Statement of Principles concerning thromboangiitis obliterans (Reasonable Hypothesis) (No. 28 of 2017)

The instrument is structured around a set of interlocking concepts that determine when a claimant can establish a reasonable hypothesis that thromboangiitis obliterans or death from it is connected to relevant service. Those concepts and their textual sources are:

• Definition of the disease: The Statement defines "thromboangiitis obliterans" as a nonatherosclerotic, segmental, inflammatory, occlusive vascular disease affecting small and medium-sized arteries and veins (s 7(2)). The instrument emphasises that, although the disease has an ICD‑10‑AM code (I73.1), the operative meaning is the statutory definition in s 7(2) (s 7(3)-(4)).

• Death from the disease: Death is included where a terminal event or condition was contributed to by the person's thromboangiitis obliterans. "Terminal event" is defined in Schedule 1 to include causes such as pneumonia, respiratory failure, cardiac arrest, circulatory failure and cessation of brain function (s 7(5); Schedule 1 cl 1).

• Relevant service: The Statement repeatedly ties factual causation to "relevant service," which the Schedule defines to include specific categories under the VEA and MRCA (operational, peacekeeping, hazardous, British nuclear test defence service; warlike and non‑warlike service under the MRCA) (Schedule 1 cl 1). Section 10(1) requires that any factor set out in s 9 must be related to the person's relevant service.

• Qualifying factors and thresholds: Section 9 lists seven factors any one of which must, as a minimum, exist to raise a reasonable hypothesis connecting the disease with service. These include quantified smoking exposure (pack‑years), quantified second‑hand smoke exposure in enclosed spaces (hours), specified durations of oral smokeless tobacco use, and an unspecified factor of "inability to obtain appropriate clinical management" (s 9(1)-(7); Schedule 1 cl 1 defines pack‑year, second‑hand smoke, smokeless tobacco).

• Temporal windows and scope: Factors 9(1)-(3) apply to the six years before clinical onset of the disease; factors 9(4)-(6) apply to the one year before clinical worsening of the disease (s 9). Section 10(2) limits the application of factors 9(4)-(7) to claims of material contribution or aggravation where the disease was suffered or contracted before or during relevant service but did not arise out of that service.

• Cross‑Statement interaction: Section 11 provides that where a factor in s 9 refers to an injury or disease that is covered by another Statement of Principles determined under s 196B(2) of the VEA, then the factors in that other Statement apply in accordance with its terms. This creates an explicit rule for deferral and overlap among Statements.

• Measurement conventions: The Schedule sets out specific conventions for calculation of "pack‑year" and equivalents, equating one pack‑year to 20 tailor‑made cigarettes daily for a year (7 300 cigarettes), approximating one tailor‑made cigarette to one gram of tobacco or one gram of cigar/pipe tobacco, and equating one pack‑year to 7.3 kilograms of smoking tobacco by weight. The Schedule defines "being exposed to second‑hand smoke" as being in an enclosed space and inhaling smoke from burning tobacco products or exhaled smoke from a person smoking (Schedule 1 cl 1).

These concepts taken together create an evidentiary framework that is both prescriptive (numerical thresholds and temporal windows) and partially open (qualitative terms such as "inability to obtain appropriate clinical management" and the requirement that a factor be "related to" relevant service). The Statement sets out precise numerical tests for some exposure types while leaving others to factual proof and interpretation.

The instrument affects three principal groups directly and other parties indirectly through claim processes:

• Claimants: Veterans, members of Peacekeeping Forces, and members of the Forces covered under the MRCA who lodge claims under the provisions identified in s 5 (claims to which section 120A of the VEA or section 338 of the MRCA applies). The Statement sets the evidentiary medical‑scientific thresholds a claimant must meet to raise a reasonable hypothesis that thromboangiitis obliterans, or death from it, is connected to their relevant service (s 5; s 9; s 10).

• Decision‑makers and administrators: Bodies and decision‑makers that adjudicate claims under the VEA and MRCA are the intended users of the Statement. The instrument is made under subsection 196B(2) of the VEA (s 3), which places it within the VEA claims framework. The Statement specifies medical criteria decision‑makers will apply when assessing whether a reasonable hypothesis has been raised; it therefore constrains the medical questions and quantification methods (s 7, s 9, Schedule 1).

• Medical and allied professionals: Clinicians, medical assessors and experts who supply clinical opinions or assessments in support of claims must work within the Statement's clinical definition of the disease and the thresholds for exposure and timing (s 7; s 9; Schedule 1). For example, a medical report used to establish "clinical onset" or "clinical worsening" must be assessed with reference to the Statement's temporal windows (s 9).

Secondary effects fall on other stakeholders:

• Service record holders and employers: Establishing a link between an exposure factor and "relevant service" (s 10(1)) will typically require examination of service records, postings, and environment. The Statement's definition of relevant service identifies specific service categories in which the factor must have a connection (Schedule 1 cl 1).

• Parties involved in overlapping Statements of Principles: The instrument directs that if a factor refers to an injury/disease covered by another Statement, the other Statement's factors apply as in force (s 11). That affects claimants and decision‑makers dealing with comorbid conditions or overlapping causal factors.

Who pays: The Statement itself does not create a direct financial charge or benefit. Practically, the immediate "payer" for the costs of establishing the necessary evidence will typically be the claimant, who will need medical records, smoking histories and possibly expert reports to meet the thresholds listed in s 9. The broader fiscal consequences (liability of the relevant compensation scheme to pay benefits if a reasonable hypothesis is raised) are governed by the VEA and MRCA claim processes; this instrument sets thresholds that influence who will succeed in those processes (s 5; s 3).

Who decides: The Repatriation Medical Authority made the Statement (s 3) and framed the factors. The adjudication of claims against these factors is performed through the VEA and MRCA claims machinery to which the Statement applies (s 5). The instrument does not itself specify the adjudicator but prescribes medical criteria those adjudicators must use.

The Statement prescribes no obligations attaching directly to private parties in the form of criminal or civil duties. Instead, it establishes criteria that create rights and evidential duties within the claims process under the VEA and MRCA. The operational duties and rights created by the instrument include:

• Duty to relate factors to service: For a claimant to succeed in raising a reasonable hypothesis, any factor in s 9 relied upon must be related to the person's relevant service (s 10(1)). The duty to establish this relationship is evidentiary. The Statement makes the claimant responsible for demonstrating that the qualifying factor occurred in a context linked to the relevant categories of service defined in Schedule 1.

• Threshold proof duties: The Statement sets minimum quantitative and qualitative thresholds in s 9. Claimants bear the duty to produce evidence that meets those thresholds. Examples include showing smoking of at least three pack‑years within six years before clinical onset (s 9(1)) or exposure to second‑hand smoke for at least 3 000 hours within the six years before clinical onset (s 9(2)). The Schedule provides the specific method for calculating pack‑years and the definition of "being exposed to second‑hand smoke" (Schedule 1 cl 1).

• Temporal restrictions on aggravation claims: Section 10(2) restricts the applicability of factors 9(4) to 9(7), which relate to material contribution or aggravation, to situations where the claimant's thromboangiitis obliterans was suffered or contracted before or during, but did not arise out of, the person's relevant service. That creates a duty to establish the timing of disease onset relative to service for aggravation claims.

• Right to have the Statement applied in adjudication: The Statement is made under the authority of the VEA (s 3) and applies to claims under specified provisions (s 5). That confers a right on claimants that decision‑makers will use the Statement's factors as the medical‑scientific yardstick when deciding whether a reasonable hypothesis has been established, including adherence to the numerical thresholds and definitions set out.

• Interaction with other Statements: If a factor in s 9 refers to a condition covered by another Statement of Principles determined under s 196B(2) of the VEA, then the factors in that other Statement apply according to its terms (s 11). This creates a right and duty framework where claimants and decision‑makers must consult and apply the relevant cross‑referenced Statement.

• Definition‑driven duties: The Schedule supplies definitional conventions that govern how evidence is measured. For instance, the pack‑year conversion standards (Schedule 1) are the applicable method for calculating tobacco exposure. Pursuant to s 7(3)-(4), clinicians and decision‑makers must use the textual definition of the disease rather than relying solely on external coding systems.

What the Statement does not do, by its text, is create new statutory penalties, investigate or adjudicate claims, or set benefit entitlements directly. Those functions remain in the associated legislation. The Statement is an instrument that prescribes evidentiary and medical concepts to be applied by the operational adjudicators under the VEA and MRCA.

The Statement contains no express penalty provisions or enforcement mechanisms within its text. It is an instrument under subsection 196B(2) of the Veterans' Entitlements Act 1986 (s 3) that sets medical‑scientific criteria for raising a reasonable hypothesis in claims. As such:

• The Statement does not create offences nor prescribe sanctions for non‑compliance. There are no sections in the instrument that impose fines, criminal sanctions, administrative penalties, or enforcement powers.

• Enforcement in practice is effected through the application of the Statement's factors within the claims processes to which it applies. Section 5 makes the instrument applicable to claims governed by section 120A of the VEA or section 338 of the MRCA. Those Acts and their procedures will determine the legal consequences (allowance, denial, review, appeal) of whether a claimant has raised the requisite reasonable hypothesis. The Statement supplies the medical criteria used in those determinations but does not itself perform adjudication.

• The Repatriation Medical Authority expresses a scientific view in s 8 that there is sound medical‑scientific evidence that the disease and death from it can be related to relevant service. That statement is a foundational evidentiary position, not a penalty or enforcement provision.

• Where questions of incorrect or false evidence arise in the claims process, any disciplinary, criminal or administrative consequences would flow from the rules and offences in the VEA, MRCA or other law, not from any clause in this Statement. The instrument does not address fraud control, sanctions for false statements, or investigative powers.

• The Statement contains a revocation clause (s 4) that withdraws the prior Statement No. 7 of 2009. The practical enforcement effect of that revocation is that decision‑makers and claimants must apply the current Statement (No. 28 of 2017) to claims to which it applies from its commencement (s 2). Repeal and replacement of an earlier Statement is a regulatory housekeeping measure rather than an enforcement action.

In short, the instrument is a prescriptive evidentiary standard to be applied within the statutory claim framework. Enforcement and penalties are matters reserved to the primary legislation and administrative processes referenced at s 5 and s 3.

The instrument links into the wider statutory architecture and to external medical classification systems, while specifying how those interactions operate:

• Authority under the VEA: The Statement is made under subsection 196B(2) of the Veterans' Entitlements Act 1986 (s 3). The authority for making Statements of Principles under that subsection is the legal source for the instrument. The instrument does not itself restate the powers or procedures of the VEA beyond this enabling reference.

• Applicability to VEA and MRCA claims: Section 5 states the instrument applies to claims to which section 120A of the VEA or section 338 of the Military Rehabilitation and Compensation Act 2004 applies. That places this Statement within the adjudicative pathways created by those Acts. The Statement does not replicate adjudicative or review procedures, but it prescribes the medical criteria to be used within them.

• Interaction with other Statements of Principles: Section 11 creates a direct interaction rule. If a factor in this Statement refers to an injury or disease covered by another Statement determined under subsection 196B(2) of the VEA, then the factors in that other Statement apply according to its terms. This produces a hierarchy and a deferral rule for overlapping medical conditions and ensures that cross‑referenced Statements are applied in the manner they prescribe.

• Relationship to ICD coding: Section 7(3) notes that thromboangiitis obliterans attracts ICD‑10‑AM code I73.1, and s 7(4) specifies that the reference to an ICD‑10‑AM code is to the Ninth Edition effective 1 July 2015. However, the instrument clarifies that the operative meaning of thromboangiitis obliterans for the Statement is the textual clinical definition in s 7(2). The net effect is that the ICD‑10‑AM code is a reference point but not a substitute for the statutory definition.

• Definitions that track statutory categories: The Schedule adopts and uses the terms MRCA and VEA and directly maps "relevant service" to specific categories under those Acts (Schedule 1 cl 1). The instrument therefore depends on the statutory categories in those Acts for determining what service qualifies as "relevant service" (s 10).

• Revocation of prior Statement: Section 4 revokes the previous Statement No. 7 of 2009 made under subsection 196B(2) of the VEA. That revocation changes which Statement decision‑makers must apply to claims from the commencement date (s 2), and creates a legal transition in the corpus of Statements of Principles.

• No express interaction with other statutory regimes: The instrument does not make express references to other federal, state or territory laws (for example, workplace safety, public health, or privacy statutes), nor does it impose duties under those regimes. Interaction with other laws, such as those dealing with evidence, administrative decision‑making, or appeals, is left to the primary legislation (VEA, MRCA) and general administrative law.

Practical consequence: the Statement is a specialised, statutory medical criterion intended to be read and applied within the limited statutory channels created by the VEA and MRCA. Where this Statement cross‑refers to other Statements or to ICD coding, it provides instructions on which text governs,normally, the Statement's own definitions and the cross‑applied Statements govern the analysis.

The instrument includes concise metadata about its creation, commencement and revocation history:

• Date and identification: The instrument is the Statement of Principles concerning thromboangiitis obliterans (Reasonable Hypothesis) (No. 28 of 2017), dated 21 April 2017 (cover page and formal signature block).

• Commencement: It commences on 22 May 2017 (s 2). That date is the operative start for its application to claims.

• Revocation of prior instrument: Section 4 expressly revokes the Statement of Principles concerning thromboangiitis obliterans No. 7 of 2009 that was made under subsection 196B(2) of the VEA. The revocation clause is unconditional; the prior Statement is therefore withdrawn from that commencement date.

• Authority and statutory basis: The instrument was made under subsection 196B(2) of the VEA (s 3). The instrument does not itself record any earlier amendments or intermediate versions between the revoked 2009 Statement and this 2017 Statement. The text contains no schedule of amendments or transitional provisions beyond the revocation.

• Textual stability: This instrument is presented as a standalone Statement (No. 28 of 2017). It does not list subsequent amendments, consolidated changes, or later revocations within its text. Any later amendments, repeal or replacement would be recorded in subsequent instruments or legislative instruments, but such instruments are not contained in this text.

• Cross‑referenced editions: The Statement refers to the Ninth Edition of the ICD‑10‑AM effective 1 July 2015 for its cited ICD code (s 7(4)). That reference is to a fixed edition of a medical classification system rather than to a rolling update. The instrument thereby pins its ICD cross‑reference to a specific published edition.

For users, the amendment history in the instrument is short and definitive: the 2009 Statement is revoked and replaced by the 2017 Statement, which operates from 22 May 2017. The instrument itself contains no further amendment record.

The instrument contains no litigation history, case citations, or references to judicial or tribunal decisions. The text does not name any cases, nor does it record any legal challenges to its content or to the underlying scientific propositions. The only legal references are to statutory provisions and to the ICD‑10‑AM classification (s 3; s 5; s 7(3)-(4); Schedule 1).

Consequences of that absence:

• No documented judicial testing in this instrument: The Statement does not summarise any litigation or judicial findings about the validity of its medical thresholds, the RMA's view in s 8, or the legal effect of meeting its factors. Any judicial or tribunal treatment of these factors would appear elsewhere in case law or administrative decisions, but that material is not included in the instrument.

• Practical implication for advisers: Because the instrument does not include litigation history, practitioners relying on it must consider that questions about the interpretation and application of its provisions (for example, how to determine "clinical onset", how to prove hours of second‑hand smoke exposure within an enclosed space, or what constitutes "inability to obtain appropriate clinical management") are matters that could be subject to challenge in adjudicative fora. The instrument itself does not record outcomes of such challenges.

• Revocation note: The instrument revokes an earlier Statement (No. 7 of 2009) (s 4). The revocation could generate transitional disputes about claims straddling the change, but the instrument does not document any litigation arising from that revocation.

Users should therefore treat this Statement as a policy and evidentiary standard, not as a judicial precedent. Any litigation history or interpretative guidance from courts or tribunals will need to be sought outside this instrument.

This instrument contains several textual features and practical thresholds that can create pitfalls for claimants, advisers and decision‑makers. These are matters to watch closely when preparing or adjudicating claims.

1. Temporal windows tied to clinical events are not defined in the instrument. The factors in s 9 refer to the "clinical onset" of thromboangiitis obliterans and to "clinical worsening" of the disease, with different exposure windows (six years before clinical onset for s 9(1)-(3); one year before clinical worsening for s 9(4)-(6)). The instrument does not define "clinical onset" or "clinical worsening" in the Schedule or elsewhere. That absence means that parties must rely on medical evidence to establish those temporal markers, and disputes may arise about the dates used to trigger the prescribed windows.

2. Specific numerical thresholds impose rigid quantification requirements. Examples include:

   • Smoking at least three pack‑years within six years before clinical onset (s 9(1)).
   • Exposure to second‑hand smoke for at least 3 000 hours within six years before clinical onset (s 9(2)).
   • Smoking at least half a pack‑year in the year before clinical worsening (s 9(4)).
   • Exposure to second‑hand smoke for at least 500 hours in the year before clinical worsening (s 9(5)). The Schedule supplies the pack‑year calculation method (Schedule 1). The practical difficulty is proving precise exposure amounts and hours, particularly for historical or informal exposures during service.

3. The definition of "being exposed to second‑hand smoke" is tightly worded. Schedule 1 defines it as being in an enclosed space and inhaling smoke from burning tobacco products or smoke exhaled by a person who is smoking (Schedule 1 cl 1). This excludes open‑air or non‑enclosed exposures. Claimants whose exposure was primarily in open or semi‑enclosed settings may therefore fail to meet the hours thresholds even if their cumulative exposure was substantial.

4. The pack‑year calculation is anchored to "tailor‑made cigarettes" and gram equivalents. The Schedule equates one pack‑year to 20 tailor‑made cigarettes per day (7 300 per year) and to 7.3 kilograms of smoking tobacco by weight (Schedule 1). Where a claimant's tobacco consumption involved manufactured, hand‑rolled, or different products, a conversion exercise using the Schedule's conventions will be necessary. The Schedule's conversion rules are precise and may produce material differences from other pack‑year methods used by clinicians or experts.

5. "On more days than not" phrasing for smokeless tobacco is imprecise but operationally strict. Factors 9(3) and 9(6) require the oral use of smokeless tobacco on more days than not for specified durations. That phrasing requires proof of habitual daily or near‑daily use; intermittent or occasional use will not satisfy the threshold.

6. Factor 9(7) , "inability to obtain appropriate clinical management for thromboangiitis obliterans" , is open‑ended. The Statement does not define "appropriate clinical management" nor prescribe a quantifiable threshold for inability to obtain it. That creates evidentiary uncertainty and a potential area for factual dispute and differing medical opinions.

7. Limits on aggravation claims (s 10(2)). The instrument restricts the applicability of factors 9(4)-(7) to material contribution or aggravation only where the disease was suffered or contracted before or during rather than arising out of service. This can be counterintuitive: if the disease arose out of service, these factors do not apply for aggravation. Careful sequencing of disease onset, contraction and service periods is therefore critical.

8. Cross‑Statement referrals can complicate claims. Section 11 requires that if a factor refers to an injury or disease covered by another Statement of Principles, then the factors in that other Statement apply. Practically, this may require identifying, locating and applying another Statement, which may have different thresholds and temporal windows.

9. ICD code note without substitution. Although the Statement mentions ICD‑10‑AM code I73.1 (s 7(3)-(4)), it makes clear the statutory text controls the definition. Parties relying on ICD coding alone without reference to the s 7(2) definition risk misalignment.

10. No penalties or enforcement detail in this instrument. The Statement contains no guidance about procedural consequences for inaccurate or fraudulent evidence. Parties must consult the VEA and MRCA and general administrative processes for such issues; those references are outside the instrument's text.

In summary, the principal gotchas are the instrument's precise numeric thresholds, its reliance on medical temporal markers that are not defined in the text, the enclosed‑space requirement for second‑hand smoke, the open‑ended clause about clinical management, and the limits imposed on aggravation claims. These are concrete interpretative and evidentiary friction points that advisers should address early in claim preparation.

Compliance in the practical sense means preparing a claim and accompanying medical evidence that, when assessed against the Statement's factors, raises the required reasonable hypothesis connecting thromboangiitis obliterans (or death from it) to relevant service. The instrument provides specific tests and definitional conventions; compliance requires structured factual and medical proof aligned to those tests.

Stepwise approach based on the instrument's text:

1. Confirm applicability of the instrument to the claim. The Statement applies to claims to which section 120A of the VEA or section 338 of the MRCA applies (s 5). Establish that the claimant's claim falls within those statutory pathways before relying on this Statement.

2. Establish the diagnosis using the Statement's clinical definition. Ensure the claimant's diagnosis fits the definition in s 7(2) , namely a nonatherosclerotic, segmental, inflammatory, occlusive vascular disease affecting small and medium arteries and veins. Although the instrument references ICD‑10‑AM code I73.1 (s 7(3)), the operative definition for claim purposes is the text of s 7(2). Medical reports should explicitly address how the claimant's clinical presentation matches s 7(2).

3. Time the disease events. Identify and document the dates of clinical onset and, where relevant, dates of any clinical worsening. Those dates are critical because s 9 separates qualifying factors into those applying within six years before clinical onset (s 9(1)-(3)) and those applying within one year before clinical worsening (s 9(4)-(6)). Because the instrument does not define "clinical onset" or "clinical worsening", reliable clinical records or contemporaneous medical notes that establish those dates are essential.

4. Select and substantiate a qualifying factor under s 9. Any one factor is sufficient as a minimum to raise a reasonable hypothesis, provided it is related to relevant service (s 9; s 10(1)). Prepare evidence tailored to the factor relied upon:

   • For pack‑year smoking thresholds: Use the Schedule's calculation method. One pack‑year equals 20 tailor‑made cigarettes per day for one calendar year (7 300 cigarettes), approximated to 1 gram of tobacco per cigarette, and equating to 7.3 kilograms of tobacco by weight per pack‑year (Schedule 1). For factor s 9(1) the claimant must show at least three pack‑years within the six years before clinical onset. For factor s 9(4) a minimum of half a pack‑year within the year before clinical worsening is required. Documented smoking histories, service records indicating availability of tobacco, or corroborating contemporaneous records should be assembled to meet these quantitative thresholds.

   • For second‑hand smoke exposure: The Schedule defines the exposure as being in an enclosed space and inhaling smoke from burning tobacco products or exhalation by a smoker (Schedule 1). The thresholds are 3 000 hours within the six years before clinical onset for s 9(2) and 500 hours within the year before clinical worsening for s 9(5). Evidence should therefore address the enclosed nature of the spaces, the duration and frequency of exposure, and the timing relative to disease onset or worsening.

   • For smokeless tobacco: The instrument requires oral use on "more days than not" for specified durations: at least three years within the six years before clinical onset (s 9(3)), or at least six months within the one year before clinical worsening (s 9(6)). Ensure documentation supports habitual daily or near‑daily use.

   • For "inability to obtain appropriate clinical management" (s 9(7)): Because the instrument does not define "appropriate", assemble records showing attempts to access care, refusals or lack of available treatments, referral logs, correspondence, and clinical evidence that the absence of management materially affected the condition. Medical opinion addressing how lack of management contributed to the disease or its progression will be necessary.

5. Link the factor to relevant service. Section 10(1) requires the existence of any factor in s 9 to be related to the person's relevant service. The Schedule defines "relevant service" with specific categories (Schedule 1). Evidence linking exposure or access‑to‑care issues to the service environment is necessary. For example, service postings, unit logs, workplace descriptions, and witness statements corroborating exposure or absence of care while on relevant service will be material.

6. Observe the s 10(2) limitation for aggravation/material contribution. If relying on factors s 9(4)-(7) to show material contribution to, or aggravation of, existing disease, ensure the claimant's disease was suffered or contracted before or during relevant service (but did not arise out of service). Prepare evidence to establish the timing of the original disease relative to service.

7. Check for cross‑referenced Statements. If any factor refers to another injury or disease for which a different Statement exists, s 11 requires application of that other Statement's factors. Identify and apply any relevant coexisting Statements to ensure consistent evidentiary sufficiency.

8. Use the Schedule's measurement conventions consistently. For instance, apply the pack‑year calculation method exactly as the Schedule prescribes. Inconsistencies between pack‑year calculations in different medical reports create a risk of challenge.

9. Prepare medical opinion evidence that addresses the RMA's stated medical basis. Section 8 records the RMA's view that sound medical‑scientific evidence indicates the disease can be related to relevant service. Medical reports should therefore explicitly address causation and the nexus to service in terms the adjudicator can apply to the Statement's factors and temporal rules.

10. Ensure contemporaneous and corroborative evidence is in order. Because the Statement relies on quantified exposures and temporal markers, contemporaneous documentation, service records and corroborating witness statements will strengthen the claim and reduce disputes over reconstruction of exposure histories.

11. Note the revocation and effective date. The prior Statement (No. 7 of 2009) is revoked (s 4). Claims should therefore be prepared against No. 28 of 2017 effective 22 May 2017 (s 2). For claims spanning the revocation date, advisers should verify which Statement applies under the governing statutes and any transitional provisions in the primary legislation.

Putting these steps together yields a compliance workflow: confirm statutory applicability (s 5), confirm diagnosis against s 7(2), determine clinical onset/worsening dates, select and document a qualifying s 9 factor using Schedule 1 calculations and definitions, demonstrate relation to relevant service per s 10, and cross‑check other Statements per s 11. The Statement supplies the specific thresholds and definitions but leaves many factual questions to documentary and medical evidence.