The Authority has now clarified the matter by deciding to use the term particularized need consistent with its use by the D.C. Circuit in later decisions, such as United States Department of Veterans Affairs, Washington, D.C. v. FLRA, 1 F.3d 19 (D.C.
Menarche marks the commencement of the reproductive phase of a woman's life. Records suggest that there was a secular decline in the average age at menarche in developed countries across the 19th and 20th Centuries until the 1950s, with an average age at menarche of 15-17 years reported in the mid-19th Century.
Examining the average age of menarche globally, the data indicate that the average age of menarche has decreased significantly in the last 100 years. Earlier menarche is attributed to improved nutrition, and the industrial revolution, which brought on a higher stress level due to the faster pace of life.