NAF Atsugi Incinerator - VA Inaction
In the years prior to the founding of VFEA, two of our cofounders had begun researching the NAF Atsugi incinerator exposure in their own personal capacities. It was through this research that they met each other and discovered that their families had crossed paths at NAF Atsugi during the same time frame in the late 80s - each of their families having later been affected by early cancer diagnoses. In March of 2023, Veteran Families for Education and Awareness (VFEA) came to fruition, becoming a 501(c)(3) nonprofit, with the Atsugi incinerator as one of the first focuses.
Betty and Shawn attend the January 2023 Veterans’ Family, Caregiver, and Survivor Federal Advisory Committee meeting, Red Cross Headquarters, Washington DC.
Federal Advisory Committee
In their own personal capacities, they decided to travel to Washington D.C. to attend the Veterans’ Family, Caregiver, and Survivor Federal Advisory Committee in January of 2023 to deliver public comments on the NAF Atsugi exposure. Armed with their personal stories and concern for a forgotten exposure population, they each delivered a 5-minute verbal dialogue and written statement detailing their deep concern with the governments handling of the exposure, decision not to notify former residents, and lack of long-term follow up with the exposure cohort.
Getting Caught Up
It had been a while since Atsugi had seen advocacy efforts. While the VA had created a webpage acknowledging the Atsugi exposure in 2009, it had stated the same thing for more than a decade: “Currently, there is no definitive scientific evidence to show that living at NAF Atsugi while the incinerator operated caused additional risk for disease.”
Well, what is the scientific evidence? We were aware of the Navy’s air samplings and health risk assessments performed in the 1990s which all concluded at least a slight increased risk for cancer and non-cancer diseases in the Atsugi population. We were also aware of Navy Medicine’s 2009 limited epidemiological study which found significantly higher acute and chronic dermal (skin) issues in NAF Atsugi residents - even though this study only evaluated military healthcare data before May 2008 and had other significant limitations. Did this not quality as evidence?
We were aware that the DOD/VA Deployment Health Working Group (DHWG) received a briefing on the incinerator-generated exposures in June 2009 by the Navy BUMED Occupational Medicine Program Head. As a result of this meeting it was agreed that the VA would receive a list of former active duty residents of NAF Atsugi from 1985-2001 with coordination and communication between Navy’s Epi Data Center and VA. Besides receiving this list resulting from the Navy’s limited epidemiological study, we were unsure of what studies, evaluations, or actions had been carried out by the VA on the Atsugi veteran population in the years since.
VA Actions
We were able to find that VA added the Atsugi exposure to the October 2009 Compensation & Pension Bulletin, an April 2010 VBA training letter titled: “Environmental Hazards in Iraq, Afghanistan, and Other Military Installations”, as well as a feature in the M21-1 Adjudication Procedures Manual (M21-1, Part VIII, Subpart iii, Ch.9, Section A & B).
Excerpt from the VA’s M21-1 Adjudication Manual
“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.
The Veteran’s exposure to pollutants from a waste incinerator near the Naval Air Facility (NAF) Atsugi can be conceded when the evidence of record verifies service at NAF Atsugi between 1985 and 2001.”
Beyond these records we could not find any comprehensive epidemiological studies, long-term medical surveillance programs, or any evaluation of Atsugi veteran health data by the VA, DOD, or any other entity (at least in the public realm).
VFEA’s Perspective
VFEA finds that some of the information presented in these documents are not entirely accurate. The VA’s summaries consistently state that the Atsugi population was exposed to 7 pollutants between 1985-2001 from an off-base waste incinerator, burning up to 90 tons of industrial and medical waste daily.
The Shinkampo/Enviro-Tech incinerator complex hazard next to NAF Atsugi commenced on March 3, 1980 and Navy investigators frequently observed the operators burning more than the licensing maximum of 30 tons per day (prior to September 28, 1998) and 90 tons per day (after September 28, 1998). According to Navy surveillance records from 1998, the incinerator operator frequently burned upwards of 200 tons of industrial and medical waste daily.
Furthermore, it is unclear why the VA only recognizes 7 pollutants related to this exposure. The Navy’s final comprehensive sampling and health risk assessment documented at least 48 pollutants of concern that exceeded health protective guidelines and regulations established by the EPA. Air and soil sampling conducted in previous years revealed additional pollutant exceedances on base, bringing the total list of pollutants of concern to more than 55.
Given our initial research, VFEA wanted to know:
What had the VA learned since they were informed of the exposure by the DoD in June 2009?
What insights had they gleaned from veteran heath data? From veteran benefits claims data?
Why had the VA maintained that there is no scientific evidence of additional risk for disease in the population when there was at least evidence since 2009 that higher rates of long-term skin issues had been observed in the population?
Why do the exposure years list 1985-2001 when the exposure actually started in 1980?
How did we go from 48+ pollutants of concern in the Navy’s final health assessment report to only 7 pollutants in the VA’s guidance?
How have these factual irregularities affected VBA and BVA claim adjudications over the years?
What percentage of claims filed specifically for the Atsugi Incinerator have been denied vs approved?
Veterans Administration (VA) Inquiries
In early February 2023, inquires were sent to the Veterans Health Administration and the VA’s Health Outcomes Military Exposures (HOME) office, formerly, the Post-Deployment Health Services. HOME focuses on researching and assessing health outcomes related to military exposures, including potential health risks associated with various environmental and occupational hazards encountered by military personnel during their service.
Essentially we were given a generic “work is ongoing” response and pointed back to the VA’s Atsugi webpage. We were thanked for sharing our concerns and told that the VA Military Environmental Exposure Sub-Council (MEESC) would review this issue for consideration.
In a follow up email with HOME we were told that the information on the public website is all that they have and that the best information that VHA has on Atsugi comes from Navy Medicine’s 2009 epidemiological study and the Navy’s website on Atsugi. This response by VA’s toxic exposure experts essentially confirmed that no evaluation or studies have been performed by VA on the Atsugi veteran cohort.
A Quiet Shift
A few days after this interaction, we noticed that the text on the VA’s Atsugi webpage had been modified. For 13 years, the webpage had stated:
“Short-term health effects could include irritation to the eyes, nose and throat, skin rashes, and sinus problems. These conditions usually went away after the exposure ended. Long-term health effects could include a possible increase in the lifetime risk for cancer. Since the 1990s, the Navy has informed sailors and their families about the possible long-term health effects of living at Atsugi. Visit the Navy and Marine Corps Public Health Center website for health information about air quality monitoring and soil testing at Atsugi. Currently there is no definitive scientific evidence to show that living at NAF Atsugi while the incinerator operated caused additional risk for disease.”
The wording was then changed in March 2023 to acknowledge that there was evidence to suggest long-term health issues in the Atsugi population - at least for skin disorders, leading us to wonder if the VA had evaluated the Navy’s 2009 study before receiving our inquiries.
Updated text:
“Short-term health effects could included irritation to the eyes, nose and throat, skin rashes, and sinus problems. These conditions usually went away after the exposure ended. Since the 1990’s, the Navy has informed sailors and their families about the possible long-term health effects of living at Atsugi. In 2009, the Navy and Marine Corps Public Health Center completed a study demonstrating no increased risk for cancer among NAF Atsugi residents compared to residents living at Yokosuka Naval Base, Japan after 15 years of follow-up. The study showed significantly higher dermal (skin) complaints among the Atsugi residents both while they were in Japan and after they left, suggesting the possibility of long-term dermal effects.”
VFEA Concerns
Concerningly, in making this change, the VA has decided to lean in heavily on the Navy’s limited epidemiological study from 2009. As mentioned prior, this small study has significant limitations that inhibits its ability to infer any long-term latent health affects in the Atsugi population - especially cancer rates. Its unfortunate that the VA removed the statement that “long-term health effects could include a possible increase in the lifetime risk for cancer” and decided to replace this with a statement that the 2009 study demonstrated no increased risk for cancer after 15 years of follow-up. This statement is misleading as the study did not follow subjects for 15 years and was performed too soon after the exposure period to capture representative cancer rates (most exposure-related cancers take 20-30 years to develop).
To be included in the study, 15 years would have had to gone by since your first exposure day in Atsugi - excluding half of the exposure population right off the bat due to the study’s timing (2008) relative to the evaluated exposure period (1985-2001). Additionally, no veteran or civilian healthcare data was evaluated. Since the study only considered active duty personnel and their dependents still in the military healthcare system at the time, attrition was extremely high. Due to the study’s design and limitations, loss of follow-up likely excluded the majority (80%+) of the Atsugi cohort.
We also find it misleading to say that the Navy has informed sailors and their families about the possible long-term health effects of living at Atsugi since the 1990s. The Navy initiated informal and voluntary notifications in Oct. 1995 but did not begin formal, mandatory notifications until May of 1998. However, these were only provided for current and incoming residents/personnel and ended in 2002 after the incinerator was shut down. Former residents and personnel did not receive notifications on their prior exposures nor the results of subsequent health risk assessments, such as the 2002 Comprehensive Health Risk Assessment, which concluded that there is an increased health risk in the population. When the Department of the Navy published their Atsugi exposure website, they did not perform direct outreach to individuals of the affected population. As a result of these decisions, it's conceivable that over 80% of the exposed population is unaware of the increased health risks they may face and that any subsequent illnesses could be linked to their time at NAF Atsugi.
Freedom of Information Requests
In the search for additional information, FOIA requests were submitted to VHA and VBA.
The VHA request was executed. However, no documents or information on the Atsugi exposure was provided by VHA -besides the presentation provided by the Navy in June 2009- furthering our concern about the lack of follow up in the veteran population.
Efforts to obtain VBA data on Atsugi veterans are ongoing.
Moving Forward
While VFEA is concerned about the lack of follow-up and attention afforded to the Atsugi veteran and dependent population, we also recognize the challenges that the VA faces due to understaffing and overtasking. It's evident that the VA's primary focus is often driven by priorities set forth by Congress, Veteran Service Organizations, and media pressure. This often leaves smaller exposures, without big advocates, behind.
However, the landscape surrounding military toxic exposures has undergone significant changes in recent years, particularly following the passage of the historic PACT Act. Although Atsugi veterans did not benefit from the presumptive disabilities awarded to post-9/11 veterans, this legislation has brought increased attention to military exposures and set a precedent to care for veterans affected by toxic exposures in a meaningful way. In this setting, VFEA is dedicated to facilitating dialogue regarding the Atsugi Incinerator exposure and bringing attention to the disparities in the VA’s actions. We will continue engaging with the Health Outcomes Military Exposure office, as well as VA leadership, to help ensure that the Atsugi population receives appropriate support and equitable attention by the Department of Veterans Affairs.