VA’s First Formal Evaluation Under the New Presumptive Process
On July 26, 2023, the Department of Veteran Affairs (VA) published a notice for plans to initiate a formal evaluation to explore potential connections between exposure to fine particulate matter (PM2.5) and the occurrence of acute leukemias, chronic leukemias, and multiple myeloma. This marks the first formal evaluation conducted by the new toxic exposure working group known as MEESC (Military Exposure and Environmental Health Conditions Committee). As mandated by Sec 202 of the PACT Act, the VA solicited public commentary over the following month and held a public listening session on November 7, 2023.
Reason for Evaluation
The genesis of this study stems from a recognition that certain blood cancers were not encompassed by the provisions of the PACT Act, prompting a focused effort to address potential gaps in coverage. Specifically, the PACT Act designates Multiple Myeloma originating in the head or neck as a presumptive condition. However, instances where Multiple Myeloma originates outside of these areas currently fall outside the scope of qualification. In response to this discrepancy, the formal evaluation undertaken by the VA seeks to bridge this gap for PACT Act-eligible veterans.
Public Comments
The VA received 26 comments in total during the submission period, including comments from two of VFEA’s co-founders, Betty Seaman and Shawn Lopez, submitting comments in their own personal capacity.
Many commenters supported the VA’s proposal for evaluation. Although, a common theme of the comments was that the study should not be constrained to Gulf War and Post-9/11 veterans that served in the Southwest Asia theater of operations. As noted by other commenters, fine particulate matter exposures are not restricted to this region; burn pits and open burning have been used in the military long before the post 9/11 era, including in Vietnam and many other theaters. Toxic emissions and unhealthy levels of fine particulate matter are also documented to have affected servicemembers and dependents at NAF Atsugi, Japan due to a neighboring incinerator (1980 to 2001) and open burn pit (1980-1984).
Veterans and stakeholders seem to agree that they would like equal application of study and presumptions. Otherwise, such an omission might prompt many veterans to question why their dedicated service and well-being are not afforded equal attention.
You can read all of the received comments, posted online at www.regulations.gov, here.
Public Listening Session
On November 7, 2023, a public listening session was held by the VA’s Health Outcomes Military Exposure (HOME) Office, which leads various programs related to environmental and occupational exposures, including epidemiology and environmental health programs. The VHA and VBA Undersecretaries, Shereef Elnahal and Joshua Jacobs, were both in attendance and gave brief comments. Notably, Dr. Elnahal acknowledged the 26 public comments received and touched on the repeating recommendation to expand the research to cover other locations.
Dr. Patricia Hastings, Chief Consultant for HOME, also delivered comments about the proposed conditions and the new presumptive process. Afterwards, there were 7 public speakers - each given 5 minutes of time to talk before rotating to the next speaker. No opportunity was given for a response or dialogue. The rules of engagement stated that “the VA will not have the ability to answer questions or engage in dialogue with speakers.” VFEA found this format to be rather limiting. However, we are thankful to have a venue to provide commentary directly to VA Leadership and appreciate both Undersecretaries for their attendance.