The Army Says Burn-Pit Exposure Can Be Combat-Related.
Now We Need to Talk About What That Means.
There is a phrase I keep running into when discussing military deaths, toxic exposure, disability, and survivor recognition:
“But it wasn’t combat.”
Usually what people actually mean is:
He wasn’t shot.
There wasn’t an IED.
He didn’t die on the battlefield.
And that is where our understanding of the word combat-related becomes far too narrow.
Because the Army's own regulations and policies recognize something more complicated.
Sometimes the thing that harms a service member is not an enemy bullet.
Sometimes it is the military environment itself.
Sometimes it is the smoke they breathed every day while serving in a combat zone.
And according to the Army, under certain circumstances, that burn pit can be an instrumentality of war.
Yes, the Army Actually Said That
On August 14, 2025, the United States Army Physical Disability Agency issued a memorandum titled:
“Application of Instrumentality of War Coding for Unfitting Condition(s) Resulting from Burn Pit Exposure in a Designated Combat Zone.”
Its purpose was to provide guidance on applying combat coding to conditions caused by fumes from open-air burn pits during contingency operations.
And then it says something remarkably important:
“Open-air burn pits, as defined in reference f, and located in combat zones, are instrumentalities of war…”
That is not an advocate's interpretation.
That is the Army's language.
Think about that for a moment.
An open-air burn pit in a qualifying combat zone can be considered an instrumentality of war.
Not merely an occupational hazard.
Not just unfortunate environmental exposure.
An instrumentality of war.
What Does “Combat-Related” Actually Mean?
This is where military terminology gets messy.
People often use “combat-related” as though it means only one thing: a service member was directly injured by enemy action.
But that isn't how the Army defines it.
Army Human Resources Command describes several pathways through which an injury or disease may be considered combat-related, including:
direct result of armed conflict;
hazardous service;
conditions simulating war; and
an instrumentality of war.
Those are different categories.
A Soldier does not necessarily have to be shot by the enemy for a condition to be classified as combat-related.
For instrumentality-of-war determinations, the Army says there must be a direct causal relationship between the instrumentality and the disability. It specifically recognizes that illness can result from military fumes, gases, explosions, ordnance, or material.
That distinction matters enormously when we talk about toxic exposure.
Being in a Combat Zone Is Not Enough
There is an important limitation here.
Merely developing cancer, respiratory disease, or another illness while serving in Afghanistan, Iraq, or another combat zone does not automatically make the condition combat-related.
There still has to be a connection between the exposure and the condition.
That is reasonable.
A Soldier who develops an unrelated illness while deployed does not automatically have a combat-related disability simply because of geography.
But once the government recognizes both pieces of the chain, things get interesting:
Combat-zone burn pit → toxic exposure → disease caused by that exposure.
The Army has now established that the first part of that equation can be an instrumentality of war.
That changes the conversation.
And This Gets Personal for Me
My husband, Sgt. Jeremy “Jay” Seals, served in Afghanistan.
A few years later, he developed Stage IV stomach cancer.
He eventually died while serving on active duty.
His military records determined his condition was in the line of duty, and the VA ultimately recognized his death as service-connected.
For years, though, I have watched military systems place deaths into different boxes.
Combat.
Noncombat.
Killed in action.
Service-connected.
Gold Star.
Surviving family.
As though the human body particularly cares which bureaucratic box caused it to fail.
Jay did not come home from Afghanistan with a bullet wound.
He came home with something much harder to see.
Like thousands of others, he came home having breathed the air around military operations.
And years later, cancer showed up.
That is one of the great complications of toxic exposure.
The battlefield sometimes follows you home.
Delayed Does Not Mean Unrelated
Toxic exposure does not behave like a gunshot wound.
A gunshot is immediate.
Exposure-related illness may take years or decades to appear.
That delay created enormous problems for Vietnam veterans exposed to Agent Orange.
It created problems for Gulf War veterans.
It created problems for Iraq and Afghanistan veterans exposed to burn pits and other airborne hazards.
The injury may have occurred during deployment.
The disease may not announce itself until much later.
That does not magically relocate the origin of the injury.
The Army's burn-pit memorandum appears to recognize exactly that problem by allowing qualifying conditions resulting from combat-zone burn-pit exposure to receive instrumentality-of-war coding.
But Here Comes the Bureaucratic Fun
Because apparently military policy can never have just one definition when seventeen will do.
Combat-related disability is not necessarily the same thing as Killed in Action.
And it is not automatically the same thing as Gold Star eligibility under every law, program, organization, or benefit.
Those terms arise from different statutes, regulations, policies, and organizational definitions.
That distinction is critical.
The August 2025 memorandum is guidance to the Army Physical Disability Agency concerning combat coding for unfitting conditions caused by open-air burn-pit exposure. It does not say that every veteran who later dies from a burn-pit-related disease must be reclassified as KIA.
It does not create an automatic Gold Star designation for every toxic-exposure death.
And I am not going to pretend it does.
But it raises a question our military community should be willing to confront.
If the Cause Is Combat-Related, Why Do We Treat the Death as Though Combat Had Nothing to Do With It?
That is where this gets uncomfortable.
Imagine two service members.
One is injured immediately by an instrumentality of war and dies.
The other is exposed to an instrumentality of war, develops cancer years later because of that exposure, and dies from the disease.
The timeline is different.
The mechanism is different.
The grief certainly is not.
Yet our recognition systems can treat those families very differently.
And sometimes nonprofit programs, scholarships, recognition programs, and support services use even narrower definitions than the government.
That can leave families in an incredibly strange position.
The government may say:
The disease was service-connected.
The Army may say:
The exposure involved an instrumentality of war.
Records may say:
The death occurred while on active duty and in the line of duty.
And someone else may still say:
But that doesn't count as a combat death.
At some point, we have to ask whether our categories are accurately describing military sacrifice or merely preserving administrative traditions.
Burn Pits Were Part of the War Environment
Burn pits were not suburban backyard fire pits somebody happened to wander past.
They were used during military contingency operations to dispose of enormous amounts of waste in deployed environments.
Service members did not choose their exposure.
They breathed what was in the air because that was where their country sent them to serve.
The August 2025 memorandum specifically defines qualifying combat zones broadly enough to include presidentially designated combat zones, certain hazardous-duty areas where hostile-fire or imminent-danger pay applies, and some areas supporting combat operations under specified conditions. ~Army Regulation 635-40 (AR 635-40), which is the official U.S. Army regulation governing Disability Evaluation for Retention, Retirement, or Separation
In other words:
The Army understands the military context.
We should too.
Service-Connected and Combat-Related Are Not Opposites
This is another misconception worth killing off.
People sometimes speak as though a death must be either service-connected or combat-related.
Those aren't necessarily competing categories.
Service-connected generally answers one question:
Was the condition connected to military service?
Combat-related classification asks a more specific question:
Did it arise through one of the recognized combat-related circumstances?
A condition can therefore be service-connected and potentially also combat-related.
The second classification simply requires additional criteria.
That is why this memorandum matters.
It identifies qualifying combat-zone burn pits as an instrumentality of war.
I Am Not Asking the Army to Rewrite History
I am asking it to apply its own logic consistently.
If a military burn pit operating in a combat zone is an instrumentality of war...
and a Soldier was exposed to that instrumentality...
and that exposure caused a disease...
and that disease ultimately caused the Soldier's death...
then we should at least be willing to discuss whether that death has a combat-related origin.
Not emotionally.
Not because someone wants a prettier title.
Not because one family's grief is somehow worth more than another's.
Because that is where the evidence and the Army's own terminology may lead.
Why This Matters Beyond One Family
This is bigger than Jay.
Thousands of military families have spent years trying to understand how exposure-related illnesses fit into military recognition systems designed around immediate battlefield injuries.
The PACT Act helped change how the government handles toxic-exposure claims.
Now military policy is beginning to confront another layer of the issue:
What does “combat-related” mean when the weapon that harms you doesn't kill you immediately?
That question matters for retirees.
It matters for disability determinations.
It matters for veterans.
And yes, it matters for surviving families.
Because military sacrifice does not always arrive with a Purple Heart attached to it.
Sometimes it arrives years later in an oncology office.
We Need Better Definitions, Not a Grief Hierarchy
I have said this before and I will keep saying it:
Grief should not be a competitive sport.
Recognizing toxic-exposure deaths does not diminish those who were killed by enemy fire.
Recognizing training deaths does not diminish combat deaths.
Recognizing service-connected deaths does not take anything away from anyone else.
The military community is large enough to honor different forms of sacrifice without creating a caste system of bereavement.
And acknowledging that an exposure was combat-related does not rewrite what happened.
It describes what happened more accurately.
Jay wasn't shot in Afghanistan.
He didn't step on an IED.
But if the environment created by military operations exposed him to toxins that ultimately caused the cancer that killed him, then saying “that wasn't combat-related” becomes much harder to defend when the Army itself says qualifying combat-zone burn pits are instrumentalities of war.
That doesn't answer every question.
But it changes the question considerably.
The Question I Am Asking Now
I am not claiming that this memorandum automatically gives my husband, or anyone else, a particular survivor designation.
I am asking something more basic.
If the United States Army recognizes a burn pit in a combat zone as an instrumentality of war, what happens when exposure to that instrumentality ultimately kills a service member?
Where does that death belong?
What records should reflect it?
What recognition should follow?
And should a family really be told that the death was service-connected but somehow unrelated to combat when the underlying exposure came from something the Army itself categorizes as an instrumentality of war?
Those are questions worth asking.
And I intend to keep asking them.
Because sometimes advocacy begins with finding one sentence buried inside government policy and asking everyone in the room to explain what it actually means.
This time, that sentence is pretty damn clear:
Open-air burn pits located in combat zones are instrumentalities of war.
Now let's talk about what happens to the people they killed.
Source note: The principal document discussed here is the U.S. Army Physical Disability Agency memorandum dated August 14, 2025, Application of Instrumentality of War Coding for Unfitting Condition(s) Resulting from Burn Pit Exposure in a Designated Combat Zone. The memorandum cites AR 635-40, DoDI 1332.18, DoDI 4715.19, and federal statutes governing combat-related disability determinations.
This post discusses military policy and terminology for educational and advocacy purposes. Individual disability, survivor, casualty, and recognition determinations depend on the applicable statute, regulation, facts, and responsible agency.
