Notice2025-19310
Response to Comments for the Department of Veterans Affairs To Assess Exposures and Conditions of Interest for Veterans Who Served at Karshi-Khanabad Air Base
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Published
October 2, 2025
Issuing agencies
Veterans Affairs Department
Abstract
On November 27, 2024, the Department of Veterans Affairs (VA) solicited public comments on exposures and conditions of interest related to veterans who served at Karshi-Khanabad Air Base (K2). That notice provided an opportunity for veterans, caregivers, survivors, and the public to share relevant information with VA to inform decisions regarding presumptive benefits that could impact the roughly 16,000 veterans who served at K2 from 2001 to 2005. In this notice, VA provides responses to comments received.
Full Text
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<title>Federal Register, Volume 90 Issue 189 (Thursday, October 2, 2025)</title>
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[Federal Register Volume 90, Number 189 (Thursday, October 2, 2025)]
[Notices]
[Pages 47909-47912]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-19310]
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DEPARTMENT OF VETERANS AFFAIRS
[Docket No. VA-2025-VACO-0002]
Response to Comments for the Department of Veterans Affairs To
Assess Exposures and Conditions of Interest for Veterans Who Served at
Karshi-Khanabad Air Base
AGENCY: Department of Veterans Affairs.
ACTION: Notice; response to comments.
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SUMMARY: On November 27, 2024, the Department of Veterans Affairs (VA)
solicited public comments on exposures and conditions of interest
related to veterans who served at Karshi-Khanabad Air Base (K2). That
notice provided an opportunity for veterans, caregivers, survivors, and
the public to share relevant information with VA to inform decisions
regarding presumptive benefits that could impact the roughly 16,000
veterans who served at K2 from 2001 to 2005. In this notice, VA
provides responses to comments received.
FOR FURTHER INFORMATION CONTACT: William J. Culpepper, Ph.D., Director,
K2 Surveillance Program, Health Outcomes of Military Exposures,
Veterans Health Administration, (202) 821-5294.
SUPPLEMENTARY INFORMATION: K2, or Camp Stronghold Freedom, is a former
Soviet air base located in Uzbekistan. The United States Army, Air
Force, and Marine Corps used the base to support missions into
Afghanistan. The base was 1 square mile in Southeastern Uzbekistan,
near the border of Tajikistan, and Service members located at K2 may
have been exposed to contaminants. For further information on K2
exposures, visit <a href="https://www.publichealth.va.gov/exposures/karshi-khanabad.asp">https://www.publichealth.va.gov/exposures/karshi-khanabad.asp</a>.
On November 27, 2024, VA published a notice in the Federal Register
to inform the public that it had plans to assess exposures and
conditions of interest related to military service at K2. VA provided a
30-day public comment period, which ended on December 27, 2024, and
received 185 comments from individuals and organizations. Overall,
these comments supported VA's plan to assess the scientific literature
and historical claims data regarding the determination of whether there
is an association between military environmental exposure to toxic
substances related to military service at K2 from 2001 to 2005 and
medical conditions.
Comments From Veterans Service Organizations (VSO)
VA received two comments from VSOs describing a combination of K2
exposures as a ``toxic soup'', and they requested many conditions be
classified as presumptions. Specifically, the VSO requested presumptive
status for 9 cancers; 18 conditions they categorized as immune
dysregulation disorders; 2 immune suppression disorders, atopic
dermatitis and numerous undiagnosed skin diseases; 33 ``inflammatory
diseases;'' 12 neurological diseases; 16 hematological or bone type
conditions; 14 endocrine conditions (including women's health
concerns); ``legacy issues'' (such as congenital disorders); and 9
respiratory conditions including ``breathing conditions.''
VA Response: Many of these conditions are currently covered under
the Sergeant First Class Heath Robinson Honoring our Promise to Address
Comprehensive Toxics Act of 2022 (PACT) Act, Public Law 117-168, or are
currently under consideration as a presumption following VA's new
presumptive process. The K2 Surveillance Program (K2SP) is designed
specifically to assess the health effects of those Veterans that
deployed to K2 and is a key source of the scientific evidence base.
Data from K2SP and from claims submitted to the Veterans Benefits
Administration (VBA) will be reviewed to assess whether conditions not
currently covered occur at sufficient rates to warrant a formal
evaluation. Some conditions are non-specific and unable to be
addressed, such as ``endocrine conditions'' and ``inflammatory
diseases.''
One VSO requested that VA provide more detailed data in future
reports; specifically, a breakdown of studied conditions within major
diagnostic groups and prevalence ratios of morbidity. The commenter
suggested reviewing additional target organs and considering rare
diseases not currently captured. The commenter also recommended an
analysis of historical VBA K2 Veterans' claims data for valuable
insight.
VA Response: VA is submitting a manuscript on the initial morbidity
and all-cause mortality findings from K2SP for publication in a peer-
reviewed scientific journal and will be publicly available in the
future. VA has additional scientific papers currently underway for
publication. K2SP updates data on an annual basis, which allows for
morbidity and mortality analyses to be repeated at regular intervals as
well as for rapid response to emerging health concerns. VA plans to
maintain K2SP
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for the next 10 or more years. A review of VBA claims data was used to
aid in the selection of outcomes evaluated by K2SP. These data sets
will be reviewed again prior to the next K2SP data extraction and
analyses.
Comment From Stronghold Freedom Foundation
Stronghold Freedom Foundation, an organization focused on advocacy
related to K2 exposures, commented that veterans who served at K2 have
reported numerous health issues linked to environmental toxic
exposures, including many of those identified by the two comments
received from VSOs. Additionally, Stronghold Freedom Foundation
requested that VA take four specific actions.
First, Stronghold Freedom Foundation asked VA to quickly publish an
interim final rule establishing a presumption for K2 veterans for
multiple conditions, including rare conditions. They requested that the
rulemaking acknowledge exposure to all documented toxic substances and
include all diseases plausibly associated with these exposures.
VA Response: K2SP is designed specifically to assess the health
effects of those veterans who deployed to K2 and is a key source of the
scientific evidence base.
Stronghold Freedom Foundation also requested that VA develop
specialized training for VA health care practitioners on the
synergistic effects of the ``toxic soup'' substances at K2.
VA Response: Training has been an integral part of PACT Act
implementation, and as a requirement of the PACT Act, VA continues to
refine and update training for its employees.
Stronghold Freedom Foundation further wanted VA to create a
dedicated Toxic Exposure Risk Activity (TERA) K2 cohort to evaluate the
long-term health impacts of these exposures.
VA Response: K2SP includes nearly all of the K2 veterans and is
designed to assess and monitor health effects over the next 10 or more
years. Additionally, VA published a proposed rule on October 1, 2024,
which stated that VA would consider certain K2 exposures to be a TERA.
89 FR 79815, 79820. Examples provided by VA in the proposed rule
included exposure to jet fuel (as a result of leaking Soviet-era
underground jet fuel distribution systems); volatile organic compounds
found in air samples; particulate matter and dust; depleted uranium
from non-U.S. ammunition destroyed in fires; asbestos roofing tiles and
lead-based paint; and lead in water samples. However, this rulemaking
is not final and is subject to change.
Finally, Stronghold Freedom Foundation requested that VA engage an
independent agency to correlate exposure data with reported illnesses
and ensure unbiased assessments.
VA Response: K2SP was independently reviewed by the Centers for
Disease Control and Prevention's Agency for Toxic Substances and
Disease Registry (ATSDR), which also convened an external review panel.
Both ATSDR and the external review panel endorsed K2SP.
Comments From Veterans and Survivors on K2 Exposures
VA received comments from veterans and survivors expressing
concerns with several substances such as blood, nerve, and other
chemical agents; black goo; contaminated water; small burn pits;
burning of trash and soil; aircraft fumes; smoke; dust; asbestos;
fuels; particulate matter; and benzene. Additional concerns included
the remains of a reported Russian rocket fuel dump, vaporizing
chemicals, use of mefloquine (an anti-malarial drug), and insecticide
exposures.
VA Response: A variety of contaminants were identified at K2.
Additionally, ATSDR reevaluated all samples collected at K2 by
comparing levels to modern standards. See <a href="http://www.publichealth.va.gov/docs/exposures/K2_Contaminants.pdf">www.publichealth.va.gov/docs/exposures/K2_Contaminants.pdf</a>. K2SP used this information to augment
the outcomes assessed to provide a comprehensive evaluation.
Although radiation is not an exposure confirmed by the Department
of Defense (DoD), several veterans reported concerns with radiation
exposures, including both depleted and enriched uranium. VA engaged
with DoD regarding potential radiation exposure at K2. Additionally,
there is no evidence that enriched uranium was present at K2.
Comments From Veterans and Survivors on Health Conditions
In addition to the exposure concerns summarized above, veterans and
survivors provided comments related to specific health conditions
including:
<bullet> Various cancers such as brain, breast, prostate,
esophagus, renal, bladder, skin, lung, and testicular cancers, and
multiple myeloma;
<bullet> Thyroid conditions;
<bullet> Bone and joint issues, including chondrosarcoma, chronic
pain, severe foot pain, spinal degradation, rheumatoid arthritis, and
fibromyalgia;
<bullet> Cognitive and mental disorders, including depression,
brain fog, racing thoughts, post-traumatic stress disorder, early
dementia of unknown origin, and insomnia;
<bullet> Ruptured appendix;
<bullet> Liver conditions;
<bullet> Multiple skin conditions;
<bullet> Neurological issues, including burning sensations,
peripheral neuropathy, severe neuropathies, tremors, seizures, and
carpal tunnel syndrome;
<bullet> Undiagnosed illnesses;
<bullet> Gallbladder disease;
<bullet> Dental issues;
<bullet> Various tumors, such as those affecting the kidneys, eyes,
skin, and chest;
<bullet> Myasthenia gravis;
<bullet> Monoclonal gammopathy of undetermined significance;
<bullet> Chronic fatigue;
<bullet> Hypertension;
<bullet> Endocrine disorders;
<bullet> Pancreatitis;
<bullet> Diabetes;
<bullet> Cataracts;
<bullet> Lung and respiratory conditions, including asthma,
sinusitis, sleep apnea, lung nodules, chronic obstructive pulmonary
disease (COPD), various coughs, chronic bronchitis, and a benign lung
nodule;
<bullet> Hashimoto's disease;
<bullet> Atrial fibrillation;
<bullet> Autoimmune diseases;
<bullet> Various gastrointestinal conditions, including
gastroesophageal reflux disease, inflammatory bowel disease, colon
polyps, Crohn's disease, ulcerative colitis, and celiac disease;
<bullet> Erectile dysfunction;
<bullet> Brain aneurysms;
<bullet> Kidney stones and kidney disease;
<bullet> Gynecomastia;
<bullet> Dysfunctional eustachian tubes and tinnitus; and
<bullet> Metabolic disorders.
VA Response: Many of these conditions are covered under the PACT
Act. VA will evaluate additional conditions as scientific evidence
accrues to determine whether there is sufficient evidence to recommend
presumption of exposure.
One veteran commented that military working dogs at K2 were always
sick.
VA Response: In collaboration with DoD, VA has created a Military
Working Dogs Database that includes morbidity, mortality, and post-
mortem data. A total of 16 dogs have been identified as having deployed
to K2, and preliminary analyses did not reveal any significant
findings. Further analysis is ongoing.
Two veterans stated that they would be willing to undergo medical
testing to further help K2 veterans. Several veterans requested that
all military personnel who served at K2
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automatically receive a service-connected disability rating, while
other veterans commented that any condition they developed should be
covered under a presumption.
In addition, one veteran commented that anyone who ever flew in or
out of K2 deserves coverage. One veteran reported that their child had
thyroid issues and connective tissue disease. Many commenters requested
help for their conditions, stated that K2 veterans should receive
benefits, or asked for additional research.
One commenter stated that K2 should be recognized as a TERA site;
VA practitioners should be trained on the specific environmental
concerns at K2; VA should conduct outreach and establish a K2 cohort;
an independent review of the unique K2 toxic environment should be
conducted; and VA should review the female cohort to investigate
specific reproductive conditions. Finally, one commenter suggested that
VA should reach out to the government of Uzbekistan on issues dealing
with past chemical weapons.
VA further responds to these comments in the ``Moving Forward''
section below.
Comments Containing Documentation
VA received several photographs covering various topics, including
a bag of medications; chemical agent warning signs; soil excavations;
large puddles of water near tents; a dust cloud near heavy equipment in
use; unknown yellow powder in soil being removed; a bottle of yellowish
water; what may be a small inactive burn pit; two workers in hazardous
materials suits; a smoke plume; what appears to be oil on the soil;
heavy dust in the air at dusk; a ``welcome to K2'' sign with air
pollution; and a female soldier using what appears to be a chemical
agent detection kit.
One veteran provided a slide deck from the Center for Health
Promotion and Preventive Medicine that listed radiation, fuels, and
asbestos among other exposures, along with mitigation steps.
Additionally, the U.S. Military Exposure Research Organization
submitted a document titled ``Factors Contributing to Toxic Exposure
Risk Activity at Camp Stronghold Freedom,'' which suggested in part
that all veterans should get TERA benefits and health care; there was
extensive flooding at K2; the validity of conclusions of K2 health risk
assessments is questionable due to the inability to measure all
exposures; and known health effects include exposures to particulate
matter and other concerns. This document also listed numerous possible
chemical exposures.
VA responds to these comments in the following section.
Moving Forward
VA has considered, and will continue to consider, all comments that
were received during the comment period. K2SP is ongoing and will
continue to assess morbidity and mortality outcomes over the next 10 or
more years. K2SP captures morbidity data from DoD and VA from 2000 to
the present and compares disease outcomes, using similar data, to
veterans who deployed in support of Operation Enduring Freedom during
2001 to 2005 but did not go to K2 and a separate group of veterans who
served on active duty during the K2 occupation but never deployed
anywhere in Southwest Asia. VA has submitted a report to Congress;
provided VSOs with information about the mortality and morbidity study;
and submitted a manuscript for publication to a peer-reviewed,
scientific journal.
Many of the conditions that veterans addressed in their comments
are assessed by K2SP. VA engaged with DoD regarding potential radiation
exposure at K2. As mentioned previously, there is no evidence that
enriched uranium was present at K2 at this time. VA is aware of
potential exposures addressed by commenters, including depleted
uranium, smoke, dust, contaminated surface water, and fuels. VA has
received similar feedback from VSOs, veterans, and other stakeholders
during public listening sessions. DoD completed a study on mortality
\1\ and preliminary findings from the K2SP have been reported by VA.\2\
To date, there is no evidence to support an increased disease or
mortality risk associated with service at K2. Epidemiologic research
and scientific review of military environmental exposures is ongoing.
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\1\ <a href="https://health.mil/Reference-Center/Publications/2024/06/01/K2-Mortality-Study">https://health.mil/Reference-Center/Publications/2024/06/01/K2-Mortality-Study</a>.
\2\ <a href="http://www.publichealth.va.gov/docs/exposures/K2_AMSUS_24.pdf">www.publichealth.va.gov/docs/exposures/K2_AMSUS_24.pdf</a>.
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VA encourages all veterans who feel their military service has
negatively impacted their health to submit a claim for disability
compensation. VA will review the claims on a case-by-case basis. When
determining eligibility for benefits, VA considers all avenues of
service connection, which includes direct service connection, secondary
service connection, and presumptive service connection. Service
connection is not limited to potential exposures; service connection is
potentially warranted for chronic conditions manifesting to a
compensable degree within the recognized time. All K2 veterans are
eligible for VA benefits for the currently recognized conditions listed
in 38 CFR 3.309(a) that manifest during service or within the
recognized period. In addition, K2 veterans are also eligible for all
conditions identified by the PACT Act for burn pit and other toxins. As
noted previously, many of the conditions addressed by commenters are
conditions currently covered as presumptive conditions for K2 veterans,
including, but not limited to, asthma; sinusitis; rhinitis; COPD;
chronic bronchitis; squamous cell carcinoma; and brain, reproductive,
and respiratory cancers. A complete list of presumptive conditions
related to burn pit exposure can be found at <a href="https://www.va.gov/disability/eligibility/hazardous-materials-exposure/specific-environmental-hazards/#what-does-it-mean-to-have-a-pr">https://www.va.gov/disability/eligibility/hazardous-materials-exposure/specific-environmental-hazards/#what-does-it-mean-to-have-a-pr</a>.
VA notes that between 2005 and March 2024, 73% of identified K2
veterans had filed a claim for disability compensation, and 68% of the
total cohort (or 93% of those who had filed a disability compensation
claim) received disability compensation benefits. For this cohort, the
average number of service-connected issues claimed was over 20, and the
number granted was 13.6. The average service-connected disability
rating for this group is over 70%. Additionally, 84% of K2 veterans are
enrolled in VA health care, and 91% are enrolled in either DoD or VA
health care.
On August 9, 2024, VA announced several steps to expand access to
VA benefits for veterans who served at K2, as well as their
survivors.\3\ VA stated that it would consider all public comments
received and assess if evidence supports additional recommendations. In
October 2024, VA created a training module specific to K2 exposures,
ensuring that toxic exposures and contaminants are fully accounted for
in the VBA claims process. VA also updated TERA documents to ensure
claims examiners are aware of exposure concerns and resources for K2
contaminants. From November 2024 through March 2025, VA conducted pre-
decisional reviews, which included additional quality checks, to ensure
K2 veterans receive all benefits to which they are entitled. VA
reiterates that K2SP is ongoing and will reevaluate morbidity and
mortality outcomes at regular intervals over the next 10 or
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more years. These findings, along with continued evaluation of VBA
claims data and review of pertinent scientific literature, will provide
additional data for VA's ongoing assessment of health effects
associated with K2 deployment.
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\3\ <a href="https://news.va.gov/press-room/va-takes-steps-to-expand-access-to-benefits-for-Veterans-who-served-at-k2-and-their-survivors/">https://news.va.gov/press-room/va-takes-steps-to-expand-access-to-benefits-for-Veterans-who-served-at-k2-and-their-survivors/</a>.
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Signing Authority
Douglas A. Collins, Secretary of Veterans Affairs, approved this
document on September 25, 2025, and authorized the undersigned to sign
and submit the document to the Office of the Federal Register for
publication electronically as an official document of the Department of
Veterans Affairs.
Taylor N. Mattson,
Alternate Federal Register Liaison Officer, Department of Veterans
Affairs.
[FR Doc. 2025-19310 Filed 10-1-25; 8:45 am]
BILLING CODE 8320-01-P
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