VA Responds to Public Comments on K2 Toxic Exposure
The Department of Veterans Affairs (VA) has released its response to public and organizational comments on health concerns related to toxic exposures at Karshi-Khanabad (K2) Air Base in Uzbekistan. The comments came from Veterans Service Organizations (VSOs), including the Stronghold Freedom Foundation (SFF) and Veteran Families for Education & Awareness (VFEA), as well as numerous veterans and survivors.
Notice of Plans to Study
On November 27, 2024, the Department of Veterans Affairs (VA) published a notice of plan to assess exposures and conditions of interest for veterans who served At Karshi-Khanabad Air Base. That notice provided an opportunity for veterans, caregivers, survivors, and the public to provide comment and 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.
The VA received 185 public comments in all. Among them was a submission from Veteran Families for Education and Awareness (VFEA), which filed remarks in support of K-2 veterans, urging stronger recognition of toxic exposure risks and transparency of VA assessments. The full comment is available [here].
Public Photos and Documents Submitted
VA Response to Comments
In Notice 2025-19310, filed on October 1, 2025, the Department of Veterans Affairs provides its responses to the public comments submitted following the notice published on November 27, 2024.
Veterans Service Organizations
Two VSOs described K2 as a “toxic soup” and urged VA to designate a wide range of conditions—including dozens of cancers, immune, neurological, respiratory, and endocrine disorders—as presumptive illnesses linked to service at the base. VA replied that many of these diseases are already covered under the Sergeant First Class Heath Robinson Honoring Our PACT Act of 2022 or are currently under consideration through VA’s new presumptive-condition process. The department emphasized that the K2 Surveillance Program (K2SP), a long-term epidemiological study, is central to evaluating health outcomes among K2 veterans and will guide future policy decisions in association with data from claims submitted to the Veteran Benefits Administration (VBA).
Another VSO (VFEA) also urged VA to provide greater transparency in future K2SP reports, recommending detailed breakdowns of studied conditions, morbidity prevalence ratios, and recommend analyses of additional target organs and consideration of rare diseases not yet tracked. They also asked VA to analyze historical Veterans Benefits Administration (VBA) claims data to better understand trends. VA responded that it is preparing a peer-reviewed scientific publication on initial K2SP morbidity and mortality findings, with additional studies currently underway for publication. The agency said K2SP data are updated annually, allowing for continuous re-analysis and rapid response to emerging health concerns, and confirmed plans to maintain the program for at least ten years.
Stronghold Freedom Foundation
The Stronghold Freedom Foundation, which advocates for K2 veterans, urged VA to take stronger action, including:
Issuing an interim final rule establishing presumptive conditions for K2 service, including rare diseases;
Developing specialized clinician training on the combined (“toxic soup”) effects of K2 exposures;
Creating a dedicated Toxic Exposure Risk Activity (TERA) cohort for K2 veterans; and
Engaging an independent body to ensure unbiased assessment of exposure data.
VA responded that K2SP already includes nearly all K2 veterans and has been independently reviewed and endorsed by the CDC’s Agency for Toxic Substances and Disease Registry (ATSDR) and an external scientific panel. It confirmed that a proposed rule issued in October 2024 would consider certain K2 exposures—including jet fuel leaks, volatile organic compounds, particulate matter, asbestos, lead, and depleted uranium—as TERA-qualifying hazards, though the rule has not yet been finalized.
Veterans and Survivors
Veterans and survivors submitted extensive personal accounts describing illnesses they believe are linked to K2, including various cancers, autoimmune and neurological disorders, respiratory disease, endocrine conditions, and reproductive health issues. Some provided photos and documentation of environmental contamination—such as fuel spills, dust clouds, “black goo,” “unknown yellow powder in soil,” and chemical warning signs—and called for automatic service connection for affected veterans.
VA reiterated that many of the illnesses reported by K2 veterans—such as asthma, sinusitis, COPD, and several cancers—are already recognized as presumptive under the PACT Act. The agency said that additional conditions raised in public comments are being reviewed through the ongoing K2 Surveillance Program (K2SP). VA also noted that it consulted with the Department of Defense to assess potential radiation exposure at K2, but the DoD maintains there is no evidence that enriched uranium was present at the site. However, VA continues to investigate possible exposure to depleted uranium, jet fuel, airborne dust, and contaminated surface water.
Moving Forward
VA reports that early data show 73% of identified K2 veterans have filed disability claims, with 68% receiving benefits—an average of 13.6 service-connected conditions per veteran and an overall disability rating of about 70%. The agency also noted that 84% of K2 veterans are enrolled in VA health care, and 91% are enrolled in either VA or DoD health systems—a rate far higher than the national average, with only about 50% of veterans enrolled in VA health care. However, VA did not provide utilization rates for K2 veterans within the Veterans Health Administration.
In addition, VA said it has introduced new training modules for staff, updated Toxic Exposure Risk Activity (TERA) documentation, and implemented pre-decisional claim reviews to ensure K2 veterans receive all benefits to which they are entitled.
VA concludes by reaffirming that the K2 Surveillance Program will continue for at least the next decade, with regular reviews of morbidity and mortality data. These analyses—combined with ongoing evaluations of veterans’ claims and emerging scientific research—will inform future assessments of the long-term health effects associated with service at K2.
VFEA Notes
Throughout its response, the VA references several DOD and VA studies on K2 veterans but makes a statement that “To date, there is no evidence supporting an increased risk of disease or mortality associated with service at K2.”
While it is true that current analyses have not shown higher rate of mortality in the K2 population, we note that the Department of Defense (DOD) did conduct an initial study in 2015 to look at cancer outcomes among Service members deployed to K2 compared to their non-deployed peers and found a higher risk of malignant melanoma (368% higher) and neoplasms of the lymphatic and hematopoietic tissues (564% higher). VA does not mention this in the response but summarizes this finding on their K2 webpage, immediately cautioning that it was based on very few cases, so it’s not definitive evidence of a causal link. Still, we think its worth mentioning.
Furthermore, a recent 2025 DOD Study, conducted in partnership with Johns Hopkins University, explored cancer incidence rates for K2 veterans compared to a broader cohort who deployed anywhere OCONUS during the same period. Of the eight cancer outcomes analyzed, researchers found no evidence linking K2 deployment to increased health risk in seven. However, results for non-Hodgkin’s lymphoma suggested a potential association with K2 service. While there was not a statistically significant association among those deployed for less than 180 days, for those deployed to K2 for 180 days or more, the odds of developing non-Hodgkin’s lymphoma were roughly 78% higher compared to those deployed elsewhere.