Processing Claims Based on Exposure to Specific Environmental or Military Occupational Hazards (EMOHs)

Overview

In This Section

This section contains the following topics:

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1. General Information for Establishing Exposure to Specific EMOHs

Introduction

This topic contains information on establishing exposure to EMOHs, including

• procedures for establishing exposure to EMOHs
• reviewing military records for exposure to EMOHs
• considering alternative evidence to establish exposure to EMOHs
• researching exposure to EMOHs in the Individual Longitudinal Exposure Record (ILER), and
• examination requests in EMOH claims.

Change Date

December 4, 2025

VIII.iii.9.B.1.a. Procedures for Establishing Exposure to EMOHs

It is critical that claims processors rely upon all available sources of evidence when verifying and/or conceding an in-service exposure event is consistent with the places, types, and circumstances of the Veteran’s service in accordance with 38 CFR 3.303.

Follow the steps in the table below when developing claims for service connection (SC) based on exposure to environmental or military occupational hazards (EMOHs).

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References: For more information on

• exposure to EMOHs and TERA, see M21-1, Part VIII, Subpart iii, 9.A.1.h, and
• processing TERA claims, see the Sergeant First Class Heath Robinson Honoring our Promise to Address Comprehensive Toxics (PACT) Act of 2022 Implementation Standard Operating Procedure (SOP).

VIII.iii.9.B.1.b. Reviewing Military Records for Exposure to EMOHs

When establishing exposure to EMOHs, thoroughly review the Veteran’s service history and circumstances of service documented in

• military personnel records, and
• STRs, to include the Post-Deployment Health Assessment (PDHA) and Discharge Examination, which include specific questions relating to exposure incidents.

Example: A Veteran claims service connection (SC) for a non-presumptive disability due to exposures at the Qarmat Ali Water Treatment Plant. The Veteran’s personnel records confirm activation with the West Virginia Army National Guard and assignment to the plant in April 2003. Exposure to sodium dichromate and hexavalent chromium can be conceded as a TERA, as it is consistent with the places and circumstances of the Veteran’s military service.

Note: Do not submit EMOH exposure research requests to the Veterans Benefits Administration Records Acquisition and Research unless the Veteran’s service in a specified location occurred during a Special Operations assignment, as noted in M21-1, Part VIII, Subpart iv, 9.A.

References: For more information on

• direct SC, see M21-1, Part V, Subpart ii, 2.A, and
• processing TERA claims, see the PACT Act Implementation SOP.

VIII.iii.9.B.1.c. Considering Alternative Evidence to Establish Exposure to EMOHs

Military service records may not verify all incidents of exposure, and therefore, it is important to consider alternative sources of evidence in establishing whether the Veteran participated in or was affected by an in-service EMOH exposure incident.

Alternative sources of evidence include

• personal statements
• buddy statements
• unit histories
• news articles
• other lay evidence, and
• the Veterans Health Administration’s (VHA’s) Military Exposures site.

Important: The Veteran’s lay statement of exposure or statements provided by others can be used to establish exposure to the claimed EMOH. Concede exposure to the claimed EMOH if the statements provided by the Veteran and/or others are consistent with the facts, places, and circumstances of the Veteran’s service.

Example: A Veteran claims SC for a disability and provides a lay statement that his military occupational duties resulted in exposure to fuels. The Veteran’s personnel records confirm he performed fuel systems maintenance duties. Exposure to fuel can be conceded and established as TERA participation as it is consistent with the circumstances of the Veteran’s military occupation.

References: For more information on considering

• evidence in claims for disability compensation, see
• 38 U.S.C. 1154(a), and
• 38 CFR 3.303(a), and
• lay statements, see M21-1, Part V, Subpart ii, 1.A and B.

VIII.iii.9.B.1.d. Researching Exposure to EMOHs in ILER

ILER is a joint Department of War (DOW) and Department of Veterans Affairs (VA) web-based application that provides the ability to link a Veteran to military exposures and/or deployments.

Claims processors must review exposures and locations of service noted in the Veteran’s ILER to determine if exposure to EMOHs is consistent with the facts, places, and circumstances of the Veteran’s service in accordance with 38 CFR 3.303.

References: For more information on

• ILER, see the ILER Guidance, and
• ILER entries related to occupational hazards, see M21-1, Part VIII, Subpart iii, 9.B.3.c.

VIII.iii.9.B.1.e. Examination Requests in EMOH Claims

When it is determined that the evidence satisfies the threshold for ordering a medical opinion based on a specific EMOH exposure(s), follow the TERA examination procedures outlined in the PACT Act Implementation SOP.

Important: In all claims where the Veteran served during the Persian Gulf War era, review M21-1, Part VIII, Subpart ii, 1.B.1.a to identify all theories of SC that must be applied to the claim.

References: For more information on

• examination requests, see M21-1, Part IV, Subpart i, 2.A, and
• the Persian Gulf War era, see 38 CFR 3.2(i).

2. Establishing Exposure to Specific Environmental Hazards

Introduction

This topic contains information on establishing exposure to specific environmental hazards, including

• verifying service at the Qarmat Ali Water Treatment Plant, and
• establishing exposure to
• the sulfur fire at the Mishraq State Sulfur Mine, and
• p ollutants near the Naval Air Facility (NAF) at Atsugi, Japan.

Change Date

December 4, 2025

VIII.iii.9.B.2.a. Verifying Service at the Qarmat Ali Water Treatment Plant

DOW has confirmed with VA that National Guard personnel from Indiana, West Virginia, South Carolina, and Oregon served at the Qarmat Ali Water Treatment Plant in Iraq. Therefore, verification of individual exposure is not required. Establish exposure to sodium dichromate and hexavalent chromium for Veterans who served in one of these National Guard units if their service in Iraq was from April through September 2003.

Reference: For more information on the Qarmat Ali Water Treatment Plant, see M21-1, Part VIII, Subpart iii, 9.A.1.f.

VIII.iii.9.B.2.b. Establishing Exposure to the Sulfur Fire at Mishraq State Sulfur Mine

Establish exposure to sulfur dioxide and hydrogen sulfide if service records show service in Iraq at Mosul Airfield or Qayyarah Airfield West (Camp Q West) at any time during the during the period June 24, 2003, through July 21, 2003.

Important:

• A roster of firefighters and support elements that participated in controlling the fire identifies involved individuals as primarily from the 101 st Airborne Division – 52 nd Engineer Battalion, 326 th Engineer Battalion, and 887 th Engineer Battalion.
• Camp Q West is a major military supply airstrip as well as the primary area of deployment for the 101st Airborne Division.

Reference: For more information on the sulfur fire at Mishraq State Sulfur Mine, see M21-1, Part VIII, Subpart iii, 9.A.1.e.

VIII.iii.9.B.2.c. Establishing Exposure to Pollutants Near NAF at Atsugi, Japan

Concede exposure to the pollutants listed in M21-1, Part VIII, Subpart iii, 9.A.1.f from the waste incinerator near the Naval Air Facility (NAF) Atsugi when the evidence of record verifies the Veteran’s service at NAF Atsugi between 1985 and 2001.

Reference: For more information on pollutants near NAF Atsugi, see M21-1, Part VIII, Subpart iii, 9.A.1.g.

3. Establishing Toxic Exposure Related to Occupational Hazards

Introduction

This topic contains information on establishing toxic exposure related to occupational hazards, including

• establishing military occupational exposures
• evidence required to establish military occupational exposures, and
• military occupational specialty (MOS) entries in ILER.

Change Date

December 4, 2025

VIII.iii.9.B.3.a. Establishing Military Occupational Exposures

A Veteran’s exposure to a specific military occupational hazard can be conceded as TERA participation if the claimed exposure is consistent with the occupational duties and responsibilities performed during the Veteran’s military career.

Review each claim of military occupational exposure to determine if credible evidence establishes the claimed exposure is consistent with the facts, places, and circumstances of the Veteran’s service in accordance with 38 CFR 3.303.

When making this determination, consider whether the Veteran’s occupational duties are associated with risk factors for the alleged exposure.

Example 1: A Veteran claims a disability was caused by exposure to diesel fuel and exhaust. The personnel records show duties that included fueling military vehicles.

Example 2: A Veteran claims a disability due to jet exhaust. Military records confirm flight deck duties on an aircraft carrier.

Example 3: A Veteran claims a disability due to occupational duties that involved spraying pesticides around a base in Germany. However, none of the available evidence indicates overseas service or other circumstances of service consistent with spraying pesticides.

VIII.iii.9.B.3.b. Evidence Required to Establish Military Occupational Exposures

A military occupational specialty (MOS) alone is not an event, disease, or injury. Therefore, conceding toxic exposure based on a Veteran’s MOS alone is not appropriate as a military occupation alone is not considered TERA participation. Toxic exposure based on occupational duties must be considered in conjunction with other evidence.

To establish toxic exposure based on occupational duties, there must be

• lay evidence that is found to be credible and consistent with a claimed exposure, or
• exposures or potential hazards associated with the Veteran's MOS documented in ILER, STRs, or military personnel records.

Reference: For more information on processing TERA claims, see the PACT Act Implementation SOP.

VIII.iii.9.B.3.c. MOS Entries in ILER

Some IES reports from ILER contain entries in the HAZARDOUS AGENTS column in the MOS POTENTIAL CONDITIONS portion of the PERSONNEL HISTORY tile.

When ILER includes a listing of potential hazards associated with the Veteran's MOS and the Veteran is confirmed to have served in that occupation during active military service, this evidence is sufficient to establish exposure to the specific listed toxins as TERA participation.

Important: A circumstance-based TERA examination exception should not be applied simply because an ILER entry notes potential exposure to toxic substances, chemicals, or airborne hazards. In these instances, there is no requirement for the listed exposure to be further substantiated in the service records or via a lay statement.

References: For more information on

• ILER, see the ILER Guidance, and
• TERA examination exceptions, see the TERA Exception Job Aid.

4. Rating Claims Based on Exposure to Specific EMOHs

Change Date

December 4, 2025

VIII.iii.9.B.4.a. Rating Requirements for Claims Based on Exposure to EMOHs

When the Veteran claims a disability due to a specific EMOH for which VA does not recognize a presumption of SC, the claim should be considered on the basis of direct SC, to include TERA, or other theory(ies) of SC raised by the Veteran or evidence of record.

Note: For Veterans with service in a location associated with multiple toxic exposure types, follow the guidance in M21-1, Part II, Subpart iii, 1.A.2.f, to determine whether an unclaimed theory of SC is reasonably raised.

Example: A Veteran claims a disability due to the Mishraq State Sulfur Mine fire. Records show service at the qualifying location during the qualifying time period. In addition to exposure to sulfur dioxide and hydrogen sulfide from the fire and other applicable exposures in Iraq as a TERA, consider whether the presumptive provisions of 38 U.S.C. 1117 or 38 U.S.C. 1119 apply to the facts of the claim based on the Veteran’s service in Iraq during the Persian Gulf War.

References: For more information on

• processing Gulf War disability claims, see M21-1, Part VIII, Subpart ii, 1.B.1.a
• direct SC, see
• 38 CFR 3.303, and
• M21-1 Part V, Subpart ii, 2.A, and
• TERA rating decision requirements, see the PACT Act Implementation SOP.