M21-1 Manual / Part VIII, Subpart iii, Chapter 9, Section A
General Information on Exposure to Specific Environmental or Military Occupational Hazards (EMOHs)
M21-1, Part VIII, Subpart iii, Chapter 9, Section A
Overview
In This Section | | This section contains the topic, "General Information on Exposure to Specific EMOHs." |
1. General Information on Exposure to Specific EMOHs
Introduction | | This topic contains general information on exposure to specific EMOHs, including- exposure to EMOHs
- locations of specific environmental hazards identified by the Department of War (DOW)
- military occupational hazards exposure
- action to take when the Veteran claims EMOHs exposure but does not claim a disability
- sulfur fire exposure at Mishraq State Sulfur Mine Near Mosul, Iraq
- National Guard exposure to Chromium VI at Qarmat Ali Water Treatment Plant in Basrah, Iraq
- details on exposure to pollutants from a waste incinerator near naval air facility (NAF) in Atsugi, Japan, and
- exposure to EMOHs and toxic exposure risk activity (TERA).
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Change Date | | December 4, 2025 |
VIII.iii.9.A.1.a. Exposure to EMOHs | | Veterans may have been exposed to a variety of environmental and military occupational hazards (EMOHs) during their service. Exposure event(s) can be consistent with the places, types, and circumstances of the Veteran’s service either based on- service in a specific location, as discussed in M21-1, Part VIII, Subpart iii, 9.A.1.b, or
- occupational duties and responsibilities, as discussed in M21-1, Part VIII, Subpart iii, 9.A.1.c.
Important: - When the Department of Veterans Affairs (VA) does not recognize presumption of exposure or a presumption of service connection (SC) for specific disabilities due to exposure to EMOHs, the claim must be processed under direct SC provisions, to include following toxic exposure risk activity (TERA) procedures, or other theory(ies) of SC raised by the Veteran or evidence of record.
- Multiple theories of SC may apply to claims, especially for disabilities incurred by Veterans who served during the Persian Gulf War era. When a Veteran served in a location(s) associated with multiple toxic exposures during the Persian Gulf War era, follow the guidance in M21-1, Part VIII, Subpart ii, 1.B.1.a to process the claim under all relevant theories of SC based on all toxic exposure(s) incurred by the Veteran.
References: For more information on- direct SC, see
- considering unclaimed theories of SC, see M21-1, Part II, Subpart iii, 1.A.2.f
- exposure to EMOHs and TERA, see M21-1, Part VIII, Subpart iii, 9.A.1.h
- 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)
- Persian Gulf War era, see 38 CFR 3.2(i), and
- Gulf War service, see the Gulf War Era Service Areas Job Aid.
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VIII.iii.9.A.1.b. Locations of Specific Environmental Hazards Identified by DOW | | The Department of War (DOW) has identified a number of specific environmental hazards at military installations that could present health risks. These hazards include, but are not limited to,- a large sulfur fire at Mishraq State Sulphur Mine near Mosul, Iraq
- hexavalent chromium exposure at the Qarmat Ali Water Treatment Plant at Basrah, Iraq, and
- pollutants from a waste incinerator near the Naval Air Facility (NAF) at Atsugi, Japan.
Important: While the above list represents confirmed events associated with specific toxic exposures, toxic exposure can be consistent with places, types, and circumstance of service in other locations. Determinations should be based on a thorough fact-finding process, considering the Veteran’s service history and circumstances of service as described in M21-1, Part VIII, Subpart iii, 9.B.1.b. |
VIII.iii.9.A.1.c. Military Occupational Hazards Exposure | | Veterans may claim exposure to specific toxins based on the occupational duties they performed during their military service. VA may not recognize specific disabilities as presumptively due to the claimed occupational exposure; therefore, each exposure event should be considered based on the places, types, and circumstances of the Veteran’s service, consistent with 38 CFR 3.303(a).A military occupational specialty (MOS) simply identifies a job category and does not automatically prove that a Veteran was exposed to specific toxins. VA does not currently recognize a presumption of exposure to any specific toxins based on MOS. Each claim of toxic exposure based on occupational duties must be evaluated under the guidance outlined in M21-1, Part VIII, Subpart iii, 9.B.3.Exception: For claims based on asbestos exposure, follow the procedures outlined in M21-1, Part VIII, Subpart iii, 7.C to establish MOS-based exposure to asbestos.References: For more information on |
VIII.iii.9.A.1.d. Action to Take When the Veteran Claims EMOHs Exposure but Does Not Claim a Disability | | A claim is not substantially complete if a Veteran alleges exposure to EMOHs during service but does not claim SC for a specific disability. In cases such as these, follow the procedures for handling an incomplete application at M21-1, Part II, Subpart iii, 1.C.2.b and c. |
VIII.iii.9.A.1.e. Sulfur Fire Exposure at Mishraq State Sulfur Mine Near Mosul, Iraq | | On June 24, 2003, a fire ignited at the Mishraq State Sulfur Mine Plant in Northern Iraq. The fire burned for approximately 3 weeks and caused the release of roughly 42 million pounds of sulfur dioxide (SO2) per day as well as release of hydrogen sulfide (H2S). Field sampling data showed that the levels of SO2/H2S were not solely located in the immediate vicinity of the fire. Other areas found to be affected included- Qayyarah Airfield West (Camp Q West), which is 25 km to the south and is a major military supply airstrip as well as the primary area of deployment for the 101st Airborne Division, and
- the area approximately 50 km to the north up to the Mosul Airfield area.
Reference: For more information on establishing exposure at the sulfur fire at Mishraq State Sulfur Mine, see M21-1, Part VIII, Subpart iii, 9.B.2.b. |
VIII.iii.9.A.1.f. National Guard Exposure to Chromium VI at Qarmat Ali Water Treatment Plant in Basrah, Iraq | | From approximately April through September 2003, Army National Guard personnel from Indiana, West Virginia, South Carolina, and Oregon served at the Qarmat Ali Water Treatment Plant in Basrah, Iraq, and were assigned to guard contract workers who were restoring the plant. At that time, testing verified that sodium dichromate, a source of hexavalent chromium (Chromium VI) that was previously used as a corrosion-preventing chemical by former Iraqi plant workers, was found on the ground and measured in the air. Chromium VI in sodium dichromate is a lung carcinogen through inhalation and an acidic compound that can cause immediate irritation to the eyes, nose, sinuses, lungs, and skin. The Army could not specifically trace symptoms to the chromium exposure. Research into the effects of the exposure is ongoing. Reference: For more information on verifying service at the Qarmat Ali Water Treatment Plant, see M21-1, Part VIII, Subpart iii, 9.B.2.a. |
VIII.iii.9.A.1.g. Details on Exposure to Pollutants From a Waste Incinerator Near NAF in Atsugi, Japan | | Between 1985 and 2001, personnel at NAF Atsugi were exposed to environmental contaminants due to an off-base waste incinerator business known as the Jinkanpo or Shinkampo Incinerator Complex, which was owned and operated by a private Japanese company. Identified chemicals included:- chloroform
- 1, 2-DCE
- methylene chloride
- TCE
- chromium
- dioxins and furans, and
- other particulate matter.
Reference: For more information on establishing exposure to pollutants near NAF Atsugi, see M21-1, Part VIII, Subpart iii, 9.B.2.c. |
VIII.iii.9.A.1.h. Exposure to EMOHs and TERA | | Exposure to EMOHs is a type of TERA. When exposure to EMOHs is raised in a claim, exposure must be |
Source: VA M21-1 Adjudication Procedures Manual, M21-1, Part VIII, Subpart iii, Chapter 9, Section A (U.S. government work, reproduced for reference). Browse all sections →