By Jordan Cade
Volatile Organic Compounds (VOCs) are a group of chemicals that evaporate easily from solids or liquids and are commonly found in military-grade degreasers, aviation fuels, and weapon-cleaning agents used across U.S. defense operations.
Jordan Cade
Research shows that VOCs can play a central role in the development of cancers and endocrine disruptions. Presently, the Environmental Protection Agency regulates more than 200 VOCs through the Clean Air Act, all of which have known, documented toxic effects.
Despite the well-known effects of these substances on human health, the PACT Act 2022 does not include VOCs on the list of toxic agents for which the Department of Veterans Affairs (VA) provides compensation. Notably, more than 20 diseases are recognized here in conjunction with toxic exposure, many of which are also caused by VOCs. This creates a paradoxical situation where a veteran exposed to VA-recognised chemicals receives compensation, while another veteran exposed to VOCs and developing the same condition does not. In the latter case, this veteran needs to undergo an extensive process to prove causality, collect data on exposure and link it to their diagnosed illness, often without the benefit of clear documentation or acknowledgment from military records.
Why VOCs Are Not Yet Listed Under the PACT Act
The VA has a complicated process for recognizing toxic agents for which compensation is provided. One of the first steps here is a systematic evaluation of the existing scientific literature on a specific toxic compound.
The same procedure is used for expanding the list of presumed diseases under the PACT Act, where this evaluation is concentrated on evidence linking a specific toxic agent with a disease.
Notably, VOCs are not one single compound, but rather hundreds of compounds for which research is significantly scattered. At the moment, consistent data is available for trichloroethylene (TCE), where epidemiological studies, as well as research using animal models and physiologically based pharmacokinetic (PBPK) models, demonstrate that TCE has carcinogenic effects and can also impact multiple organs. Subsequently, until more comprehensive data is available for other VOCs, these will probably remain unrecognized by the Act.
Another issue here is the dose-dependent effect of VOCs. There is sufficient data to demonstrate that VOCs produce toxic effects in a dose-dependent manner, meaning that the more these substances are inhaled, the more likely it is for adverse health outcomes to occur.
The Department of Defense has no current system in place to document VOCs exposure. This means that demonstrating a clear exposure history becomes virtually impossible for most veterans, especially those deployed in combat zones or working in high-risk maintenance roles where VOCs were routinely used.
Moreover, without records and documentation of exposure, VOCs are also problematic to be introduced as presumptive.
Nevertheless, considering that the VA’s mission is to provide equitable care and support for all veterans impacted by service-related exposures, the department should work towards prioritizing better documentation of VOC exposure and systematically reviewing existing literature to identify compounds with sufficient evidence of harm.
VOCs Exposure in California Veterans
VOCs exposure is particularly common in Air Force bases because of the routine use of industrial solvents, degreasers, and jet fuels in aircraft maintenance, fueling operations, and equipment cleaning.
In California, George Air Force Base, March Air Force Base, and Travis Air Force Base are all EPA superfund sites because of contamination with various toxic chemicals, including VOCs.
California has one of the largest veteran populations in the nation, counting almost 1,300,000 people.
In 2023, 1.337 of these veterans lived in Santa Cruz, a county with proximity to former and active military installations. Veterans from this region who served at bases with known VOCs contamination now face significant challenges when seeking recognition and compensation for health issues tied to VOC exposure.
This PACT Act omission reflects a broader systemic oversight, where the fragmented nature of VOC research and lack of exposure documentation allow a known hazard to persist without institutional accountability and without compensation for those who were exposed in the line of duty.
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Jordan Cade is a lawyer and advocate for civil justice working at the Environmental Litigation Group, P.C., a Birmingham-based firm dedicated to representing clients in environmental and toxic exposure cases.