 338 of the MRCA applies (s4). The Schedule defines "relevant service" as operational service, peacekeeping service, hazardous service, British nuclear test defence service under the VEA, and warlike or non‑warlike service under the MRCA (Schedule). Therefore the primary population affected is serving members or veterans whose eye injuries occurred in contexts encompassed by those service categories.

Who decides and who uses the instrument:

• The Repatriation Medical Authority made the instrument under statute (s3). The RMA is the medical body that issues Statements of Principles under s196B(2) of the VEA. The instrument provides medical-evidentiary criteria for use by adjudicators who process claims under the VEA and MRCA. The instrument does not itself adjudicate benefits; rather it supplies the RMA’s view of the medical link for adjudicators to apply when considering whether a reasonable hypothesis of service connection is raised.

Who must supply evidence:

• Claimants who assert retinal burn as related to relevant service must supply or rely upon evidence that meets the factors the RMA sets out (s8). Specifically, claimants will need clinical evidence demonstrating ocular exposure of the kinds enumerated (laser, welding, nuclear flash, sun viewing) that resulted in a visual field defect or scotoma at the time of the clinical onset (s8(1)-(4)), or evidence that appropriate clinical management was unavailable where the retinal burn predated or occurred during service but did not arise out of it (s8(5), s9(2)).

Other affected parties:

• Where a factor in s8 refers to an injury or disease covered by another SOP, that other SOP governs the factors in respect of that injury or disease (s10). This affects claimants whose presentations involve multiple ocular pathologies or where the causal mechanism is commonly addressed under another SOP.

Excluded cohorts:

• Persons with retinal injury resulting from causes expressly excluded by the definition,such as electrical injury, external eye burns, operating microscope exposures, ionising radiation other than ultraviolet, and temporary effects like dazzle,are outside the ambit of this SOP for the purposes of raising a reasonable hypothesis under it (s6(2)(c)). They may be subject to other SOPs or legal pathways, but this instrument does not cover them.

In sum, the instrument governs the evidentiary threshold for claims by certain service categories of members or veterans alleging retinal burn or death from retinal burn, prescribes the medical circumstances that will suffice to raise a reasonable hypothesis, and identifies excluded causes and interactions with other SOPs that may reassign evidentiary expectations.

This instrument does not create statutory duties or rights in the sense of imposing civil obligations or conferring benefits directly; instead it prescribes medical-evidentiary standards that adjudicators must apply when determining whether a reasonable hypothesis exists that links retinal burn or death from retinal burn to relevant service. The operative legal effects derive from its use in the administration of claims under the VEA and MRCA (s3-s4).

What the RMA requires of decision‑makers:

• Decision‑makers considering claims under the VEA and MRCA are provided with the RMA’s authoritative statement of the medical factors that constitute a minimum to raise a reasonable hypothesis (s8). The RMA’s view is recorded as to there being "sound medical‑scientific evidence" for a relationship between retinal burn and relevant service (s7). Administrators must therefore treat the enumerated factors in s8 as the RMA's baseline medical guidance when testing whether the statutory threshold of a reasonable hypothesis is met.

What claimants must establish to invoke the SOP:

• A claimant seeking to rely on this instrument must show at least one of the factors set out in s8. For the exposure-based factors (s8(1)-(4)), the claimant needs evidence of ocular exposure of the specified type and clinical evidence of a visual field defect or scotoma of the affected eye at the time of clinical onset. For the management-based factor (s8(5)), the claimant must show inability to obtain appropriate clinical management, but s9(2) narrows that factor to cases where the retinal burn was suffered or contracted before or during, but did not arise out of, the person’s relevant service.

What is required regarding the relationship to service:

• Any factor relied upon must be related to the person's relevant service (s9(1)). The Schedule defines "relevant service" in specific statutory categories. This creates a conjunctive requirement: the factual factor must exist and that factor must be related to relevant service for the reasonable hypothesis threshold to be satisfied.

Rights of appeal or legal challenge:

• The instrument itself does not set out procedural appeal rights or remedies; those are governed by the VEA and MRCA frameworks to which claims are subject. The instrument instructs on the medical test that should be applied within those statutory decision-making processes.

Cross-application between SOPs:

• Where a factor in s8 refers to an injury or disease that is already the subject of another SOP determined under subsection 196B(2) of the VEA, then the factors in that other SOP apply according to its terms (s10). Decision‑makers must therefore be alert to overlapping SOP coverage and apply the appropriate SOP factors where overlap exists.

Duties not imposed by this instrument:

• The instrument does not impose duties on employers, service providers, or medical practitioners in relation to workplace safety, compensation payments, or clinical practice. It does not create offences or penalties. Its practical duty is to supply a medical yardstick for adjudicators under the VEA and MRCA.

In short, the instrument defines the minimum medical facts necessary to raise a reasonable hypothesis of service connection for retinal burn or related death, constrains how and when those facts are to be related to "relevant service", and cross‑refers to other SOPs where appropriate. The rights and duties it produces are procedural and evidentiary within the statutory claim frameworks rather than new standalone entitlements or duties.

The Statement of Principles instrument itself contains no criminal or civil penalties and does not prescribe enforcement mechanisms. It is a medical-evidentiary instrument made by the Repatriation Medical Authority under subsection 196B(2) of the VEA (s3), intended to be applied within existing administrative processes provided by the VEA and the MRCA (s4). The text contains no provisions imposing fines, offences, or coercive enforcement measures.

How the instrument is enforced in practice:

• Enforcement in the sense of application comes through the decision-making processes under the VEA and MRCA for claims to which the instrument applies. The instrument sets out the factors that must exist to raise a reasonable hypothesis connecting retinal burn or death from retinal burn to relevant service (s8). Administrative decision-makers under the VEA and MRCA will apply these factors when assessing whether the reasonable hypothesis threshold is met for entitlement purposes. The instrument itself does not specify procedural remedies, review pathways or sanctions for non-compliance with the instrument’s standards; those procedural elements are governed by the primary legislation and administrative rules of the claim-handling agencies.

Evidentiary consequence rather than punitive consequence:

• The consequence of failing to meet the RMA’s factors is evidentiary: a decision-maker may find that a reasonable hypothesis is not raised and consequently proceed under the VEA/MRCA framework as appropriate. The instrument does not set out consequences such as penalty payments for false claims or requirements for corrective action by third parties. It does not authorise compulsory inspections, penalties for employers, or regulatory enforcement steps.

Administrative discretion and compliance risk:

• The instrument leaves determinations of causation and assessment of medical evidence to the adjudicative processes under the VEA and MRCA, informed by the RMA’s statement (s7, s8). That gives administrative decision‑makers scope to evaluate the sufficiency and credibility of the evidence. The RMA’s statement that there is "sound medical‑scientific evidence" (s7) frames the medical baseline, but it does not define binding penalties nor does it prescribe standards of proof beyond the "reasonable hypothesis" threshold.

Interactions with other enforcement regimes:

• The instrument contains no cross-reference to industrial, occupational health and safety, or workers' compensation enforcement mechanisms. It does cross‑refer to other Statements of Principles where relevant (s10), which affects administrative application across SOPs but not criminal or civil enforcement regimes. Any recourse to other enforcement processes (for example, workplace safety regulators) is not addressed by this instrument.

In summary, the instrument is not an enforcement instrument in a penal sense; it is an evidentiary and definitional tool to be applied within the VEA and MRCA claims processes. Its "force" is in shaping administrative decision-making rather than imposing statutory penalties.

This Statement of Principles is a statutory instrument made under the VEA and expressly intended to be used within the decision‑making frameworks of that Act and the MRCA. The text provides specific, narrow cross-references and interactions:

Primary statutory anchors

• The RMA made the instrument under subsection 196B(2) of the VEA (s3). The instrument applies to claims to which section 120A of the VEA or section 338 of the MRCA applies (s4). That situates the instrument functionally as an evidentiary input into the VEA and MRCA administrative decision-making processes. It is not freestanding legislation but a piece of medical guidance with statutory origin.

Interaction with other Statements of Principles

• Section 10 creates a direct interaction rule: where a factor in s8 refers to an injury or disease covered by another Statement of Principles made under subsection 196B(2) of the VEA, then the factors in that other SOP apply in accordance with that SOP’s terms. This determines hierarchy or allocation of medical causation issues where injuries or disease overlap between SOPs. Practically, decision‑makers must identify whether a factor is already addressed in another SOP and then apply the other SOP’s factors rather than duplicating or ignoring that coverage.

Interaction with the concepts of the VEA and MRCA

• The instrument ties its causal tests to "relevant service", which the Schedule defines by reference to categories under both the VEA and MRCA (Schedule). Consequently, whether a claimant's service is "relevant" must be determined under the definitions and processes of those Acts. The SOP does not itself decide what constitutes relevant service; it requires that the RMA factors be related to such relevant service to raise a reasonable hypothesis (s9(1)).

Scope limits relative to other medical or regulatory frameworks

• The instrument explicitly excludes certain mechanisms and effects (s6(2)(c)), such as retinal injury from operating microscope optical radiation, electrical injury including lightning, external burns where retinal burn is only a component, ionising radiation other than ultraviolet, and transient effects such as flash blindness. Those exclusions create lines of demarcation between this SOP and other potential regulatory or medical frameworks that may cover those excluded causes. Where an injury arises from an excluded cause, the decision‑maker should not rely on this SOP to establish a reasonable hypothesis of service connection for retinal burn.

What the instrument does not address

• The instrument does not reference industrial law, workers’ compensation, clinical practice obligations, or occupational health and safety legislation. It does not purport to displace or amend the operation of those regimes. Any interaction with other areas of law beyond the VEA/MRCA and other SOPs is not set out in the instrument and would be left to the ordinary legal interaction between those regimes and the VEA/MRCA processes.

Practical implications of cross-references

• Because the SOP requires factors to be "related to the person's relevant service" (s9(1)) and because "relevant service" is statutorily defined, decision‑makers must coordinate two inquiries: first, whether a factual factor exists in the terms defined by s8; second, whether that factor is connected to service that meets the statutory categories in the Schedule. Where a factor involves an injury covered by another SOP, the decision‑maker must pivot to that SOP’s factors per s10, which may change the evidentiary baseline.

In sum, the instrument functions as a medical-evidentiary rule within the VEA/MRCA legal architecture and contains a built-in mechanism (s10) for coordinating overlapping SOP coverage. It does not, however, create or alter obligations under non‑VEA/MRCA statutes; those interactions are outside the instrument’s scope.

This instrument is presented in its final form as "Statement of Principles concerning retinal burn (Reasonable Hypothesis) (No. 25 of 2023)". The instrument is dated 24 April 2023 and commences on 23 May 2023 (s2). It is made under subsection 196B(2) of the VEA (s3). The instrument identifies itself as No. 25 of 2023 and carries the RMA seal attested by the Chairperson (front matter).

The instrument contains no recorded amendments, repeal provisions, or transitional arrangements within the text provided. It does not list prior versions of a retinal burn SOP or refer to having superseded an earlier SOP. The only temporal markers in the instrument are the signature/date block and the commencement date. There are no clauses that specify expiry, review dates, or scheduled amendments.

Statutory context for amendment

• The RMA's power to determine Statements of Principles is derived from subsection 196B(2) of the VEA (s3). Any amendment to this instrument would therefore be made by the RMA under the same statutory power and would be expected to take an instrument form similar to this one.

Implication of the absence of amendment text

• Because the text does not record prior iterations or transitional arrangements, users should treat this instrument as the current RMA position as at its commencement date. Any subsequent amendments, replacements, or revocations would need to be located in later instruments made under the same statutory provision; they are not captured within this document.

Document identifiers and provenance

• The instrument is identified by number and year (No. 25 of 2023). The signature block and common seal statement indicate it was executed at the direction of the RMA Chairperson. The Schedule includes statutory definitions that anchor the instrument to the VEA and MRCA regimes.

What to check for updates

• Practitioners should verify the RMA’s instruments register or the consolidated legislation repository to confirm whether later Statements of Principles have amended, superseded, or otherwise affected this instrument. That procedural step is necessary because this printed instrument does not contain any internal schedule for revision or sunset.

In short, the instrument has a single recorded creation date and commencement date and contains no in-text amendment history. Any changes to its terms must be effected by later instruments under the RMA’s statutory power.

The instrument text contains no references to litigation, judicial decisions, or administrative review outcomes. It does not cite any cases, nor does it reproduce any adjudicative findings or precedent. The RMA's statement in s7 asserts that "there is sound medical‑scientific evidence" connecting retinal burn and death from retinal burn with relevant service, but the instrument does not identify litigation in which that evidence has been tested or judicially considered.

Implications of an absence of litigation record in the text

• Because the instrument contains no litigation history, it does not function as a catalogue of disputes or judicial interpretations of retinal burn within the VEA/MRCA context. Decision-makers, claimants and advisers will need to consult tribunal or court decisions, and administrative review records outside this instrument to understand how these SOP factors have been applied in contested determinations. This instrument should be treated as the RMA's contemporaneous medical guidance rather than a summary of adjudicative outcomes.

What practitioners must therefore do

• For contested claims or appeals, practitioners should locate relevant administrative decisions, tribunal or judicial authorities interpreting the application of SOPs generally and retinal burn specifically. Since none are cited here, the instrument provides the medical baseline; the application at administrative or judicial review will turn on the facts, the medical evidence presented, and the legal standards for reviewing administrative factual findings under the VEA and MRCA.

Caveats

• The absence of litigation references in the instrument does not imply that no disputes exist in practice. It simply indicates that the instrument does not record or summarise such litigation. Users should not infer from silence that the legal standards set out by the instrument are uncontested in tribunal or court settings.

In summary, the instrument contains no litigation history; it is a medical statement for administrative application and must be read alongside any jurisprudence developed under the VEA and MRCA in relevant decisions, which are not reproduced or summarised in this text.

This instrument contains several technical, timing and definitional features that commonly cause practical difficulty for claimants and decision-makers. The following points identify those "gotchas" and link them to the text.

1. The test requires a specific clinical finding "at the time of the clinical onset" (s8(1)-(4)). That phrase requires precision in clinical documentation. A claimant must show not just exposure but that a visual field defect or scotoma was present contemporaneously with the clinical onset of the retinal burn. Retrospective or delayed clinical findings, absent records connecting them to the onset time, may not satisfy the RMA’s minimum factor.

2. Arc welding retinal burns may be masked by more obvious corneal and conjunctival injuries (s8 notes). The instrument notes that arc welding retinal burns are often associated with corneal and conjunctival burns (Welder's flash), but the clinical onset of the retinal burn could have been at the time of the arc flash while the claimant's symptoms were dominated by external eye injuries (s8 note 2). Practically, this can make onset dating and causal attribution difficult where different ocular tissues are affected simultaneously.

3. The instrument excludes several mechanisms commonly encountered clinically (s6(2)(c)). Notable exclusions include electrical eye injury including lightning, external burns where retinal burn is a component of broader eye burns, retinal burns from operating microscopes (intended or accidental), ionising radiation apart from ultraviolet light, and temporary effects such as flash blindness (s6(2)(c)(i)-(v)). If a claimant’s injury arises from one of these excluded mechanisms, this SOP cannot be used to raise a reasonable hypothesis for retinal burn under its terms.

4. The inclusion for "non-therapeutic exposure to lasers" (s6(2)(b)(iv)) is specific, and s8(1) requires ocular exposure to laser radiation producing a visual field defect or scotoma. The instrument’s notes clarify that not all laser exposures cause retinal injury and that risk is a function of energy delivered, irradiance, beam power and exposure duration (s8 note 1). Establishing the technical parameters of a laser exposure may be necessary, and simple assertions of exposure without supporting technical or clinical evidence may fall short.

5. The management‑related factor (s8(5)) has a constrained temporal application (s9(2)). Section 9(2) makes clear that inability to obtain appropriate clinical management applies only to cases of material contribution to, or aggravation of, retinal burn where the retinal burn was suffered or contracted before or during, but did not arise out of, the person's relevant service. That is a narrow class: the claimant must have had a pre-existing or contemporaneous retinal burn that did not arise out of service but was materially contributed to or aggravated because appropriate management could not be obtained during the relevant window.

6. The instrument requires the factor to be "related to the relevant service" (s9(1)). Establishing an actual relationship between the exposure/factor and the service category set out in the Schedule can be a discrete evidentiary hurdle independent of the clinical proof of exposure and clinical onset.

7. Overlap with other SOPs can redirect which factors apply (s10). If a factor in s8 refers to an injury or disease that is covered by another SOP, the other SOP’s factors apply. Failure to identify overlapping SOP coverage at the claim assessment stage can lead to misapplication of the RMA’s criteria.

8. The statutory definition of "terminal event" is specific (Schedule). Death from retinal burn is included only where the retinal burn contributed to a terminal event such as pneumonia, respiratory failure, cardiac arrest, circulatory failure or cessation of brain function. Claimants asserting fatal consequences must link the retinal burn to one of the defined terminal events.

9. Optical system causation focus. The definition emphasises injuries caused by optical radiation passing through the eye’s optical system (s6(2)(a) and Note). Injuries from other transmission mechanisms or systemic causes will fall outside the SOP.

10. No procedural detail on how medical evidence should be presented. The SOP identifies required medical facts but does not prescribe the format, expertise level, or evidentiary thresholds for medical reports. Practitioners will need to ensure that clinical reports address the specific temporal and clinical elements required by s8 and s9.

These features mean that proving a reasonable hypothesis under this SOP frequently requires contemporaneous clinical documentation, precise medical reports addressing onset timing, technical evidence where exposure is to lasers or welding, and careful linkage of the exposure to the person’s relevant service category.

To frame compliance in administrative claim terms: a claimant seeking to rely on this Statement of Principles should assemble evidence that satisfies the RMA’s minimum factors (s8) and demonstrate that the factor relied upon is related to the claimant's "relevant service" as defined in the Schedule (s9(1)). Below are practical steps, tied to the instrument’s text, that advisers and claimants should follow.

1. Identify the applicable service category

• Confirm the claimant’s service falls within "relevant service" as defined in the Schedule: operational, peacekeeping, hazardous, British nuclear test defence service under the VEA, or warlike/non‑warlike service under the MRCA. The causal factor must be related to that service for the SOP to apply (s9(1)).

2. Select the operative factor from s8

• Determine which of the factors in s8 the claimant can meet: ocular exposure to laser radiation (s8(1)); ocular exposure to arc welding radiation (s8(2)); ocular exposure to nuclear explosion radiation (s8(3)); ocular exposure to sun-viewing with naked eye or optical instrument (s8(4)); or inability to obtain appropriate clinical management where temporally permitted (s8(5) with s9(2)).

3. Assemble clinical evidence addressing "clinical onset"

• For exposure-based factors (s8(1)-(4)), obtain medical records and expert reports that document the visual field defect or scotoma of the affected eye and, crucially, link those findings to the time of clinical onset. The instrument requires the visual field defect or scotoma to have been present at that time. Where corneal or conjunctival injuries co‑occur (e.g. welder’s flash), obtain notes that specifically address when retinal injury signs appeared relative to external signs (s8 note 2).

4. For laser and welding exposures, obtain technical or occupational evidence where relevant

• The instrument notes that probability of retinal injury depends on energy delivered, irradiance, beam power and exposure duration for lasers, and similar factors for welding (s8 notes). Where possible, obtain documentation identifying the laser class, power output and exposure circumstances, or the welding equipment, protective gear used, duration and proximity. Where exposure occurred through optical instruments (binoculars, telescopic sights), document that fact; the instrument notes increased risk when lasers are viewed through magnifying devices.

5. If relying on inability to obtain appropriate clinical management (s8(5))

• Ensure the retinal burn was suffered or contracted before or during,but did not arise out of,the person’s relevant service (s9(2)), and compile evidence of attempts to obtain appropriate treatment, barriers encountered (geographic, operational, lack of access), and how lack of management materially contributed to or aggravated the retinal burn.

6. Address exclusions explicitly

• If the claimant’s presentation involves mechanisms excluded by the instrument (electrical injury including lightning; operating microscope optical radiation; ionising radiation other than ultraviolet; external burns where retinal burn is only a component; temporary dazzle/glare), prepare alternative legal strategies because this SOP excludes those mechanisms (s6(2)(c)). Clinical reports should state the causal mechanism and explain why it fits within s6(2)(a)-(b) rather than an excluded mechanism.

7. Where overlapping SOPs may apply, map coverage

• If the factor relied upon refers to an injury or disease covered by another SOP, identify that SOP and its factors; s10 requires the other SOP’s factors to apply in accordance with its terms. Structure evidence to meet the other SOP where overlap exists.

8. Prepare medico-legal reports that address the RMA’s language

• Reports should use the instrument’s terminology (retinal burn as "acute photic injury to the retina from optical radiation", visual field defect or scotoma at clinical onset, "terminal event" where death is claimed). An expert opinion should explicitly state whether, on the balance required by the administering statute, the clinical facts satisfy at least one of s8’s factors and whether the factor relates to the claimant’s relevant service (s9(1)).

9. Document the causal chain for deaths

• For death claims, demonstrate how the retinal burn contributed to a terminal event as defined in the Schedule (for example pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function). Establishing contribution will require clinical linkage between the retinal injury and the terminal event.

10. Anticipate proof gaps and plan for rebuttal

• Be prepared to explain delays in presentation, missing contemporaneous records and to address the possibility that corneal/conjunctival injuries masked retinal onset (s8 note 2). Where contemporaneous evidence is weak, strengthen evidence through expert reconstruction of plausible clinical onset tied to documented exposures.

In short, compliance is evidentiary: select the correct s8 factor, produce clinical and technical evidence tying a visual field defect or scotoma to the time of clinical onset and to relevant service, respect s9’s temporal limitation for management‑based claims, account for exclusions in s6(2)(c), and map any overlap to other SOPs per s10. The RMA’s instrument provides the checklist; a successful claim will require targeted medical evidence that addresses each element in the checklist.