Oil-well fire smoke
EPA-led monitoring found high particulate levels while sulfur dioxide and hydrogen sulfide were generally insignificant during monitored periods. Plume location, duration, and symptoms remain veteran-specific.
1990–1991 and Southwest Asia service
Gulf War Exposures
The Gulf War was a multi-exposure environment: more than 600 burning oil wells, pesticides, pyridostigmine bromide pills, Khamisiyah nerve-agent concerns, depleted uranium, sand, fuels, exhaust, vaccines, and environmental stressors.
All wartime eras
Hazards and evidence questions
Khamisiyah
Sarin and cyclosarin concerns require unit-location evidence, modeled hazard dates, alarms or protective posture, and consideration of other cholinesterase-inhibiting exposures.
Pesticides and PB pills
Individual records can be incomplete. Statements should identify issue and use of pills, application methods, frequency, and acute neurologic, skin, respiratory, or gastrointestinal symptoms.
Gulf War illness
Persistent fatigue, pain, cognitive difficulty, headache, GI symptoms, sleep disturbance, dizziness, and respiratory complaints may fit an undiagnosed illness or medically unexplained chronic multisymptom illness pathway.
Watch this first
Gulf War veterans: VA health care and benefits
VA’s briefing for veterans of the 1991 Gulf War, including the undiagnosed and medically unexplained illnesses that still get denied for the wrong reason. It tells you what VA offers. It does not tell you how to document the six months of chronicity that decides most of these claims, which is why so many are denied on a technicality rather than on the medicine.
Source: U.S. Department of Veterans Affairs, official channel
Accuracy safeguard: Reported estimates place Gulf War illness at about 25%–30% of 1990–1991 Gulf War veterans, but definitions and study methods vary.
Unique and shared
What this generation is up against
On paper the 1991 Gulf War veteran holds the most generous rule in the entire compensation system. Under 38 CFR § 3.317, a qualifying chronic disability arising from an undiagnosed illness or a medically unexplained chronic multisymptom illness is presumed service-connected with no nexus opinion required at all. In practice, denial rates in this population stay high, and the reason is procedural rather than medical. An examiner gives the symptoms a conventional label — this is not undiagnosed, it is irritable bowel syndrome — and the rater then treats § 3.317 as inapplicable and denies direct service connection for want of a nexus. The claim is defeated by being answered under the wrong regulation.
The evidence problem compounds it. Pyridostigmine bromide tablets were handed out by the blister pack and almost never charted in an individual health record. Pesticide application was constant and unrecorded. The Khamisiyah plume modeling has been revised more than once, and unit locations were reconstructed from records years after the fact. “I was there and I am sick” loses. What wins is a file that documents each symptom domain separately — fatigue, pain, gastrointestinal, neurologic, skin, respiratory — with the date of onset, persistence of six months or more, the effect on work, and the name of the regulation it wants applied.
Two veterans of the same conflict rarely carry the same claim, and veterans of different conflicts often carry the same one. The first panel is what belongs to this era alone. The second is the layer this era shares with the rest of the site — and it is the layer that reopens old denials.
Only this era
Unique to the 1991 Gulf War
Six months of deployment in an environment that has no parallel in any other era, and one regulation written for this population alone.
- More than 600 Kuwaiti oil wells burning at once. Smoke plumes crossed encampments for months. Environmental monitoring at the time recorded high particulate levels, while sulfur dioxide and hydrogen sulfide were generally insignificant during the periods monitored — which is exactly why the particulate argument, not the gas argument, is the one that holds.
- Pyridostigmine bromide pretreatment tablets, issued against the threat of nerve-agent attack, with no individual dosing record in most health records.
- The March 1991 demolition of the Khamisiyah ammunition depot, and the sarin and cyclosarin plume the Department of Defense later modeled across units in the area.
- Depleted uranium in armor and munitions — with a dedicated VA follow-up program and, importantly, no presumption attached to it.
- Heavy pesticide use: permethrin-treated uniforms, DEET, pest strips in living quarters, and area application of organophosphates and carbamates by service members with no training in it.
- The § 3.317 pathway itself. It is a regulation written for this population and it exists nowhere else in the compensation system.
Crosses eras
Shared with veterans of other eras
Desert Shield and Desert Storm veterans are routinely told the burn pit laws are for the younger generation. That is wrong, and it costs claims.
- The PACT Act presumptions begin on August 2, 1990. Every burn pit and particulate matter presumption that covers an Iraq or Afghanistan veteran also covers a Desert Storm veteran who served in Bahrain, Iraq, Kuwait, Oman, Qatar, Saudi Arabia, Somalia, or the United Arab Emirates.
- The § 3.317 Gulf War pathway is shared with post-9/11 veterans of Southwest Asia service. It did not end in 1991.
- Automatic burn pit registry participation. Since August 1, 2024, VA has been adding veterans to the Airborne Hazards and Open Burn Pit Registry from Department of Defense records for service between August 2, 1990 and August 31, 2021. You are likely already in it.
- Sand, dust, and fine particulate, diesel generator exhaust inside living areas, and JP-8 fuel vapor — identical to the post-9/11 exposure profile.
- Asbestos, solvents, lead, and hazardous noise, which run through all five eras on this site and are decided on the facts of the job in every one of them.
Conditions
What these exposures can cause
This era has two separate presumptive authorities and most veterans only know about one. They do not overlap, they do not cancel each other, and a denial under one says nothing at all about the other. Read both lists before you decide what to file.
Presumptive, no nexus needed
The § 3.317 Gulf War presumptions
For qualifying Southwest Asia service, these are presumed service-connected without any medical opinion connecting them to service. The disability must be chronic — six months or more — and at least 10 percent disabling.
- Chronic fatigue syndrome
- Fibromyalgia
- Functional gastrointestinal disorders, including irritable bowel syndrome, functional dyspepsia, and functional abdominal pain syndrome
- Undiagnosed illness presenting as fatigue, muscle or joint pain, headache, sleep disturbance, cognitive or memory problems, skin signs, respiratory signs, gastrointestinal signs, or neurologic signs
- Nine listed infectious diseases: brucellosis, Campylobacter jejuni, Coxiella burnetii (Q fever), malaria, Mycobacterium tuberculosis, nontyphoid Salmonella, Shigella, visceral leishmaniasis, and West Nile virus
- Amyotrophic lateral sclerosis, presumed under 38 CFR § 3.318 for any veteran with 90 days or more of continuous active service, in any era
Presumptive
The PACT Act presumptions, for these same veterans
Covered service starts August 2, 1990 for Bahrain, Iraq, Kuwait, Oman, Qatar, Saudi Arabia, Somalia, and the United Arab Emirates, plus the airspace above. These 23 conditions are presumed service-connected with no exposure proof and no nexus:
- Asthma that was diagnosed after service
- Chronic bronchitis
- Chronic obstructive pulmonary disease
- Constrictive or obliterative bronchiolitis
- Emphysema
- Granulomatous disease
- Interstitial lung disease
- Pleuritis
- Pulmonary fibrosis
- Sarcoidosis
- Chronic rhinitis
- Chronic sinusitis
- Head cancer of any type
- Neck cancer of any type
- Respiratory cancer of any type
- Gastrointestinal cancer of any type
- Reproductive cancer of any type
- Lymphoma of any type
- Lymphomatic cancer of any type
- Kidney cancer
- Brain cancer
- Melanoma
- Pancreatic cancer
Facts-found and secondary
Argued on the facts, and often worth more
These are not on either list. They are granted when the exposure, the diagnosis, and the opinion are in the file — or when they grew out of something already service-connected.
- Parkinsonism and tremor disorders following organophosphate, carbamate, and pyridostigmine bromide exposure
- Peripheral neuropathy and persistent cognitive impairment, documented by testing rather than by complaint
- Chronic migraine, which is frequently misfiled as an undiagnosed headache symptom when it is separately ratable at a higher level
- Obstructive sleep apnea secondary to service-connected rhinitis, sinusitis, or respiratory disease
- Depression, anxiety, and post-traumatic stress disorder secondary to years of chronic pain and unexplained illness
- Autoimmune and thyroid disease, and bladder or kidney disease following solvent and fuel exposure
38 CFR § 3.317 and the PACT Act are separate authorities with separate requirements. A denial under one is not a decision about the other, and both can be pleaded in the same claim. One caution on timing: § 3.317 sets a presumptive period for when the disability must have become manifest, and that period has been extended repeatedly by regulation. Check the current period before you assume you are outside it.
Rating criteria
Possible ratings, spelled out
These three codes carry most of the rating weight in this era, and all three are rated on frequency and function rather than on any laboratory finding. That cuts both ways: there is no test that can contradict you, and no test that can speak for you either. A symptom diary and a provider who charts it are the evidence.
DC 6354Presumptive under § 3.317
Chronic fatigue syndrome
38 CFR § 4.88b
100%
Debilitating fatigue, cognitive impairments, or a combination of other signs and symptoms which are nearly constant and so severe as to restrict routine daily activities almost completely, and which may occasionally preclude self-care.
60%
Symptoms which are nearly constant and restrict routine daily activities to less than 50 percent of the pre-illness level, or which wax and wane resulting in periods of incapacitation of at least six weeks total per year.
40%
Symptoms which are nearly constant and restrict routine daily activities to 50 to 75 percent of the pre-illness level, or which wax and wane resulting in periods of incapacitation of at least four but less than six weeks total per year.
20%
Symptoms which are nearly constant and restrict routine daily activities by less than 25 percent of the pre-illness level, or which wax and wane resulting in periods of incapacitation of at least two but less than four weeks total per year.
10%
Debilitating fatigue, cognitive impairments, or a combination of other signs and symptoms that wax and wane but result in periods of incapacitation of at least one but less than two weeks total per year, or the symptoms are controlled by continuous medication.
There is no 30 percent and no 50 percent tier under this code — the schedule jumps from 20 to 40 to 60 to 100. Note 1 defines an incapacitating episode as a period of acute signs and symptoms severe enough to require bed rest and treatment by a physician. Bed rest you decided on yourself does not count; bed rest a physician ordered does. That single sentence decides most of these ratings.
DC 5025Presumptive under § 3.317
Fibromyalgia
38 CFR § 4.71a
40%
Symptoms that are constant, or nearly so, and refractory to therapy.
20%
Symptoms that are episodic, with exacerbations often precipitated by environmental or emotional stress or by overexertion, but that are present more than one-third of the time.
10%
Symptoms that require continuous medication for control.
The schedule defines widespread pain for this code as pain in both the left and right sides of the body, that is both above and below the waist, and that affects both the axial skeleton and the extremities. Forty percent is the ceiling here, which is why fibromyalgia is so often paired with separately rated conditions — and why a file that stops at fibromyalgia alone is usually under-rated.
DC 8100Facts-found, or secondary
Migraine headaches
38 CFR § 4.124a
50%
Very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability.
30%
Characteristic prostrating attacks occurring on an average of once a month over the last several months.
10%
Characteristic prostrating attacks averaging one in two months over the last several months.
0%
Less frequent attacks.
Prostrating means the attack stops you — you lie down in the dark and you cannot function. If your headaches are charted as “headache, given medication” with no description of what you had to stop doing, you will be rated at zero or 10 percent no matter how often they come. A dated log showing each attack, its duration, and what work you missed is worth more here than any imaging study.
When a condition has no diagnostic code of its own, 38 CFR § 4.20 allows VA to rate it by analogy to a closely related code. That choice can change the ceiling on your rating entirely — an undiagnosed multisymptom illness rated by analogy to fibromyalgia is capped at 40 percent, while the same picture rated under chronic fatigue syndrome can reach 100 percent. Which analogy VA picked is worth checking on every Gulf War decision.
Combine your ratingsEligibility
Who qualifies — and how to file
Three separate doors, and in this era it is common to qualify through more than one at the same time. Naming all of them in a single claim is not greedy; it is how you keep the rater from answering the wrong question.
Door 1 — The § 3.317 Gulf War pathway
Active military service in the Southwest Asia theater of operations on or after August 2, 1990. No exposure proof required, no nexus opinion required. The disability must be chronic — six months or more — and at least 10 percent disabling.
What the file needs
Proof of Southwest Asia service on the DD-214 or personnel recordEach symptom domain named and dated separatelyDocumentation that symptoms persisted six months or moreWork and daily-function impact, in writing
Door 2 — The PACT Act presumptions
The same service on or after August 2, 1990 in the listed countries brings you inside the 23-condition burn pit and particulate matter list. Many veterans in this era were denied for asthma, sinusitis, rhinitis, or cancer years before this list existed, and never refiled.
What the file needs
Covered location and dates of serviceA diagnosis named exactly as it appears on the listPrior denial letters, if any — they set up a Supplemental ClaimNo exposure proof and no nexus opinion required
Door 3 — Direct and secondary service connection
For everything the two lists do not cover: parkinsonism, neuropathy, cognitive impairment, sleep apnea, and the mental health conditions that follow years of unexplained illness. This is where the accredited work usually happens.
What the file needs
Unit, every location, and every duty actually performedDocumented exposure — pesticides, tablets, oil-fire smoke, depleted uraniumA diagnosis supported by objective testing where testing existsAn opinion connecting it to service or to a service-connected condition
The filing sequence, in order
Order matters more than speed. Every step below is free, and the first one protects money you have not been awarded yet.
- 1
File the Intent to File first, today
VA Form 21-0966An Intent to File locks your effective date for one year. Everything you are later awarded is paid back to the date VA received that form, not the date you finished gathering evidence. It takes minutes and costs nothing.
- 2
File the claim and name every diagnosis separately
VA Form 21-526EZOne form can carry many conditions, but each one has to be named. "Breathing problems" is not a claim; asthma, chronic sinusitis, and chronic rhinitis are three claims with three sets of criteria, and each is rated on its own before the ratings are combined.
- 3
Pull the exposure record VA already holds
The Individual Longitudinal Exposure Record compiles what the government already knows about where you served and what was there. For exposure that is not on a presumptive list, ask for a Toxic Exposure Risk Activity determination under 38 U.S.C. § 1168 — that determination is what turns an unlisted exposure into a developed one.
- 4
Decide whether you want representation
VA Form 21-22aForm 21-22a appoints an accredited agent or attorney; form 21-22 appoints a veterans service organization. Representation is never required. No one may lawfully charge you a fee to prepare or file an original claim.
- 5
If a decision is already wrong, choose the correct lane
VA Form 20-0995 / 20-0996 / 10182A Supplemental Claim (20-0995) is for new and relevant evidence. Higher-Level Review (20-0996) is for a decision that got the existing evidence wrong and allows no new evidence. A Board appeal (10182) is for the law itself. Choosing the wrong lane can cost a year and, in the worst case, an effective date.
One line to remember when you write your claim: name the regulation. A claim that says “please consider 38 CFR § 3.317 and, in the alternative, direct service connection” is far harder to answer with a single conventional diagnosis than a claim that just lists symptoms. Filing is free, and no one may lawfully charge a fee to prepare or file an original claim.
Sign up for the VA registry
Three VA programs you are eligible for
This era has more health-surveillance programs attached to it than any other, and most veterans are enrolled in one without knowing it and missing the other two. All three are free, and none of them is a claim.
- The Gulf War Registry health exam. Free, with no copay and no requirement to be enrolled in VA health care. Covers service on or after August 2, 1990 in Bahrain, Iraq, Kuwait, Oman, Qatar, Saudi Arabia, or the United Arab Emirates; in the Persian Gulf, Arabian Sea, Gulf of Aden, Gulf of Oman, or Red Sea; or in the associated airspace, during Desert Shield, Desert Storm, Operation Iraqi Freedom, or Operation New Dawn.
- Eligibility for that exam is based on your own recollection of service — no Department of Defense confirmation is required first, and it is not a compensation and pension examination.
- The Airborne Hazards and Open Burn Pit Registry. Since August 1, 2024 VA adds eligible veterans automatically from service records for service between August 2, 1990 and August 31, 2021 — no exposure and no symptoms required. Anyone eligible for the Gulf War Registry exam is included. Participation is optional and you may opt out.
- The Depleted Uranium Follow-up Program, run out of the Baltimore VA Medical Center. Open to service members and veterans with active duty in the 1990 to 1991 Gulf War, Bosnia, Operation Enduring Freedom, Operation Iraqi Freedom, or Operation New Dawn. Priority goes to anyone in or near a vehicle struck by friendly fire, and to those who performed rescue or salvage work or were near burning depleted uranium. It is a questionnaire plus a spot urine test.
- Family members are not eligible for any of these exams.
How to get on the registry
For the Gulf War Registry exam and to check whether you are already in the burn pit registry, contact the Environmental Health Coordinator at your VA medical center, or call MyVA411 at 800-698-2411, available 24 hours a day, seven days a week. For the Depleted Uranium Follow-up Program, ask your VA provider for the referral to the Baltimore VA Medical Center program.
MyVA411, 24 hours a day800-698-2411
There is no presumption of service connection for depleted uranium, and being listed in any registry is not evidence that you were exposed. The registries document your health; the claim is what pays. File both.
Need this looked at by a doctor?
Registry exams and exposure evaluations start with a clinician. Our doctor page has the words to use at the appointment, the direct phone number and VA email of the exposure coordinator at your own VA medical center, and every VA registry you can sign up for.
Who else this touched
The family this era reached
Gulf War illness and its multisystem symptoms can be disabling enough to reach a permanent and total rating — which opens health care and education doors for the whole household. If a service-connected Gulf War condition contributes to death, survivors have a DIC pathway that is frequently overlooked.
- DIC for survivors when a service-connected Gulf War condition causes or contributes to death (38 C.F.R. §§ 3.5, 3.22).
- CHAMPVA health coverage for dependents of a veteran rated permanently and totally disabled.
- Chapter 35 Survivors’ and Dependents’ Educational Assistance (DEA) for a spouse and children.