CARC is a polyurethane paint that provides superior durability, extends service life for military vehicles and equipment, provides surfaces with superior resistance to chemical warfare agent penetration, and greatly simplifies decontamination. Established DOD occupational safety and health guidance called for proper personal protective equipment, including respiratory equipment, to protect painters. Several compounds in CARC formulations, if taken into the body in sufficiently high concentrations, may cause short- and long-term health effects. The most notable of these compounds is hexamethylene diisocyanate (HDI), which hardens, or plasticizes, the paint. Exposure to high concentrations of aerosolized HDI during spray painting leads to immediate respiratory irritation and watery eyes. Long-term exposure can cause or aggravate respiratory problems, in particular, asthma. The use of personal protective equipment, such as respirators, coveralls, eye protection, gloves, and head coverings, can prevent or minimize exposures to HDI. The HDI in polyurethane paint does not present a hazard after the paint dries and cures, unless exposed to heat sufficient for thermal decomposition of the coating, such as welding.

Solvents used in CARC and paint thinners, as well as solvents used to clean equipment, can be hazardous via skin contact and breathing. Exposures to solvents can lead to dizziness, rashes, and nausea. However, the proper wear of personal protective equipment greatly decreases the risks associated with exposure to solvents.

The purpose of this report is to:

• Clarify the issue of who could have been exposed to the hazards of CARC in theater;
• Discuss the scenarios under which CARC exposures could have occurred in theater;
• Describe the health effects associated with exposure to CARC; and
• Present recommendations for improvements in the policy regarding CARC to improve future usage.

Beginning in September 1990, a small group of Department of the Army civilians from Anniston, Alabama established the first in-theater painting operation at the port of Ad Dammam, Saudi Arabia (referred to as the Anniston Ad Dammam site). This group, experienced in CARC painting operations, arrived with their own personal protective equipment, including paint suits, gloves, boot covers, and air-purifying respirators. The 900th Maintenance Company, a National Guard unit from Alabama, assumed operation of this paint site in February 1991.

In addition, the Army Materiel Command established two major new CARC spray painting operations in-theater at the Saudi Arabian ports of Ad Dammam and Al Jubayl in December, 1990, to process the majority of the Army equipment arriving in theater. The 325th Maintenance Company, of the Florida Army National Guard, operated these sites. The members of the 325th Maintenance Company lacked training or experience in CARC spray paint operations and the necessary personal protective equipment. By the time the two main painting sites had ceased operations in February 1991, a total of over 8,500 vehicles and other equipment had been painted in theater.

In addition to the two major CARC painting sites manned by the 325th, a number of smaller CARC painting facilities were established throughout the theater. These smaller sites operated for shorter periods and generally used brush and roller painting application techniques, rather than spray painting.

In April 1991, before redeployment from the Kuwait Theater of Operations, the Army’s VII Corps reestablished painting operations in Ad Dammam and Al Jubayl to return tan vehicles to their original woodland camouflage paint schemes. Initially, personnel from the 325th Maintenance Company staffed these operations, but were later replaced by members of the incoming VII Corps. Altogether, these sites processed over 8,000 vehicles and other equipment, painting them with woodland CARC before shipping them to Europe, the United States, or other destinations.

During the painting operations, some servicemembers in the 325th Maintenance Company began reporting health problems. Prompted by these complaints, health and safety inspectors visited the major CARC painting sites on several occasions throughout the period from December 1990 through June 1991. With few exceptions, the inspection reports cited weak overall command and control, serious deficiencies in the type and quantity of personal protective equipment available, and soldiers who had not received sufficient training and information regarding the potential hazards associated with CARC paint operations. The inspections also revealed that some soldiers exhibited symptoms consistent with exposure to CARC.

These inspections brought some positive changes. The quality and availability of the personal protective equipment improved, additional training was provided, and in some instances, paint operations were suspended until the safety deficiencies were corrected. Air-supplied respirators, replacement air hoses, air compressors, gloves, and eye protection, as well as explosion-resistant lighting and electrical outlets, became increasingly available. Nevertheless, some of this equipment did not arrive at the paint sites until months after the initiation of painting activities. Equipment failure and maintenance difficulties, as well as inconsistent adherence to proper health and safety procedures by painters and their chain-of-command, were some of the factors that led to the persistent problem of unsafe working conditions.

Following their deployment, some service members from the 325th Maintenance Company communicated their CARC painting experiences and concerns to their US representative, Charles Canady of Florida’s 12th District. A series of correspondence between the congressman and DoD officials discussed the issues of CARC exposures and follow-on medical care for Operation Desert Storm National Guard members. The matter was referred to the National Guard Bureau for investigation. The National Guard Bureau Inspector General (IG) issued an assessment addressing health care issues for veterans of Operations Desert Shield and Desert Storm in June 1994.

A number of veterans of the 325th Maintenance Company have sought treatment or assistance from the military health system or the Department of Veterans Affairs health care for symptoms they believe to be linked to their Gulf War exposures. The Department of Veterans Affairs has linked the illnesses suffered by some of the members of the 325th to exposures to CARC. The process of evaluating and treating veterans of the 325th Maintenance Company continues to the present day.

Veterans have voiced concerns about health problems that they attribute to their exposure to CARC. The most frequently cited symptoms are: coughing, eye and throat irritation, skin rashes, headaches, nausea, and asthma—symptoms often indicative of adverse health effects resulting from exposures to the HDI in CARC and the solvents often used in the related mixing, spray application, and clean-up activities. In a number of cases, personnel who were directly involved in the major spray painting operations of CARC were diagnosed with respiratory ailments that could be attributed to exposure to CARC (although other, unknown causitive factors cannot be ruled out). However, this investigation cannot definitively link CARC paint to the undiagnosed illnesses reported by Gulf War veterans that were not engaged in painting operations.

The Office of the Special Assistant for Gulf War Illnesses developed three important findings from its investigation of CARC painting performed in the Gulf theater. These lessons and recommendations are summarized below.

Some soldiers reported that a number of standard operating procedures, including painting vehicles with CARC, were modified in the rush to mobilize personnel and equipment for Operations Desert Shield and Desert Storm. In some cases, safety considerations were disregarded or otherwise compromised. In the future, military operational planning should incorporate measures to meet occupational safety and health standards even under "surge requirements". Prior planning should improve the military’s ability to quickly establish austere, field-expedient, but safe CARC painting sites. Advance hazard awareness training and education would help prevent or minimize risky practices and needless exposures. In the future, the CARC-painting mission should be assigned to appropriate units before deployment—units that could rapidly obtain the required occupational and safety training and guidance, procure personal protective equipment, and plan for the assignment of direct, qualified oversight by trained, certified safety and occupational health professionals.

Upon their return to the United States, members of the 325th Maintenance Company left active duty without completing post-deployment occupational health evaluations, missing the opportunity to identify and document many of the problems they encountered. To prevent the recurrence of this type of situation, the services (including the Reserve Component) need to insure compliance with medical surveillance policies and procedures aimed at establishing both a baseline (pre-deployment) health status of individuals, and capturing any deployment-related exposures and health symptoms after their return from deployments.

The redeployment painting operations conducted in-theater were better organized and more established than were the field-expedient operations initially established for tan painting. Nevertheless, routine safety inspections continued to document numerous problems. Occupational Safety and Health Administration (OSHA) regulations do not apply to combat operations. However, redeployment operations should strictly adhere to OSHA regulations. In addition, existing DOD guidance governing safety and occupational health issues in deployment settings were not observed in numerous cases.

Subsequent sections of this report will examine issues relevant to CARC painting and include:

• A description of CARC, including technical information, health and safety standards, and doctrine available prior to the Gulf War;
• An examination into the use of CARC during the Gulf War, including the locations and major units involved; and
• A discussion of the medical care for the 325th Maintenance Company following the Gulf War.

Tabs A and B contain an acronym and abbreviation listing, a glossary, and a bibliography. See Tabs C through E for a technical discussion of CARC specifications and formulations, examples of solvents used in painting operations, and a discussion of safety and health regulations, respectively. Tab F provides a brief summary of the changes in to the interim report.

This investigation used the following methods to determine the chronology of events:

• Interviews of veterans who were directly involved with, or had knowledge of, in-theater CARC painting operations;
• A thorough review of operational logs, memoranda, reports, and journals from classified and unclassified databases;
• Interviews of health and safety professionals who were in theater.

To compare actual CARC painting practices to established policies and procedures, investigators conducted interviews with health and safety personnel and reviewed technical guides, field manuals, training videocassettes, and Gulf War message traffic.

Investigators, in coordination with the Army Research Laboratory, the Army’s lead agency on all paints and coatings, conducted a thorough review of technical specifications of CARC. Investigators placed emphasis on identifying any CARC compounds that could cause or contribute to adverse health effects.

We reviewed medical literature to determine what health effects—acute and/or chronic—may be associated with CARC’s chemical components.

To obtain a clearer picture of the types and levels of care provided to soldiers involved in painting operations, investigators contacted military physicians and specialists working with the Department of Defense Comprehensive Clinical Evaluation Program (CCEP). These physicians and specialists conducted follow-up medical examinations on a number of soldiers involved with the painting operations. The Department of Veterans Affairs shared summarized information about the symptoms and diagnoses as reported for the 325th Maintenance Company.

The U.S. military relies on paint to achieve a variety of visual and mechanical effects, ranging from camouflage to unit identification to the protection of metal surfaces. CARC-painted surfaces resist the absorption of chemical warfare agents, making decontamination much easier to accomplish. Chemical agent resistant coatings—CARC—make up the largest category of paints applied to the U.S. military’s inventory of equipment. CARC’s ability to conceal and protect improves the survivability of tracked and wheeled vehicles, artillery pieces and missile launchers, rotary and fixed-wing aircraft, and support equipment such as communications vans, water purification units, generators, and forklifts.

The Army developed the first chemical agent resistant coatings in 1974. The Army made the decision in 1983 to require all combat, combat support, tactical wheeled vehicles, aircraft, and essential ground support equipment (i.e., tactical equipment) be painted with CARC.[1] This decision initiated the development of the CARC protocol as it exists today. As a result of stringent health and environmental regulations, lead and hexavalent chromium were removed from CARC and the levels of solvents or volatile organic compounds (VOCs) were reduced. These actions occurred before the Gulf War.[2]

CARC is essentially a low gloss version of automotive-grade polyurethane paint. These coatings provide the standard characteristics of any protective finish: corrosion resistance, durability, identification marking, etc. However, CARC formulations provide some unique properties that distinguish them from typical commercially-available paints.

Chemical agent resistant coatings all have a very matte finish, or extremely low gloss, to minimize visual detection due to glare or reflection from the sun or other bright light sources.

Because chemical warfare agents are unable to penetrate the coating, a standard military decontaminating solution, such as decontaminating solution number two (DS2), can readily neutralize surface chemical contaminants on CARC-painted vehicles.[3] CARC’s resistance to a variety of chemicals and solvents, and its ability to withstand weathering—including exposure to sunlight—has made CARC the paint of choice for outdoor use in a military-operational environment.

While all colors of CARC are chemically similar, the pigmentation additives in CARC formulations have unique properties and characteristics that make them particularly suitable for military operations. For example, the base green color—referred to as Green 383—used in the common three-color woodland pattern employed throughout the military, uses two types of pigments with reflectance properties in the near-infrared region of the spectrum. The combination of these pigments mimics the reflectance properties of chlorophyll present in living foliage, such as tree leaves and grasses, and thus minimizes detection of woodland-scheme CARC-painted equipment by near-infrared detectors. Another color, Tan 686, was reformulated with higher reflectance pigmentation to reduce the amount of solar heat vehicles would absorb, which was a serious concern during Operation Desert Shield. A subsequent color change, designated Tan 686A, increased the reflectance properties of the coating. Initial supplies of CARC available in the early stages of Operation Desert Shield were Tan 686.

As new batches of CARC were manufactured to meet the supply needs, Tan 686A became the standard.[4] See Tab C for a discussion of CARC formulations.

All color variations of CARC must meet stringent military specifications. The typical formulation of these finishes consists of three primary groups of raw materials: the resin or binder system, the pigment package, and the solvents.

As a means of standardizing the paint formulations manufactured by various suppliers, the military uses a system of military specifications (MIL SPEC). The military specification lists all the requirements of the paint, including composition, color and spectral reflectance properties, and label markings. In addition, the military maintains a list of approved suppliers called the qualified products list (QPL) as another control measure to ensure the consistency, quality, and performance of its paints. The military procures CARC only from suppliers on the qualified products list. The Army Research Laboratory has rigorously tested the products of the manufacturers listed on the QPL for conformance to all specifications of performance and composition.[5] See Tab C for a detailed discussion of the military specifications and qualified products list for CARC.

1.  Identification of Compounds of Concern

Because polyurethane paint has been commercially available for years, documentation exists about the hazards and toxicity of this category of paints. While it is well known that the isocyanates found in polyurethane paints pose the most significant health risks, solvents in the paints, thinners, and cleaning products are also known to pose a secondary health risk, if absorbed in sufficient quantity.[6]

Most of the components of CARC are not unique; almost any polyurethane paint contains them. Hexamethylene diisocyanate (HDI) is the only isocyanate found in CARC.[7] Inhalation of airborne droplets containing HDI released during spray paint applications is a well-documented hazard.[8] Direct skin contact to wet CARC is another avenue of exposure that causes irritation of the skin and mucus membranes, and possible absorption of solvents.[9]

Dry CARC poses no known health threat unless disturbed by sanding, grinding, extreme heat, or other conditions that could produce CARC dust, fumes, or vapors. Welding or cutting CARC painted surfaces results in the airborne release of HDI, carbon monoxide, and other toxic materials.[10]

Solvent exposure may occur as a result of contact with any solvent-based paint, including CARC, due to the high volatility (the ability to vaporize readily) of most solvents. Solvent exposure can occur during the surface preparation phase, however, in the Kuwait Theater of Operations, minimal surface preparation occurred.[11]

Solvents are released from CARC during the drying and curing process. These solvents are readily absorbed through the skin and through the respiratory tract.[12,13] Thinners are often added to the paint solution to achieve the correct spray paint viscosity. As the thinners evaporate, excessive solvent concentrations may occur, especially in areas with minimal airflow or ventilation.[14]

Exposure to solvents also occurred during the Gulf War when a variety of solvents were used to clean painting equipment and tools. Some of the solvents used for this purpose were locally procured, and therefore, the identity of all the solvents used in theater is not known.[15]

Tab D presents a listing of the solvents found in some of the paints and thinners most likely used during the CARC painting operations in the Gulf theater. This tab includes information on permissible exposure limits, lower explosive (flammable) limits in air (LEL), concentrations which are immediately dangerous to life or health (IDLH), odor characteristics, health effects, and target organs.

2.  Possible Health Effects of Hexamethylene Diisocyanate and Solvents

Exposure to isocyanates and solvents without proper protection can be harmful. Isocyanate exposure, including exposure to the HDI found in CARC, can cause three types of health effects:

• Almost all persons exposed to relatively high concentrations of isocyanates will develop irritation to skin and the respiratory tract;
• A small proportion of persons who are chronically exposed can become sensitized and develop asthma;
• A small proportion of persons who are chronically exposed can develop hypersensitivity pneumonitis.

At high concentrations, isocyanates can cause non-specific irritation of the mucous membranes and respiratory tract in some individuals, even after relatively short-term (minutes to hours) exposures.[16] At high concentrations, HDI causes shortness of breath, chest pain, chest tightness and cough and is extremely irritating to the eyes, nose, and throat, causing watery eyes and burning sensations.[17,18] At high enough concentrations, nearly all exposed persons will exhibit some or all of these short-term symptoms, but when the exposure stops, the symptoms will generally resolve rapidly.[19]

A small proportion of individuals exposed to HDI over a period of months to years may develop asthma.[20] This occurs sometimes even at relatively low concentrations over time.[21] Sensitization to isocyanates after exposures of shorter duration (days or weeks) is unlikely.[22,23,24] However, once a person is sensitized to isocyanates, an exposure to levels as low as the parts-per-billion range can cause the onset of episodes of wheezing, shortness of breath, chest tightness, and coughing.[25,26,27] Sensitized persons may suffer progressive worsening of respiratory symptoms with recurrent exposures.[28] When exposures stop, the asthma may resolve; on the other hand, it may be persistent and may be triggered by other factors, such as tobacco smoke, cold air, or exercise.[29,30] The general, worldwide population diagnosed with asthma ranges from 5 to 10%.[31]

Hypersensitivity pneumonitis, though uncommon, is another known effect of chronic exposure to isocyanates. The symptoms of hypersensitivity pneumonitis can be severe, and, in most cases, abnormalities will appear on chest X-ray and pulmonary function tests. Symptoms, which usually occur about three to eight hours after exposure, include repeated bouts of fever, muscle aches, headaches, malaise, shortness of breath, dry cough, and chest tightness. Removal from exposure is usually mandatory. Sometimes the condition persists, even when no longer exposed to isocyanates. In such cases, medications such as steroids may be necessary.[32,33,34]

Some solvents found in CARC are readily absorbed through the respiratory tract and skin.[35,36] Exposure to high concentrations of solvents can lead to non-specific central nervous system effects, ranging from headaches or dizziness, to more serious effects, including staggering gait, nausea, vomiting, or loss of consciousness.[37,38] At high levels, solvent vapors can also cause irritation of the eyes, skin, mucous membranes, and respiratory tract. If exposures are brief (for example, an eight-hour shift), these irritant and central nervous system effects are generally transient and resolve rapidly after cessation of exposure.[39,40] Nevertheless, chronic, long-term exposure to solvents can cause skin rashes, usually leading to an irritant dermatitis, characterized by dryness, scaling, and cracking of the skin, especially of the hands.[41]

Long-term exposure to solvents has been associated with increased rates of chronic central nervous system symptoms, such as fatigue, irritability, depression, headaches, poor concentration, and forgetfulness.[42] These chronic effects generally occur only after several years of heavy exposure (many experts estimate a threshold to be about ten years of relatively heavy exposure).[43] Some solvents can cause peripheral neuropathy, which means damage to the nerves in the arms and legs.[44] CARC does not contain the solvent compounds that are most closely associated with this type of nerve damage.

Workers occasionally develop liver or kidney disease after either long-term exposure or a massive single over-exposure to some solvents. Generally, chlorinated solvents cause these effects. CARC does not contain chlorinated solvents. A few solvents, such as benzene, are known or suspected to be human or animal carcinogens (cancer-causing agents),[45] but CARC has been specifically formulated to eliminate these types of solvents.

Tab E provides a detailed discussion of safety and health requirements for CARC painting operations, including Occupational Safety and Health Administration (OSHA) and National Institute of Occupational Safety and Health (NIOSH) requirements, as well as military guidance for conducting CARC paint operations. The tab also includes a discussion of material safety data sheets and the hazard communication program. A direct comparison of the exposures during the Gulf War to existing standards is theoretical since no workplace sampling or measurements were taken during the war. These standards are discussed in detail in Tab E and in the applicable cited references, but the most important aspect of this discussion is that there were no measurements taken during the Gulf War for direct comparison. Obviously, this has hampered retrospective efforts to evaluate the frequency, intensity, and duration of exposures, and their subsequent medical or health effects.

Nevertheless, two conclusions can be drawn. First, current Army and federal occupational and safety directives require the use of personal protective equipment, including respiratory protection, during polyurethane (CARC) spray painting operations. Second, based on experience and professional judgment of the health and safety professionals monitoring the CARC painting operations in-theater, unprotected personnel who were spray painting CARC in the conditions documented in the Gulf were exposed to potentially hazardous conditions.

The commitment of U.S. forces to the Kuwait Theater of Operations in support of Operations Desert Shield/Desert Storm (ODS/DS) required the rapid, large-scale deployment and build-up of troops and equipment to Southwest Asia from the continental United States and Europe. Because much of this equipment, particularly from the U.S. Army’s Germany-based VII Corps, arrived in-theater painted in woodland camouflage colors, Central Command directed that units repaint their equipment with tan CARC to enhance troop and equipment survivability. The U.S. Army XVIII Airborne Corps painted a significant portion of its combat vehicles tan prior to deployment. For this reason, CARC painting in the Kuwait theater of operations focused mostly on the VII Corps vehicles.

From the early planning stages, the U.S. military anticipated that only a limited number of vehicles would be painted with tan CARC. There were three primary constraints:

1. the urgent massing of combat power in tactical assembly areas could not be slowed by painting operations;
2. the existing paint-application capability of the Army Materiel Command (AMC) could not be expanded to paint every vehicle in theater; and
3. the existing supplies of CARC were limited. VII Corps established painting priority to combat vehicles (i.e., Abrams tanks, Bradley Fighting Vehicles, and engineer breaching equipment), as well as to command and control vehicles (i.e., M577 tracked command vehicles and M113 armored personnel carriers).[46]

The shortage of CARC was a key issue of concern. VII Corps considered two options. The first option was to paint as many of the lead or first vehicles in theater as possible, and hope that additional CARC would become available for later-arriving units. The second option was to paint only priority vehicles from lead units and save enough CARC to paint the priority vehicles of units arriving later. If more CARC than anticipated arrived, CARC would be sent to the tactical assembly areas to paint lower priority vehicles that had already passed through the port. VII Corps selected the second option.[47,48]

The port support authority and the port assistance task force (TF), TF North, assisted the Army Materiel Command and the 325th Maintenance Company as they established the paint site in Al Jubayl. They informed units of the process to prepare and paint vehicles, and they coordinated support provided to the civilian and military painters.[49]

The increasing supply of CARC to the theater eventually allowed almost all tracked vehicles on the list of priority vehicles to be painted. Eventually units were given the latitude to allocate CARC to other vehicles.[50]

By the time large-scale painting at the port ceased in February, the original mission given by the VII Corps commander had been achieved—3,500 priority vehicles painted—without slowing the movement of units into tactical assembly areas. In addition, 5,000 other vehicles were painted.

The port support authority sent 4,700 gallons of paint to the tactical assembly areas to paint additional vehicles. Army Materiel Command provided technical experts to short-term paint sites in the tactical assembly areas, including sites in the 1st Armored Division sector and one in the 3rd Armored Division sector.[51] The VII Corps Artillery, the 7th Engineer Brigade, and Detachment 1 of the 101st Military Intelligence Battalion, as well as the 207th Military Intelligence Brigade and 14th Military Police Brigade, were also provided with equipment and supplies to finish their priority vehicles in their tactical assembly areas. Brushes, rollers, and safety masks were purchased locally by the port support authority.[52] Table 1 shows the number of VII Corps vehicles, by unit, that were painted with tan CARC as of Feb. 14, 1991.[53]

Table 1. CARC painting tally as of Feb. 14, 1991

Before Operation Desert Shield began, a well-established set of regulatory guidance existed detailing the procedures for vehicle painting and safety and occupational health requirements. Army technical manuals of that period required that CARC be applied to all combat, combat support, and combat service support equipment. To assure the most effective CARC protection, approved directions for surface preparation involved the following steps:

1. remove loose paint by light sandblasting;
2. wash cleaned areas with a specified liquid detergent cleanser;
3. allow surface to thoroughly dry; and
4. clean surface with solvent within four hours of detergent wash.[54] 

However, this protocol was not followed during the Gulf War. Instead, vehicles received minimal surface preparation and CARC was applied to the existing coating.

Significant additional pre-war guidance existed in Army Technical Manual 43-0139, "Painting Instructions for Army Materiel." This includes descriptions and warnings of undercoats, finish materials, and related materials, drawings of proper paint patterns, vehicle inspection procedures, and descriptions of painting equipment.[55]

A number of command directives were issued dictating procedures for vehicle painting. Unit maintenance managers at all levels were periodically informed of the changing priorities and policies. As an example, a point paper written in the early stages of the U.S. deployment listed several major potential hazards to avoid. Among them was the failure to properly follow established safety procedures when painting with CARC.[56]

A notable portion of the policy disseminated during Operations Desert Shield/Storm related to small scale, unit-level painting. This type of painting was limited to touchup, or spot-painting, using brushes or rollers. Policy dictated the use of at least half-face respirators with organic vapor cartridges, but medical surveillance during the operation was waived unless the painting operation exceeded 30 days. However, the wearers of respirators were to be fit-tested and medically cleared prior to beginning work. Spray painting, sand blasting, and power sanding was to be limited to large-scale maintenance operations. Policy also required workers and supervisors to review material safety data sheets before spot painting. The policy prohibited the use of solvents for surface preparation prior to spot painting.[57]

References to painting procedures at the division maintenance level is found in Gulf War military message traffic. Within VII Corps, tanks, Bradley fighting vehicles, command and control vehicles (e.g., M577s and M113s), engineer breaching vehicles, fire support team vehicles (FSTV), and high mobility multi-wheeled vehicles (HMMWV) received priority at division maintenance spray sites. The unit owning the vehicles controlled the flow of the vehicles into the paint site,[58] not the unit painting the vehicles. Command guidance from Army Materiel Command explains that spray painting was only to be conducted in large maintenance areas to meet OSHA regulations, while unit level repainting was to be limited to brushes and rollers.[59]

In addition to the painting procedures applicable for painting ground vehicles, there was also a limited amount of instruction as to the proper way to paint Army aircraft. The high reflective desert-blending paint schemes for ground vehicles made aircraft three times more vulnerable to surface-to-air missiles. Therefore, the preferred CARC color for Army aircraft in the desert environment was either the low reflective green paint or the aircraft interior or exterior gray.[60]

The vast majority of in-theater painting was conducted at the ports of Ad Dammam and Al Jubayl, Saudi Arabia (see Figure 1). The Army Materiel Command, through the military supply system, supplied the equipment used to support these operations. The equipment included CARC, thinner, solvents, respirators, paint guns, compressors, and hoses. However, because of the urgent need for new and replacement equipment, some of the equipment used during the operations was procured locally from Saudi sources. Plastic hoses, used to carry paint or air, frequently required replacement because they melted and cracked from the high local temperatures. Various solvents were also regularly purchased locally. The locally-procured equipment varied in quality, but served a necessary function in allowing the paint operations to proceed.[61,62] Figure 2 provides a timeline of major events associated with paint operations during the Gulf War. These events will be discussed in greater detail.

Figure 1. Locations of Ad Dammam and Al Jubayl

Figure 2. Timeline of major events associated with in-theater painting

1. Department of Army Civilians/900th Maintenance Company at the Port of Ad Dammam

A group of approximately 16 Department of Defense civilians from Anniston Army Depot established the first large-scale, in-theater painting operation in late September 1990 at the port of Ad Dammam. In addition, a small number of civilian contract personnel from various private companies joined them.[63] For purposes of clarity, this operation will be referred to as the Anniston Ad Dammam site.

The Anniston Army Depot personnel set up the paint operation in three large maintenance tents—one for preparatory work and two for painting. They used the preparatory tent for taping and greasing, a process that covers the parts of the vehicle that are not to be painted, such as headlights.[64,65,66] The painters found the evening hours unsuitable for painting due to the high nighttime humidity levels along the Arabian Gulf coast. Atmospheric moisture condensing on the vehicles altered the tint of the paint. Consequently, they painted during the morning and afternoon hours, for up to 16 hours each day.

The painters applied CARC directly on top of the existing CARC surface, without the use of primers and with only minimal surface preparation. Two painters, each equipped with spray guns, painted each vehicle. The larger of the two paint tents accommodated two vehicles at one time, while the smaller paint tent could accommodate only one. Consequently, a total of six painters usually worked at any given time. These two-painter teams usually worked for about one to two hours in their respective paint tents before being replaced by another team.[67]

The experienced CARC painters from Anniston Army Depot brought personal protective equipment with them to the Gulf theater. This equipment included respirators, paint suits, gloves, and boot covers. Several persons from this group report differing types and levels of availability of respiratory protective equipment when painting activities began.[68] By mid-January, the operation had matured significantly, and full-face, air-supplied respirators and other personal protective equipment were available. Based on interviews with several Anniston Ad Dammam paint site civilian painters in 1998, no adverse health effects from the CARC paint operation were reported in our interim report dated February 24, 2000.[69] Subsequently, several civilian painters from Anniston told us of reported respiratory problems that they associate with their CARC painting experiences in the Gulf War.[70] Their comments and concerns were forwarded to the Army's Office of the Surgeon General who has agreed to arrange for further medical follow-up through the occupational medicine clinic at Anniston Army Depot.[71]

In late February of 1991, the 900th Maintenance Company, an Alabama Army National Guard unit, arrived at the Anniston Ad Dammam paint site. The 900th Maintenance Company was a general support maintenance unit primarily tasked to repair tanks. However, the unit had some experience using paint guns, respirators, and personal protective equipment.[72] Following repairs in the maintenance shop, vehicles would go through the paint tents. About ten soldiers from the 900th Maintenance Company operated the two paint tents used at this site. This group painted approximately 100 vehicles during the tan-painting operation.

A small portion of the group from the Anniston Army Depot remained at the Anniston Ad Dammam site to help train painters and supervise this paint operation. In this configuration, the majority of the painting was done by the soldiers of the 900th,[73] which ensured a smooth transition of the operation to the control of the 900th Maintenance Company. Conversations with several veterans from the 900th have indicated that they believed that their respiratory equipment differed slightly from that used by the civilians. That is, they reported that the civilian painters used better-quality personal protective equipment. There were no identified adverse health reactions experienced among the military paint teams as a result of the painting operation.[74]

Figure 3 shows the command hierarchy for the 325th and 900th Maintenance Companies. These units conducted large-scale CARC spray painting operations in the Kuwait theater of operations.

Figure 3. Command relationships of units involved

2. 325th Maintenance Company

a.  Tan CARC Painting Operations at the Ports of Ad Dammam and Al Jubayl

The 593rd Area Support Group (ASG) assigned the 325th Maintenance Company, a Florida Army National Guard unit, to establish and operate the theater’s two high-volume paint sites, one at Ad Dammam and one at Al Jubayl. (See hierarchy of command chart in Figure 3.) This unit was a direct support maintenance company with no trained painters.[75] It is important to note that the site operated by the 325th at Ad Dammam was a new site, and was not a part of the site established earlier at Ad Dammam by the civilians from Anniston Army Depot. The Ad Dammam paint site operated by the 325th will henceforth be referred to as the 325th Ad Dammam paint site, while the Al Jubayl site will be referred to as the 325th Al Jubayl paint site.

Though the operations were planned prior to the arrival of the bulk of the Army’s equipment, the available evidence differs as to the degree to which the operations complied with applicable occupational safety and health precautions. Both the commander of the 593rd ASG and the commander of the 176th Maintenance Battalion stated that the operations commenced with adequate safety measures in place. The commander of the 593rd believed that the operations met OSHA standards (i.e., the occupational safety standards that civilian operations are required to meet). The commander of the 176th explained that an air-purifying respirator was available for each painter. He also reported that safety inspections at the sites had verified that appropriate safety precautions were in place.[76,77]

Although several senior officers indicated that adequate safety measures were implemented, a number of soldiers directly involved with the day-to-day painting operations and various safety officials have contested these claims, stating that proper safety procedures were not in place at the two major paint operations. The officer in charge of the painting operation explained that the greatest problem was a shortage of proper personal protective equipment. From the beginning of the operation, his unit had trouble acquiring parts and equipment. Equipment often took weeks to be delivered to the sites following a request.[78,79,80]

The paint sites established by the 325th at the ports of Ad Dammam and Al Jubayl began operations in December, 1990. The 325th sites consisted of four to six large maintenance tents, with one tent used from time to time for vehicle preparation by vehicle crews. Preparation rarely involved more than spraying off the vehicles with water, occasional light sanding or scraping, and taping and greasing the vehicle windows. The tent flaps were generally left open to allow natural ventilation. Only on occasions when there was a great deal of wind were the tent flaps closed. No engineering ventilation devices, such as fans and blowers, were used in the in-theater painting operations. As a result, there was typically a noticeable cloud of paint overspray outside the maintenance tents. Figure 4 shows four paint tents at Al Jubayl.[81,82]

Figure 4. Paint tents at Al Jubayl

Daily status reports for CARC painting activities at the Al Jubayl paint site during December 1990 and January 1991[84] recorded the number and type of vehicles and equipment painted per day. The number varied significantly from none to over 200 per day depending on a variety of factors, including the weather, the number of priority vehicles at the site, and the operating status and availability of painting equipment. The status reports also included information on the personnel involved, any problems, concerns or safety issues encountered, dignitary visits, and other comments. Many daily reports do not identify problems or safety concerns, however, the following issues are identified:

• Limited quantities of paint thinner and filters for respirators;
• Locally purchased thinner is inadequate for painting at night;
• Compressors breaking down and replacement compressors missing fittings; and
• Hazardous waste disposal.[85]

The majority of the 325th Maintenance Company (roughly 200 people) were directly involved in the painting operations at the two sites. There were approximately 70 soldiers from the unit assigned to each site at any given time, with members of the unit periodically rotating in from assorted duties at the port. There were generally three shifts of paint teams per day at each site. Typical shifts were 7 am-3 pm, 3 pm-11 pm, and 11 pm-7 am, although 12-hour shifts were also in place at times. The urgent need to paint as many vehicles as quickly as possible resulted in round-the-clock painting operations despite the concerns noted earlier with nighttime painting. The soldiers at the 325th Ad Dammam paint site slept in buildings about a mile away from the paint site. At the 325th Al Jubayl paint site, however, the soldiers slept in tents that were approximately 50-200 yards away from the paint tents. In fact, the paint tents, showers, mess storage, latrines, and sleeping quarters were all collocated in a topographical depression about a city block in length and width, outside of the port of Al Jubayl. As a result, some of the personnel assigned to the site indicated an overspray haze often shrouded the entire 325th Al Jubayl paint site compound.[86]

In general, the most important health and safety issue associated with a CARC painting operation is the proper use of personal protective equipment. The primary complaint of many of the soldiers from the 325th was that the appropriate personal protective equipment was not available to them during the painting operations. Numerous reports of unsafe practices have been received from veterans, including the use of face shields taped to standard military helmets, torn paper coveralls, standard issue chemical protective masks, improper mask filter cartridges, and paper surgical masks. Members of the 325th had no formal training and little practical experience as painters, and received no training in the use of air-supplied respirators.[87]

Due to soldier complaints, improved personal protective equipment was gradually phased-in at the 325th Ad Dammam and Al Jubayl paint sites. For example, within several weeks of the beginning of the paint operations, air-supplied respirators, proper gloves and coveralls, and air hoses arrived. Explosion-resistant lighting was also added at a later date. The air-supplied respirators significantly improved the respiratory protection of the painters. Figure 5 shows a soldier from the 325th wearing air-supplied respiratory protection while spraying tan CARC onto a tank. However, soldiers mixing CARC or helping to carry hoses were reportedly not always given respirators.[88] The compressors in use at the site reportedly broke down frequently and were inadequate. By March, the paint team received a high-pressure compressor, that was capable of supporting more than one respirator through a manifold system.[89] In addition, due to a shortage of air hoses, the air compressors (which carry the air from a source to the painter’s respirator) were placed in close proximity to the paint tents. As a result, air contaminated with some amount of overspray could have been pumped into the respirators. Painters from different shifts reportedly shared these respirators, yet rarely cleaned or serviced them.[90]

Figure 5. A member of the 325th Maintenance Company spray paints desert tan CARC onto a tank

Training and education is another important aspect of health and safety. Soldiers contacted for this investigation have complained that requests for training were generally ignored by their leaders, and material safety data sheets, as well as military training tools such as video tapes[92] and guidance (which are supposed to be readily accessible), were rarely available.[93]

A number of soldiers from the 325th experienced symptoms in-theater that they attributed to exposure to CARC. Eight members of the 325th were interviewed about the symptoms that they or others experienced while working with CARC. Several members of the 325th developed respiratory symptoms, including cough and chest tightness, promptly after starting to work with CARC. In addition, several members developed other symptoms, including headaches, nausea, vomiting, and dizziness, that are consistent with exposure to solvents.[94] There were no reports of instances of serious health problems such as hypersensitivity pneumonitis[95] which can be associated with severe exposure to the HDI in CARC. However, some soldiers were sent back to the unit’s headquarters at Ad Dammam to be temporarily removed from the paint detail.[96]

b.  Green CARC Painting Operations for Redeployment

Shortly after the cessation of hostilities in the Kuwait Theater of Operations, there was an immediate need to plan and execute the large-scale redeployment of over half a million U.S. troops to their Stateside or European bases and installations For VII Corps, this involved returning a large number of vehicles to Europe. Many of these vehicles had been painted desert tan and needed to be returned to their original woodland camouflage pattern suitable for central Europe. By mid-March the commander of VII Corps had issued guidance that the Corps was to attempt to repaint all tracked and wheeled vehicles and helicopters with the three-color CARC woodland camouflage pattern prior to returning to Europe. The VII Corps Command suggested that this be accomplished at the ports of Al Jubayl and Ad Dammam.[97] Due to the experiences from the pre-war painting operations, military planners anticipated that the redeployment operations would be safer and would adhere more closely to established military guidelines. A safety sheet and concept of operations document, for example, directed the strict safety measures and processes that were to be followed at the Al Jubayl site.[98,99]

The requirement to paint vehicles with the three-color woodland pattern, rather than the previous, uniform olive drab, was reemphasized on March 23rd by the 22nd Support Command (SUPCOM).[100] However, by April 13th, this requirement had been altered. Instead of the three-color woodland pattern, the SUPCOM planned for one coat of olive drab paint.[101] This guidance ultimately proved to be the final decision, as those vehicles that were painted prior to redeployment only received one coat of olive drab. This coating was put directly on top of the existing (tan) CARC layer, which was often the same coating hastily applied just a few months earlier. Many of the tan coatings were in poor shape, with paint visibly flaking off due to the lack of surface preparation prior to paint application.[102] Nevertheless, surfaces were generally only washed with water before the redeployment olive drab coating was applied. Army Materiel Command (AMC) reported on the morning of April 24th that this redeployment painting would begin the following day.[103]

Redeployment painting operations were reestablished in Ad Dammam and Al Jubayl. The redeployment painting operations saw improved working conditions. Improved training and guidance along with appropriate personal protective equipment and other task-related equipment were in place before the initiation of painting. For example, from the outset, full-face air-supplied respirators were available. Unfortunately, there is some evidence that respirator and compressor filter maintenance, at least, were still not up to approved safety standards. Further, not all of the air compressors in use were designed to provide breathing quality air, called Grade D. Instead, some of the air compressors were standard shop compressors designed for routine maintenance tasks.[104,105] Likewise, not all personal protective equipment was suited to the task; examination of paint hoods by a 22d SUPCOM civilian safety professional officer revealed that paint was getting into some of the hoods.[106,107,108]

In addition to the general improvement in personal protective equipment, a significant improvement in safety was made with the relocation of the 325th Al Jubayl paint site to higher ground, roughly one mile away from the sleeping, eating, and administrative areas of the operation. This site was set-up in a line along a road that was roughly 75 feet wide and 1000 feet long. Figure 6 shows the arrangement of paint tents at the 325th redeployment paint site at Al Jubayl. Figure 7 shows the location of the 325th Al Jubayl paint site and layout of its major features. In mid-May, after about a month of operating the redeployment sites, the 325th Maintenance Company turned over site operations to personnel from VII Corps.[109]

Figure 6. The redeployment paint site at Al Jubayl was set-up along an unused road

Figure 7. Location and major features of the VII Corps redeployment paint site at Al Jubayl

Rather than immediately taking over the paint operations, VII Corps suspended operations until the arrival of additional safety equipment.[112,113] By May 10, 1991, VII Corps had commenced full-scale painting. By this time, almost 20,000 gallons of paint, 4,000 gallons of paint thinner, explosion-resistant lighting, and air compressors were on hand. The air-supplied respirators, air hoses, paint guns, and lighting were all new. In addition, carbon monoxide alarms, air pressure gauges, and respirator pre-filters were all available. This equipment was set-up in advance of the initiation of the paint operation by safety professionals.[114] Figure 8 shows a painter at the Al Jubayl redeployment paint site wearing a paint suit and air-supplied respirator with a cooling vortex—a vast improvement over some of the previous practices and procedures.

Figure 8. Painter wearing an air-supplied respirator

In addition to the paint site at Al Jubayl, units from VII Corps were tasked to operate a redeployment paint site at the port of Ad Dammam. This operation was established by safety professionals before the initiation of the painting operation. New air compressors, hoses, air-supplied respirators, filters, carbon monoxide alarms, explosive resistant lighting and electrical outlets, and various personal protective equipment were available at Ad Dammam.[116] Figure 9 shows the set-up of air compressors and filters used at the redeployment paint operation at Ad Dammam. This operation was located in the same general area of the port as the previous paint site at Ad Dammam operated by the 325th. Figure 10 shows the location of the paint site and the layout of its major features.

Figure 9. Alarm panel for a high-pressure breathing air system at Ad Dammam

Another in-theater redeployment paint operation was established at Camp Doha in Kuwait. This small-scale operation was established to apply tan paint to a number of olive drab-colored vehicles designated for continuing in-theater operations. The 11th Armored Cavalry Regiment (ACR), which arrived in-theater after the war’s end, took receipt of these vehicles from King Khalid Military City (KKMC) in Saudi Arabia. In late June, 1991, an advance party of Department of the Army civilians from the US Army Support Group set up the site, including safety inspections and electrical wiring.[118] The civilians stayed at the site for the first few days of the operation to train non-specialist members of the 11th ACR in painting and safety procedures. Given the attention to safety during the setup at Camp Doha, and the application of lessons learned during earlier in-theater CARC painting operations, this particular operation was considered by an in-theater safety officer to be safe. The operation ceased on July 11th, 1991, following a motor pool fire that resulted in the destruction of many of the 11th ACR’s vehicles, munitions, and equipment.[119]

A combined total of 3216 tracked and 5248 wheeled vehicles were painted olive drab during the redeployment at all sites.[120]

Figure 10. Location and major features of the VII Corps Ad Dammam redeployment site

3.  Other Sites

In addition to the painting done by the large-scale spray paint operations at Ad Dammam and Al Jubayl, a number of short-term, small-scale paint operations existed in theater. This follows the policy decision which allowed non-combat, lower-priority vehicles to move out of the port area without being painted tan. The 3rd Armored Cavalry Regiment (ACR) operated one such paint operation. In December of 1990, while in the vicinity of Camp Cactus (an assembly area several hundred miles west of Ad Dammam), members of the 3rd ACR were tasked to CARC paint vehicles. The unit tasked approximately three to six soldiers to spray-paint vehicles, and provided them with paper surgical masks for protection. However, the operation lasted only about three days, and the two painters from this group who were contacted reported that they had not experienced any adverse health effects attributable to CARC exposures, and were unaware of any such symptoms experienced by other paint detail members.[122] Other short duration, low-volume spray-painting operations, like the one undertaken at Camp Cactus, were not uncommon in the theater.

A number of other soldiers were also involved in short-term, spot/touch-up painting operations throughout the Kuwait Theater of Operations. Soldiers from the 24th Infantry Division and the 89th Military Police Brigade, for example, are known to have conducted spot/touch-up painting.[123] Adverse health effects from these types of operations would not be expected, and have not been reported. This is due to the use of brushes and rollers, rather than spray guns, which limits aerosolization of the paint. In addition, the short-term nature and less-intense workload of these smaller operations probably limited the extent of potential exposures.

Due to the safety hazards associated with CARC painting, it became necessary to conduct paint site inspections. The need for industrial hygiene and occupational medicine support for heavy maintenance and CARC painting was identified in October 1990, well before the bulk of U.S. forces were deployed.[124]

In late 1990, an environmental health surveillance group from the 105th Medical Detachment conducted an inspection at the Anniston Ad Dammam paint site. This medical surveillance group looked at the operation’s processes from an environmental and industrial hygiene standpoint. When the group arrived, they observed that the painters were using air-purifying respirators and were working 12-hour shifts. They also noted that there was one painter in each tent, with another painter doing touch-up work outside each tent. To improve safety procedures, the inspection team procured air-supplied respirators that arrived within a week. Each painter was eventually issued an individual air-supplied respirator. Despite these deficiencies, the surveillance unit observed no health problems and was not informed of any that had occurred prior to their arrival. The inspection team was very impressed by the maintenance team commander’s quick response to safety improvement suggestions. Given the urgency of the mission, the commander of the surveillance team felt that the protection measures being taken by the maintenance unit were sufficient.[125]

The 325th Maintenance Company’s Ad Dammam and Al Jubayl paint sites were inspected on several occasions. Individual members of the 325th Maintenance Company experienced overexposures to CARC painting during the week of Dec. 10, 1990. Symptoms exhibited indicated short-term exposure to solvents as well as to isocyanates. As a result, an industrial hygiene and safety evaluation was conducted from December 17-19 at the Al Jubayl painting operation. During the evaluation, discussions were held with the commander of the 176th Maintenance Battalion and with the commander and members of the 325th Maintenance Company. According to the report, "The cause of the overexposure resulted from inadequate engineering controls and inadequate use of appropriate respiratory protection and personal protective clothing." [126]

In a Dec. 15, 1990, memorandum, an Army Central Command (ARCENT) safety director reported on the situation at the 325th Ad Dammam paint site. The memorandum describes soldiers experiencing adverse health reactions to the painting duty, including rashes, vomiting, nausea, and dizziness. The memorandum goes on to explain that one of the officers from the 176th Maintenance Battalion, the unit under which the 325th falls, was "very concerned for the welfare of his soldiers but was also interested in doing the job." Despite well-established Army safety protocols, the 325th Maintenance Company was told to use standard-issue M-17 NBC masks for respiratory protection. These masks are filter respirators designed for protection against chemical warfare agents and do not have the proper filters to protect against the aerosolized isocyanates found in CARC.[127] Using them for industrial hygiene applications, especially painting, would rapidly degrade their ability to provide protection against chemical or biological warfare (CBW) agents, as the filters would quickly become saturated by paint and would require frequent replacement.

On Dec. 16, 1990, four inspectors from the 12th Medical Detachment arrived at the 325th Al Jubayl paint site to observe practices and procedures being followed by the 325th Maintenance Company’s painters. The inspection group consisted of an industrial hygienist, an occupational medicine physician, and two enlisted personnel. Upon arrival, the group noted that the painters were wearing chemical protection masks, assorted air-purifying respirators, and standard battle dress utility (BDU) uniforms with no protective overgarments. To correct this situation, the inspection team’s industrial hygienist bought enough certified low-pressure air-supplied respirators from a local store to equip the painters. The team also ordered several more respirators so that personnel participating in all aspects of the paint operation could have air-supplied respirators. Though no one present was qualified to fit-test soldiers for the air-supplied respirators, the inspection team’s industrial hygienist believed that the painters were still adequately protected. In addition, the team gave suggestions as to where the air compressors for the respirators should be placed for optimal performance and protection.[128,129]

While at the site, the occupational medicine physician evaluated 19 soldiers of the 325th Maintenance Company. The team physician found that five soldiers had symptoms possibly related to inhalation of solvent fumes, and fourteen soldiers had possible symptoms from contact with HDI in the paint. This physician recalls seeing nausea, dizziness, and conjunctival irritation (irritation to the mucous membrane of the eyes) in the painters.[130] Each soldier who was evaluated was personally briefed on appropriate safety measures, told to avoid further contact with the HDI-based CARC, and told that they could continue painting if they were totally protected from contact with the paint. No long-term after-effects were expected for the 19 personnel. Unit leaders were also briefed on proper safety procedures. The inspection team left the site on Dec. 19, 1990.[131,132]

Instructions were provided on the proper use of the respirator and the wearing of other protective equipment during the evaluation. In addition, other control measures were implemented to reduce exposures, including the establishment of a restricted area where certain levels of protective clothing were required depending on the job performed, 8-hour work shifts, a job rotation system, and the establishment of a break area away from the paint site.[133]

The actions taken by the 176th Maintenance Battalion were viewed as a practical and effective short-term fix for a low production painting operation (up to 50 vehicles per day). The evaluation report indicated that if a higher production rate was required (100 to 200 vehicles per day), health problems would resurface and additional controls would need to be implemented.

Health and safety recommendations for a higher production rate included:

• All personnel working in and around the CARC painting and mixing areas would require a full-face air-line respirator, approved personal protective clothing and equipment, and hand and foot protection (e.g. gloves and boot covers).
• Although air-line systems should be capable of providing breathing quality air, the location of the air intakes for the compressors must be in a protected area or an area as remote as possible from the source of contamination. Filtration systems must also be maintained according to the manufacturers’ specifications.
• Additional mechanical agitators and/or mixers would need to be acquired to reduce exposures due to the manual stirring and mixing of CARC paint.
• A steady flow of respiratory protective equipment and personal protective equipment would need to be delivered to the paint site. It might become necessary to locally purchase needed items if normal supply channels prove unable to provide the needed equipment on time.
• Fire extinguishers designed to extinguish flammable liquid fires would need to be placed in the vicinity of each painting or mixing operation. The solvent carriers for CARC paint are flammable.
• The concept of a restricted area and an emphasis on the importance of good personnel hygiene among unit members after they have finished painting operations needs to be enforced.
• A point-of-contact with the 12th Medical Detachment needs to be identified.[134]

In early April 1991, a safety official indicated that the tan CARC painting operations that had taken place through February did not meet safety standards and strongly recommended against the redeployment operations if they were going to be conducted in the same manner.[135] He also expressed doubts that a quality paint job could be conducted under the existing conditions and with the available resources.[136] Specific deficiencies requiring correction prior to the redeployment painting operations included:

• Maintain a safe distance of at least 50 feet between flammable liquids (e.g., paints and solvents) from potential sources of ignition;
• Ensure that all electrical equipment, including light fixtures, cord sets, switches, and other components in paint areas, as well as adjacent areas, are explosive proof;
• Ground and bond all equipment to prevent build up static electricity;
• Provide and maintain proper respiratory protection, including: use of approved pressure-demand or continuous flow type C, full-face piece, hood or helmet supplied air respirator; provision of filters, carbon monoxide alarms, and air coolers to air compressors; testing of breathing air; fit testing of respirators of selected personnel; medical screening and monitoring of personnel, including pulmonary function tests; and implementation of a maintenance program to clean, sanitize, repair, and adjust respirators;
• Ensure that spray operations are conducted in tents of noncombustible cloth or cloth that has been treated; and that the tents are cleaned of flammable overspray on a regular schedule;
• Provide all personnel involved in paint operations with respiratory training and hazard communication training;
• Provide stand-by emergency medical service and medical monitoring, as well as emergency decon facilities;
• Provide sufficient room to prevent downwind exposures to personnel.[137]

In late April/early May, 1991, shortly after the initiation of redeployment painting operations at the Ad Dammam port, a safety inspection and tour of the paint facility was conducted. Though the facility was a 22nd Support Command operation, the inspection team brought two VII Corps general officers through the 325th Ad Dammam paint site. The team was led by a VII Corps safety manager, and included a command surgeon and a second safety manager. This inspection revealed safety problems that were significant enough to warrant halting the paint operations. In particular, the safety manager found that the air compressors in use were not designed to supply quality air fit for breathing. Based on that assessment, the proper air compressors were ordered and flown to the site. Operations resumed several days later when the safety issues had been resolved.[138]

On the 25th and 26th of April, 1991, another inspection team visited the 325th Maintenance Company’s Al Jubayl and Ad Dammam paint sites. This team consisted of a civilian safety specialist and the industrial hygienist and one enlisted soldier from the 12th Medical Detachment’s December 16th inspection team. After conducting an inspection, the team noted a number of problems at each site. Some of the problems found at the 325th Al Jubayl site were:[139]

• Electrical lighting equipment used within the vapor hazard area was not explosion proof;
• Air compressors providing the breathing supply were not oilless, and carbon monoxide alarms were not present. Due to the load on the compressors, the generation of carbon monoxide (CO) and/or filter overload was determined to be imminent;[140]
• Filters used to remove foreign material from the breathing air did not appear to have been regularly serviced;
• Flammable debris, such as paint- and solvent-soaked rags, and open paint and solvent containers littered the area in and around the paint mixing and spraying tents;
• Personal protective equipment hoods for painters were insufficiently stocked; and
• Paint was reaching the inside of the hoods.

The inspection of the 325th Ad Dammam paint site disclosed many of the same safety deficiencies as were found at the 325th Al Jubayl site. Based upon an examination of the equipment and procedures being followed, the inspection team recommended that paint operations be suspended at the 325th Al Jubayl site and slowed at 325th Ad Dammam site. Additionally, the team suggested that the second paint site at Ad Dammam, planned to open for the 325th redeployment painting operation, not be opened until proper equipment was obtained.[141]

A memorandum written on April 28, 1991, by a safety officer from the US Army Support Group[142] echoed the results of the 325th Al Jubayl paint site inspections of April 25-26. This memorandum cited a number of specific safety deficiencies, including:

• Inadequate drying time was allowed following paint application, representing a fire hazard;
• Hazardous waste (i.e., empty paint cans) was not segregated from regular trash;
• Personal protective equipment was not being properly worn;
• General site control was poor, with vehicles creating dust;
• Vehicles, which had been painted with tan latex or unknown coatings, were peeling, yet were being painted over with green CARC;
• Continued pressure to increase or maintain high production numbers was creating potentially unsafe conditions.

Ultimately, the memorandum recommended that the paint operations conform to the original safety and process guidelines, including stricter standards about pre-painting preparatory work.

As a result of the April inspections of the 325th Maintenance Company’s paint sites, efforts were made to further improve the safety equipment. Safety officers from the 22nd Support Command (SUPCOM) worked to obtain breathable air compressors with carbon monoxide alarms, high pressure compressors with coolers, and additional dual cartridge respirators with organic vapor and high efficiency filter cartridge combinations.[143]

A safety inspection on May 24, 1991 at the Ad Dammam CARC paint site identified several deficiencies posing a severe medical threat to the workers, including:

• Persons in or in the immediate vicinity of the painting area were not wearing the proper personal protective equipment. Respirators were worn, however, gloves and paint suits were not.
• Soldiers using solvents for cleaning tools and equipment were not wearing personal protective equipment such as respirators, rubber gloves, long sleeve shirts, and aprons.
• Soldiers were not protected from exposure to noise hazards caused by generators, compressors, and vehicle traffic.

Several recommendations were made including:

• All personnel who work in or around the paint tents need to wear proper protective equipment. Personnel must not be allowed to take the easy way out by not protecting themselves.
• Soldiers cleaning tools and other equipment with solvents must follow the recommended protective equipment procedures. They should be wearing a respirator, rubber gloves, long sleeve shirt, and an apron or other outer protective clothing;
• The chain of command must inspect soldiers before they start any hazardous job to ensure that they are properly protected. Additionally, the chain of command must immediately correct any soldier who is not following proper safety precautions.
• All noise hazards must be identified and properly marked. If possible, the hazard should be eliminated by moving the source or constructing barriers to reduce the noise hazard to a safe level. Soldiers who work near or enter a noise hazard area must wear hearing protection. Track drivers must wear hearing protection.
• Soldiers may work in a noise hazard area, provided they are fitted with hearing protection and pending baseline audiograms. Army Regulation 40-5 requires that soldiers who are exposed to steady noise levels greater that 85 dBA be enrolled in a hearing conservation program.

The report concluded that the proper personal protective equipment has been made available to the soldiers. The report reiterated that it is the ultimate responsibility of unit commanders to ensure his or her soldiers are properly cared for by ensuring that they wear the required personal protective equipment (including hearing protection).[144]

On June 12, 1991, another site visit of the 325th Al Jubayl CARC site was conducted. As with the previous inspection, the inspecting officer found deficiencies in leadership and oversight that were significant enough that he felt compelled to recommend that the site be shut down immediately. Specifically, the following problems were cited at the 325th Al Jubayl paint site:

• The site safety officer and non-commissioned officer in charge were not available at the site until roughly three hours after the arrival of the inspection team;
• A copy of the standard operating procedures was not available on site;
• Several soldiers without respirators were seen near the paint tents;
• Several soldiers’ paint suits were ripped;
• Soldiers were punching holes in the solvent cans using metal screwdrivers. Solvents are very flammable and a spark can cause an explosion;
• The material safety data sheets for the paint and solvent were not posted or readily available.

The inspecting officer outbriefed the senior official at the site, who stated that his unit had never been briefed or shown a copy of the standard operating procedures.[145]

In the rush to deploy units to the Kuwait Theater of Operations, the Marine Corps faced many of the same hurdles as the Army. The Marine Corps attempted to acquire traditional tan CARC through the Defense Logistics Agency (DLA), but the DLA was unable to supply adequate supplies of CARC to the Marine Corps because the Army had already depleted their supplies. Marine Corps headquarters logistics offices in Quantico, Virginia, quickly located an alternate paint supplier[146] and a sole-source agreement was established with a manufacturer to provide a non-CARC, tan latex coating[147] which came in powder form and was fast, easy, and safe to apply. The powder was mixed with water, and the resultant paint was spread with a brush or roller. The temporary coating was not intended for spray gun application, and there is no evidence that spray gun procedures were used.[148] Although the coatings offered the visual tan camouflage that the Marine Corps needed, they did not provide many of the other advantages offered by CARC (e.g., ease of decontamination).

Many Marine units did not have time to wait for the temporary coating to arrive. As a result, a number of Marine units in the continental U.S. awaiting deployment to the Kuwait Theater of Operations bought tan paints locally. These coatings included household latex, alkyd paint systems, and lacquer paints. The locally-procured coatings and the non-CARC temporary coating were applied outside in open-air environments, both in the continental United States and in the Kuwait Theater of Operations. No Marine Corps vehicles were painted by the Army operations at either Ad Dammam or Al Jubayl.

Though conversations with Marine veterans have revealed no serious adverse health effects to this work, there have been reports of minor rashes experienced during the paint operations.[149] It is also important to note that the approved temporary coating used by the Marine Corps did not contain isocyanates. The use of respiratory protection for the application of the temporary coatings in these open-air environments was inconsistent, with air-purifying respirators and dust masks used in some cases, and no protection used in others.[150]

The Marine Corps redeployment policy on painting was different from the Army’s. Unlike the Army, no Marine vehicles returning to the United States were painted olive drab or woodland colors before redeployment.[151] Instead, the Marine Corps waited until their vehicles had returned to the continental United States to strip and repaint them.

The Air Force and Navy use a more common polyurethane coating. This type of coating closely resembles the high gloss coatings found on commercial aircraft. However, like the CARC used by the Army and Marine Corps, the Air Force and Navy polyurethane coatings have hexamethylene diisocyanate (HDI), found also in CARC, and a number of solvents. For this reason, the Air Force and Navy follow the same health and safety guidance that Army and Marine Corps operations follow for spray painting operations. These respiratory protection and painting procedural guidelines are part of Air Force and Navy doctrine.[152]

Many Air Force aircraft were in place prior to the air war, so there was not a significant volume of new aircraft queuing up for in-theater painting. As a result, most Air Force aircraft participating in Operation Desert Shield/Desert Storm did not require significant painting; if anything, nose, wing, and stabilizer leading edge surfaces (the front edges of the wings and tails) needed only occasional touch up work. At that level of activity, and considering the already in-place, dedicated, well-equipped painting facilities, complete with appropriate personal protective equipment, the overall health risk to aircraft painters was low. Similarly, the Navy was limited to touch up painting of the aircraft and helicopters using long-established ship board procedures.[153]

As a result of the inadequate procedures being followed at the in-theater CARC painting sites, guidance regarding proper procedures was produced after the cessation of hostilities. One example was the release on May 7, 1991, of a revised standard operating procedures (SOP) for CARC painting operations. This revision had several distinct differences from the pre-war standing operating procedures for CARC operations, reflecting the growing awareness that painters in-theater were not properly trained and equipped. The revision included the following additions:

• Several new responsibilities were added for the officer in charge, including traffic pattern control and ensuring that nonessential electrical equipment was kept away from the paint area;
• New responsibilities were detailed for the site safety representative, including monitoring of wind direction, and daily check of fit and condition of respirators;
• A simple explanation was provided discussing the existence and hazards of the isocyanates within CARC;
• A description of the procedures for dealing with a fire in the CARC painting area was provided.[154,155]

Another example of the guidance produced after the cessation of hostilities was a medical memorandum written by a physician with the 12th Preventive Medical Detachment. As the physician explained, "Due to the hazardous nature of CARC and possible danger to soldiers who apply CARC, it has become necessary to institute a more stringent protocol for monitoring individual soldiers who may come in contact with such paint."[156] The guidelines within this memorandum echo the screening requirements found in Technical Guide No. 144,[157] and contain significantly more detail than the standard operating procedures as to the pre-painting screening that should be undertaken for all potential painters. These guidelines include:

• All soldiers mixing or applying paint should be medically cleared and fit-tested for a respirator;
• Soldiers should be tested to determine baseline pulmonary function prior to donning the mask and at the end of the paint operation;
• Soldiers should be tested to determine baseline blood chemistry;
• Soldiers who fail to follow any of the protective procedures should be re-educated about the potential dangers.[158]

A command surgeon from VII Corps generated further guidance concerning health and safety at CARC paint sites. This memorandum discussed field sanitation responsibilities, hearing conservation requirements, vision protection, and painter safety equipment. It also went into detail on the roles and responsibilities of the safety manager and the need for medical surveillance, including proper screening and physical exams. Attached to the memo was a sample history and physical examination screening form. The form lists standard steps that a physician can use to screen a soldier for eligibility to work with paint.[159]

Following their service in the Gulf War, the 325th Maintenance Company returned to Florida. As previously discussed, a number of soldiers from the unit experienced health problems while in Saudi Arabia. In many cases, these health problems persisted or even intensified after their return home. As a result of the large number of health problems experienced by the deployed 325th members and veterans, health testing was conducted while the unit was conducting its two-week annual training at Ft. Stewart, Georgia, in 1992. An Army occupational medicine physician from Florida examined members of the 325th. He reported skin rashes in 10 to 15 soldiers, as well as a number of cases of non-specific symptoms, such as headaches, fatigue, and sleep difficulty. The physician was also able to perform pulmonary function tests on 20 to 30 soldiers from the unit. He recalls asthma-like symptoms in a number of these soldiers, many of whom complained of recurring breathing difficulties. He also noted that he saw symptoms consistent with possible chemical sensitization from CARC exposure in some of the soldiers.[160] Due to the numerous health complaints within the unit, all Gulf War veterans still in the unit were given several other medical tests, including blood tests, while at Ft. Stewart.[161]

Some soldiers from the 325th Maintenance Company communicated their CARC painting experiences to their US representative, Charles Canady of Florida’s 12th District. A series of correspondence between the congressman and DOD officials discussed the issues of CARC exposures and medical care and post-deployment support provided to Operation Desert Storm National Guard members.[162,163] The matter was referred to the National Guard Bureau (the top echelon of the National Guard) for investigation.[164] The National Guard Bureau Inspector General issued an assessment addressing health care issues for veterans of Operations Desert Shield and Desert Storm in June 1994.[165]

The House of Representatives’ Committee on Veterans’ Affairs held a hearing regarding Gulf War veterans’ issues on June 9, 1993. Major General Robert Ensslin, Jr., adjutant general for the state of Florida responsible for the mobilization, deployment, and demobilization of the 325th, delivered a statement regarding the 325th Maintenance Company. In his statement MG Ensslin noted that over 200 Army National Guard members were released from active duty who had not completed medical treatment for duty related injuries or illnesses. Although this action to expedite the return of soldiers to their home station was well intended, many National Guardmembers had difficulty in receiving treatment once discharged, since their Gulf War-related exposures or related symptoms had not been reported, evaluated, treated, or documented.[166]

On Oct. 9, 1996, the issue of the 325th Maintenance Company’s exposure to CARC was discussed at a Presidential Advisory Committee on Gulf War Veterans’ Illnesses (PAC) hearing. The PAC was established in May 1995 to ensure independent, open, and comprehensive examination of health concerns related to Gulf War service.[167] At the hearing, a representative from the Florida Department of Veterans’ Affairs and a member of the 325th Maintenance Company provided statements. Both speakers explained that a number of veterans from the 325th had become ill due to their work with CARC. They also described some of the difficulties that veterans faced in obtaining treatment and benefits for their illnesses.[168]

As with members of active Army units, National Guard members in units like the 325th can pursue health care through the DOD’s Comprehensive Clinical Evaluation Program (CCEP).[169] However, unlike active Army servicemembers, National Guard (and Reserve) members are not paid when they miss duty unless a doctor states that they are incapacitated and unable to perform their duty. For a Gulf War veteran to receive disability and medical treatment through the Comprehensive Clinical Evaluation Program, participation in Phase I of the program is required. This involves undergoing a free medical evaluation. If a physician diagnoses a health problem, an evaluation can then be made as to whether the illness is connected to a soldier’s Gulf War service, called a "line of duty" determination.[170] Though Guard members are reimbursed for their travel expenses to go to a DOD or VA clinic to receive their Phase I medical evaluation (i.e., mileage, lodging, food), they are not reimbursed or compensated for time off from their civilian jobs, which in many cases imposes a financial hardship on deployment veterans and their families. Additionally, establishing the line of duty status for an illness does not necessarily guarantee compensation or benefits. Veterans only receive compensation if they are unable to perform their assigned duty or their military occupational specialty. Conversations with a specialist working with the CCEP revealed that Guard members often do not avail themselves of the CCEP evaluation process because of the monetary cost of taking the time off from their civilian jobs, as well as their skepticism that they will ever receive line of duty compensation.[171]

A number of Guardsmen who served with the 325th Maintenance Company during Operation Desert Shield/Storm left the National Guard and returned to civilian life at some point after the war. Unlike those who remained in the unit, these former Guardsmen are not eligible for the DOD’s CCEP program. Instead, they can enroll in the Department of Veteran’s Affairs (VA) Persian Gulf Registry[172] to receive medical evaluation. Due to the large number of soldiers in the 325th who were experiencing health problems, Veterans Affairs staff made a number of visits to the unit’s headquarters in Lake Wales, Florida, between 1992 and 1993. The VA representatives were also on hand at the unit’s annual training at Ft. Stewart shortly after their return from Saudi Arabia.[173] Over 100 claims from the 325th have been processed. Through this program, several members of the 325th have been discharged and given compensation and benefits for disabilities that were associated with their wartime service.[174]

As of October 1999, 66 members of the 325th Maintenance Company had received CCEP medical evaluations, and 97 members had received VA Persian Gulf Registry evaluations. Since there were about 200 members of the 325th who performed painting operations, a high proportion have enrolled in the two registries. At the start of the Gulf War in 1990, these 163 soldiers ranged in age from 19 to 58 years.

Seventy of the 163 soldiers had a diagnosis or symptoms of a respiratory disease, including 10 diagnosed with asthma. Asthma is the most specific type of chronic effect that would be expected after long-term exposure to isocyanates. Generally, in other populations, this disease has developed in workers who have been exposed for at least 12 months to several years.[175]

Several members of the 325th have been awarded compensation for disability due to a variety of service-connected diseases. Because the complete medical and compensation records could not be reviewed due to privacy act considerations, the particular disabling conditions for which these veterans were compensated have not been disclosed to OSAGWI investigators. The CCEP and VA Persian Gulf Registry databases do not provide information about changes in diagnoses over time, ongoing treatment, or disability determinations within the DOD or VA health care and benefit systems.

An estimated 200 soldiers from the 325th Maintenance Company and an unknown number of soldiers from smaller paint operations were potentially exposed to the hazards of CARC during spray painting operations during Operations Desert Shield and Desert Storm. These exposures occurred primarily due to the tasking of ill-equipped, poorly trained, and inexperienced service members to operate the two main spray painting operations in the Saudi Arabian ports of Ad Dammam and Al Jubayl. Despite repeated health and safety inspections over a seven-month period (December 1990 – June 1991) that identified serious risks, hazards, and deficiencies, painting activities continued at these two facilities with only limited improvements.

The principal health threat associated with CARC is hexamethylene diisocyanate (HDI) and various solvents used in the spray painting process. Due to the lack of adequate personal protection, and a larger failure to adhere to applicable safety and occupational health policies and procedures, a number of soldiers directly involved in CARC painting may have suffered adverse health effects, primarily respiratory effects from exposures to HDI and solvents. However, this investigation cannot definitively link CARC painting operations to the undiagnosed illnesses reported by Gulf War veterans, except in a small number of cases involving a limited number of personnel, where soldiers were known to have been directly involved in painting operations.

Several recommendations for improvements in the policy regarding minimizing exposures to CARC paint during future deployments are identified in the lessons learned section.

We determined that pre-deployment and post-deployment CARC-painting operations outside of the KTO were outside the scope of our investigation, although these deployment-related practices require further assessment by the relevant DOD occupational health and safety offices.

During our investigation of paint operations in the Gulf War theater, some soldiers reported that a number of standard procedures, including painting vehicles with CARC, were modified (or disregarded) in the rush to mobilize troops and equipment for Operations Desert Shield and Desert Storm. In some cases, safety considerations were compromised. In the future, military operational plans and policies should anticipate similar requirements, and be prepared to meet them without compromising occupational safety and health standards. Prior planning should improve the military’s ability to quickly establish field-expedient, but safe, CARC painting sites. Advance training, education, and guidance should raise the level of awareness of potential hazards involved when painting with CARC. The CARC-painting mission should be assigned to appropriate units before deployment—units that could obtain the required procedural and safety training, procure personal protective equipment, and ensure direct oversight and guidance by trained, certified, experienced safety and occupational health professionals who have the command authority and support to ensure that operations are conducted in accordance with the applicable health and safety policies and procedures.

In general, U.S. troops tasked to spray paint vehicles in-theater lacked the training, education, guidance, and oversight needed to ensure safe and successful mission accomplishment In addition, despite repeated warnings from health and safety specialists in-theater, tactical commanders charged with directing the CARC paint effort did not fully appreciate the hazards associated with spray painting CARC, or safeguard their health and wellness while still accomplishing their mission. In the future, CARC painting requirements should be more fully developed during pre-operation planning. Advance planning would enable commanders to assign the mission to appropriate units and personnel prior to deployment. The assigned units could obtain the required occupational safety and health training, procure personal protective equipment and the other materiel needed to perform their duties in a safe and efficient manner.

Recent guidance from the DOD and Joint Chiefs of Staff, along with implementing Service guidance, respond to these requirements. Service members with assigned duties requiring occupational health-related personal protective equipment are now required to deploy with appropriate personal protective equipment (respiratory protection, hearing protection, and personal exposure dosimeters).[176]

The lack of pre-deployment planning prevented appropriate pre-deployment occupational health screening of members of the 325th Maintenance Company. Even if medical screening could not have been completed prior to deployment, properly trained leaders and soldiers would have known about the hazards of CARC painting and the need for medical screening before and during the painting operations. In addition, they could have identified a requirement for post-deployment occupational health screening. The purpose of medical surveillance is to detect any adverse health effects based on the specific hazards to which personnel are exposed.

Post-deployment occupational health evaluations prior to separation from active duty could have identified many of the problems encountered by members of the 325th Maintenance Company.Follow-up medical care decisions may have been more timely for those veterans. To remedy this situation, the services should develop procedures to identify target populations at risk (e.g., CARC painters), and ensure that appropriate post-deployment occupational health evaluations are administered in a timely manner.

Since the Gulf War, the Department of Defense has addressed the post-deployment issue. DD Form 2697, Report of Medical Assessment, November 1995,[177] is now required as a minimum to provide a comprehensive medical assessment of active and reserve members who are separating or retiring from active duty. It is intended to serve as a medical history that will trigger further medical follow-up if the servicemember reports an unusual exposure, has health problems or concerns, or plans to file for disability.

The redeployment painting operations conducted in-theater were more mature than were the operations initially established for tan painting, however, routine safety inspections continued to document numerous problems. Occupational Safety and Health Administration (OSHA) regulations do not apply during actual combat. However, redeployment operations should strictly adhere to OSHA regulations.

In addition, paint surfaces received only minimal preparation, generally washing with water, before applying green CARC. Like the tan coatings applied several months earlier, these green coatings often began to peel after a short time. As a result of redeployment painting operations, some painters were needlessly put at risk to the hazards of spray painting for a paint coating that would most likely need to be reaccomplisheed in a more satisfactory fashion a short time later.

Potential exposures of soldiers spray-painting CARC could be decreased by:

• Painting the vehicles at home station. This would leverage the availability of proper personal protective equipment, trained personnel, and paint facilities existing at military installations and bases, and would be done in accordance with peacetime, regulatory safety and occupational health policies and procedures;
• Assigning trained personnel to establish and oversee paint operations in advance of redeployment. Trained personnel would ensure that the proper personal protective equipment was on hand before the painting operations commenced and the proper protocols were followed.
• Designating a unit with a wartime mission to conduct large-scale painting operations. This practice is followed with other specialized requirements. It would also be appropriate for painting operations where there is a requirement for specialized training and equipment that could be mobilized with the team and deployed anywhere in the world.
• Developing alternative CARC paint formulations. This could include reducing the levels of solvents, developing water-based CARC, and reducing the levels of HDI.
• Developing standardized equipment packages for various missions options.
  • Developing augmentation sets that include all the personal protective equipment, tents, explosive proof lighting/electrical outlets, training materials, etc. for CARC painting operations. The augmentation sets could be placed in operational project stocks.
  • Type-classifying sets, kits and outfits that include all the personal protective equipment, tents, explosive proof lighting/electrical outlets, training materials, etc. for CARC painting operations for inclusion in appropriate maintenance units authorized equipment list (Table of Organization and Equipment).
• Holding commanders accountable for the health and safety of their troops; for taking appropriate action to provide necessary training; for obtaining appropriate safety equipment, and ensuring that the safety equipment is used and maintained as required; and for taking immediate steps to resolve any identified safety and health deficiencies.

Lessons Learned are loosely classified as either systemic or individual failures. The problems associated with CARC painting operations in the Gulf were primarily attributable to individual or leadership failure to ensure that well-established health and safety guidelines associated with isocyanate painting operations were followed. Health and safety inspections repeatedly identified the problems, but corrective actions, when taken, were often short-lived.

The primary focus of our efforts to ensure that the lessons learned in the Gulf War are integrated into the Army's future planning (since the Army has the largest requirement for CARC paint operations). Our vehicle to facilitate the implementation (and institutionalization) of needed improvements has been a series of reviews conducted through the U.S. Army Training and Doctrine Command's Campaign Plan Undersecretary of the Army. These force health development reviews analyze issues such as the problems with CARC painting across existing doctrine, organization, training, leadership development, material development, and policy domains to effect the needed changes. CARC is one of several issues being addressed in this manner.

In addition, we have coordinated our findings and recommendations with the applicable DOD offices, such as the Deputy Under Secretary of Defense for Environmental Security; the Office of the Assistant Secretary of Defense for Health Affairs; the National Guard Bureau; Joint Staff Deputy Director for Medical Readiness who coordinated with the Offices of the Army, Navy and Air Force Surgeons General; the U.S. Army's Center for Health Promotion and Preventative Medicine; the U.S. Army Research Laboratory (Polymers Research Branch); and the Federal Occupational Safety and Health Administration

As often cited, "those who cannot remember the past are condemned to repeat it." Therefore, our emphasis has been to inform and educate DoD's leadership on the hazards of CARC painting operations and the procedures needed to protect the health of our soldiers, sailors, and airmen.

If you have records, photographs, or first-hand knowledge and information regarding the events and activities described in this report, or can offer corrections or pertinent details, please call 1-800-497-6261.

AAD Anniston Army Depot

AAR after action report

ACGIH American Conference of Governmental Industrial Hygienists

ACR armored cavalry regiment

AMC Army Materiel Command

ARCENT Army Central Command

ARL Army Research Lab

ASAP as soon as possible

ASG area support group

CARC chemical agent resistant coating

CCEP Comprehensive Clinical Evaluation Program

CFR Code of Federal Regulations

CHPPM Center for Health Promotion and Preventive Medicine

CINCFOR Commander in Chief, Forces Command

CINCUSAREUR Commander in Chief, United States Army Europe

CNS central nervous system

CO carbon monoxide

COPD chronic obstructive pulmonary disease

CSC convoy support center

CWA chemical warfare agent

DA Department of the Army

DBA decibels, A-scale

DESCOM United States Army Depot Systems Command

DHHS Department of Health and Human Services

DLA Defense Logistics Agency

DOD Department of Defense

DS2 decontaminating solution number 2

EPA Environmental Protection Agency

FSTV fire support team vehicle

HDI hexamethylene diisocyanate

HMMWV high mobility multi-wheeled vehicles

hp horsepower

IG inspector general

KKMC King Khalid Military City

KTO Kuwait theater of operations

lbs pounds

LNO liaison officer

LEL lower explosive (flammable) level in air

LOD line of duty

MDI methylene diisocyante

MEB Marine expeditionary brigade

MIL SPEC military specification

mg/m³ milligrams per cubic meter

MOPP mission oriented protective posture

MOS military occupational specialty

MSDS material safety data sheet

NCOIC non-commissioned officer in charge

NGB National Guard Bureau

NIOSH National Institute for Occupation Safety and Health

ODS/DS Operation Desert Shield/Desert Storm

OIC officer in charge

OSHA Occupational Safety and Health Administration

PAC Presidential Advisory Committee

PPL permissible exposure level

PPE personal protective equipment

PPM parts per million

PSA port support authority

PSI pounds per square inch

QPL qualified products list

REL recommended exposure list

SITREP situation report

SOP standard operating procedures

STEL short-term exposure limit

SUPCOM support command

TAA tactical assembly area

TF task force

TLV threshold limit value

USAEHA United States Armey Environmental Hygiene Agency

USASG United States Army Support Group

USMC United States Marine Corps

VA Department of Veterans Affairs

VOC volatile organic compound

acute health effect

An undesirable symptom or set of symptoms that is immediate and short-term

aerosolization

To bring a substance to a gaseous suspension of fine solid or liquid particles, such as with spraying paint.

air-purifying respirator

A negative-pressure mask that uses filter cartridges to clean air for the user. The type of filter cartridge required varies based upon the expected contaminant.

air-supplied respirator

A positive-pressure mask that takes in air through a hose. The air is provided by a powered compressor and exits the mask through vents.

antigen

A substance that when introduced into the body stimulates the production of an antibody. Antigens include toxins, bacteria, and foreign blood cells.

asthma

Chronic respiratory system disorder characterized by wheezing, coughing, and difficulty in breathing.

bronchitits

An inflammation of the mucous lining of the bronchial tubes, which often causes coughing and sputum production.

carbon monoxide

A colorless, odorless, highly poisonous gas, CO, formed by the incomplete combustion of carbon or a carbonaceous material, such as gasoline or oil in compressors.

carcinogenic

A compound or material capable of causing cancer.<

chemical bronchitis

An inflammation of the mucous lining of the bronchial tubes brought on by exposure to an irritant substance.

chemical sensitization

An individual who is hypersensitive or reactive to an antigen (e.g., toxins), especially through a second or repeated exposure. Also characterized as an allergic reaction to a chemical. Individuals spraying CARC without proper respiratory protection are at risk of chemical sensitization to hexamethylene diisocyanate (HDI).

chronic health effect

An undesirable symptom or set of symptoms lasting a long period of time or marked by frequent recurrence.

cooling vortex

An apparatus, used with some air-supplied respirators, that cools the air flowing into a respirator and paint suit. This improves the working conditions for a painter in a hot environment.

dBA

Unit of measure of sound measured on a sound level meter using the A-weighted network with slow meter response.

Hexamethylene diisocyanate (HDI)

A low-molecular-weight compound used in CARC as a resin to aid in the formation of the polyurethane.

hypersensitivity pneumonitis

A condition in which lung tissue is highly sensitive and easily inflamed by certain stressors. This is a type of chronic pneumonia caused by a chemical or microorganism.

in-theater

Occurring in the Kuwait theater of operations

monomer

A simple molecule that can form polymers by combining identical or similar molecules

occupational asthma

Variable airflow limitation due to causes and conditions that are attributable to a particular occupational environment, and not to stimuli outside the workplace.

oligomer

See prepolymer

organic vapor

The gaseous state of a carbon-based compound

personal protective equipment

A variety of equipment, such as respirators, gloves, and coveralls, that are designed to protect an individual from a known hazard.

polymer

A naturally occurring or synthetic substance consisting of giant molecules formed from smaller molecules of the same substance and often having a definite arrangement of the components of the giant molecules

positive pressure respirator

An air-supplied or powered air-purifying mask in which the pressure inside the mask is higher than the outside environment. Clean, supplied air constantly flows into the mask from an air hose for inhalation, while exhaled air exits the mask through vents.

prepolymer

An intermediate building block of molecules eventually forming a polymer. Also called an oligomer.

pre-filter

A device used with an air-supplied respirator that prevents large particulate matter and debris from entering an individual’s mask.

pulmonary function test

A test performed to assess the lung strength and lung capacity of an individual. One use of this test is to screen and provide a baseline for individuals who will be wearing a respirator.

raw material

An unprocessed natural substance used in manufacturing.

reflectance properties

A characteristic of a material that refers to its ability to reflect certain wavelengths of radiation (e.g., light). Many CARCs have the characteristic of mimicking reflectance properties found in nature, thereby increasing the ability of equipment to evade enemy infrared detection.

325th Maintenance Company, Daily Report – Al Jabail Port Paint Facility, Dec. 21, 1990 to Jan. 26, 1991.

"VII Corps CARC Paint Operation," Appendix 19 to Annex A to 1st ID(F) Operation Desert Shield/Storm AAR of VII Corps Debarkation and Onward Movement.

"VII Corps LNO to 22D SUPCOM Notes #35, SUPCOM Morning Stand-up 23 APR 91," April 24, 1991.

"VII Corps Redeployment LNO Coordinator Notes #24, SUPCOM Evening Stand-up, 12 Apr 91," April 13, 1991.

"VII Corps Redeployment LNO Coordinator Notes #6, SUPCOM Evening Brief, 23 MAR 91," March 25, 1991.

American Conference of Governmental Industrial Hygienists, 1999 TLVs� and BEIs� : Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, Cincinnati, OH: American Conference of Governmental Industrial Hygienists, 1999.

Annex B (Port Operations) to 1st ID(F) Operation Desert Shield/Storm AAR Background Papers.

Annex J (Service Support) to 3AD Operations Order 90-10.

Army Materiel Command / US Army Support Group (Provisional), Operation Desert Storm Saudi Arabia, safety officer, 15 January 1991 – 21 July 1991, briefing slides.

Bernstein, D. I., "Chapter 12 - Allergic Reactions to Workplace Allergens. Primer on Allergic Immunologic Diseases—Fourth Addition," Journal of the American Medical Association, December 10, 1997. www.ama-assn.org/special/asthma/library/readroom/pr7008.htm.

Chan-Yeung, M. and J. Malo, "Current Concepts: Occupational Asthma," New England Journal of Medicine, July 13, 1995.

Daily Corps SITREP, Headquarters 7th Engineer Brigade, Jan. 12, 1991.

DD Form 2697, Report of Medical Assessment, November 1995.

Department of the Army, 12th Medical Detachment, Subject: "Trip Report to Dammam/Al Jubail Regarding CARC Painting," April 18, 1991.

Department of the Army, "Painting and Marking of Army Aircraft," Technical Manual No. 55-1500-345-23, June 12, 1986.

Department of the Army, "Painting Instructions for Army Materiel," TM 43-0139, July 27, 1988.

Department of the Army, "Occupational and Environmental Health Respiratory Protection Program," TB MED 502, Feb. 15, 1982.

"E-10 CARC Painting Operations," undated.

Final Report of the Presidential Advisory Committee (PAC) on Gulf War Veteran's Illnesses, Washington, DC: US Government Printing Office, December 1996, Executive Summary.

Industrial Safety and Installation Support, "Chemical Agent Resistant Coating. A Safety Support Pamphlet," Ft. Rucker, Jan. 9, 1988.

Journal of a 22nd Support Command safety officer.

"Jubail Paint Site Concept of Operations," VII Corps Safety.

"Jubail Paint Site Safety Information," VII Corps Safety.

Lead Sheet #14228, Interview with 325th Maintenance Company painter, Jan. 21, 1998.

Lead Sheet #14234, Interview with 3rd Armored Calvary Regiment painter, Jan. 22, 1998.

Lead Sheet #14237, Interview with 3rd Armored Calvary Regiment painter, Jan. 22, 1998.

Lead Sheet #14254, Interview with 325th Maintenance Company painter, Jan. 26, 1998.

Lead Sheet #14270, Interview with 105th Medical Detachment environmental science officer, January 28, 1998.

Lead Sheet #14336, Interview with Executive Director of the Florida Department of Veterans Affairs, Feb.11, 1998.

Lead Sheet #14346, Interview with 325th Maintenance Company mechanic, February 4, 1998.

Lead Sheet #14369, Interview with CARC paint site inspector, February 6, 1998.

Lead Sheet #14379, Interview with 12th Medical Detachment industrial hygienist, Feb. 9, 1998.

Lead Sheet #14390, Interview with 12th Medical Detachment occupational medicine physician, July 8, 1999.

Lead Sheet #14978, Interview with 325th Maintenance Company painter, February 10, 1998.

Lead Sheet #15120, Interview with 325th Maintenance Company commanding officer, Feb. 17, 1998.

Lead Sheet #15187, Interview with Army Research Laboratory research chemist, August 9, 1999.

Lead Sheet #15190, Interview with 325th Maintenance Company painter, Feb. 25, 1998.

Lead Sheet #15359, Interview with 593rd Area Support Group commanding officer, March 6, 1998.

Lead Sheet #15548, Interview with 24th Infantry Division painter, March 24, 1998.

Lead Sheet #15654, Interview with Occupational medicine physician at Fort Stewart, March 31, 1998.

Lead Sheet #15853, Interview with 325th Maintenance Company painter, April 6, 1998.

Lead Sheet #15881, Interview with 89th Military Police Brigade painter, April 7, 1998.

Lead Sheet #17526, Interview with 900th General Supply Maintenance Company painter, Jan. 12, 1998.

Lead Sheet #17979, Interview with Marine Corps System Command engineer, July 13, 1998.

Lead Sheet #18049, Interview with 593rd Area Support Group senior supply sergeant, July 15, 1998.

Lead Sheet #18051, Interview with 900th General Supply Maintenance Company shop officer, July 15, 1998.

Lead Sheet #18072, Interview with USMC Master Gunnery Sergeant, July 15, 1998.

Lead Sheet #18141, Interview with site manager for the Anniston Ad Dammam paint site, July 16, 1998.

Lead Sheet #18143, Interview with Executive Director of the Florida Department of Veterans Affairs, July 16, 1998.

Lead Sheet #18146, Interview with DoD civilian painter at Anniston Ad Dammam paint site, July 16, 1998.

Lead Sheet #18259, Interview with 900th General Supply Maintenance Company maintenance warrant officer, July 22, 1998.

Lead Sheet #18301, Interview with DoD civilian painter at Anniston Ad Dammam paint site, July 27, 1998.

Lead Sheet #18305, Interview with DoD civilian painter at Anniston Ad Dammam paint site, July 27, 1998.

Lead Sheet #18328, Interview with DoD civilian painter at Anniston Ad Dammam paint site, July 28, 1998.

Lead Sheet #19487, Interview with 325th Maintenance Company painter, Oct. 16, 1998.

Lead Sheet #19604, Map provided by US Army Support Group safety officer, Oct. 22, 1998.

Lead Sheet #20572, Interview with DoD civilian safety manager for VII Corps in theater, Dec. 3, 1998.

Lead Sheet #20618, Interview with 22nd Support Command safety officer, Dec. 8, 1998.

Lead Sheet #21081, Interview with 22nd Support Command safety officer, Jan. 13, 1999.

Lead Sheet #21390, Interview with Florida National Guard personnel representative, Feb. 2, 1999.

Lead Sheet #21577, Notes from watching video of paint site inspections taken by 22nd Support Command safety officer, Feb. 5, 1999.

Lead Sheet #22086, Interview with Air Force bioenvironmental engineer in-theater, March 3, 1999.

Lead Sheet #24332, Interview with air compressor manufacturer representative, July 14, 1999.

Lead Sheet #26418, Interview with DoD civilian painter at Anniston Ad Dammam paint site, March 29, 2000.

Lead Sheet #26328, Interview with DoD civilian painter at Anniston Ad Dammam paint site, April 7, 2000.

Lead Sheet #27246, Interview with US Army Occupational Medicine Staff Officer, June 28, 2000.

Lead Sheet #27367, Interview with Navy industrial hygiene personnel, July 24, 2000.

Letter from Charles T. Canady, Congress of the United States, House of Representatives, April 27, 1993.

Letter from Charles T. Canady, Congress of the United States, House of Representatives, May 28, 1993.

Letter from Lieutenant General John B. Conaway, National Guard Bureau, May 20, 1993.

Letter from the National Institute for Occupational Safety and Health (NIOSH), Aug. 7, 1990.

"Logistical Concerns Requiring Assistance," undated.

Memorandum for All Medical Facility/SGPB from Detachment 1, HSC/OEMI, Subject: "Consultative Letter, AL-OE-BR-CL-1998-0105, 1,6-Hexamethylene Diisocyanate Exposures During Polyurethane Spay Painting Operations," Aug. 28, 1999.

Memorandum for Record from SUPCOM, Surgeon/CDR, SUPCOM Medical Group (Provisional), Subject: "CARC Painting."

Memorandum for Record, Subject: "Hazard Report, CARC painting operation," Dec. 15, 1990.

Memorandum for Record, Subject: "Paint Operations," April 28, 1991.

Memorandum for Record, USASG Safety Office, Subject: "Paint Operations," April 28, 1991.

Memorandum for See Distribution, SUBJECT: "Employees on Temporary Assignment to Saudi Arabia," Nov. 14, 1990.

Memorandum from 12th Medical Detachment, For Commander, 176th Maintenance Battalion, Subject: "Industrial Hygiene and Safety Evaluation of ‘CARC’ Painting Operation," Dec. 20, 1990.

Memorandum from Army Materiel Command, For 22nd Sub Com Safety Officer, Subject: "Paint Operations," April 20, 1991.

Memorandum from Department of the Army Medical Group (Provisional) Preventative Medicine Team, For Commander, Medical Group (Provisional), Subject: "Physical Examinations and Medical Monitoring of Troops Conducting CARC Painting Operations," May 28, 1991.

Memorandum from Department of the Army Preventative Medicine Team, Through Commander, SUPCOM Medical Group, Subject: "Assessment of the Al Jubayl CARC Paint Site," June 12, 1991.

Memorandum from Headquarters 22nd SUPCOM, For Director, 22nd SUPCOM Safety, Subject: "Chemical Agent Resistant Coating (CARC) Paint Operations, Ports of Dammam and Jubayl," April 28, 1991.

Memorandum from Headquarters, Department of the Army, 3d Brigade, 1st Infantry Division (Forward), Through Commander, 176th Maintenance Battalion, For Commander 325th Maintenance Company, Subject: "VII Corps CARC Painting Policy," Dec. 27, 1990.

Memorandum from Headquarters, VII Corps Redeployment Command, For Commander, VII Corps Redeployment Command, Subject: "Health and Safety Recommendations for CARC Painting Sites," June 4, 1991.

Memorandum from the National Guard Bureau Inspector General, For Acting Chief, National Guard Bureau, Subject: "NGB-IG Assessment of Patient Administration and Health Care for National Guard Desert Storm/Shield Veterans—Action Memorandum," June 30, 1994.

Memorandum from the Joint Chiefs of Staff to Under Secretary of Defense for Personnel and Readiness, et. al., Subject: "Deployment Health Surveillance and Readiness," Dec. 4, 1998.

Memorandum from USASG-F, For Commander, 22nd Support Command (TAA), Subject: "Kuwait Passes for Official Duty," June 21, 1991. Memorandum from USASG-R, For USASG-F, May 3, 1991.

Memorandum from United States Army Center for Health Promotion and Preventive Medicine for Headquarters, Department of Army, Subject: "Health Effects Anticipated Following Occupational Exposure to CARC Paint," Aug. 23, 1993.

Message, ARCENT, Subject: "Occupational Medicine/Industrial Hygiene Support to DESCOM," Oct. 29, 1990.

Message, Army Materiel Command, Subject: "Chemical Agent Resistant Coating (CARC) Update," Feb. 6, 1991.

Message, CINCUSAREUR, Subject: "CARC Touch-up/Spot Painting Policy," Oct. 15, 1990.

Message, Commanding General Fourth MED, Subject: "Guidance for Temporary Paint Removal," March 16, 1991.

Message, Headquarters Marine Corps, Subject: "Requirements for Temporary Desert Camouflage Paint," Aug. 28, 1990.

Message, HQ DA, Subject: "Army Adoption of Chemical Agent Resistant Coating (CARC)," May 6, 1983.

Message, VII Corps, Subject: "Commander’s SITREP #55," March 12, 1991.

"OSHA Standards Interpretation and Compliance Letters," March 3, 1986. www.osha-slc.gov/OshDoc/Interp_data/I19860303.html.

"Paint Operations at Al Jubayl," equipment tally, undated.

Point Paper from United States Army Director of Personnel, "Issue: Safety During Desert Shield Mobilization," Nov. 19, 1990.

"Preventing Asthma and Death from Diisocyanate Exposure," DHHS (NIOSH) publication no. 96-111, 1996, www.cdc.gov/niosh/asthma.html.

Rom, W. N., Environmental and Occupational Medicine, 3rd ed., Philadelphia: Lippincott-Raven, 1998

Rye, W. A, "Human Responses to Isocyanate Exposure," Journal of Occupational Medicine, March 1973.

"Standing Operating Procedures (SOP) CARC Painting Operations, revised copy 7 May 91."

"Standing Operating Procedures (SOP) CARC Painting Operations."

Tape TVT 3-40 "(CARC) Chemical Agent Resistant Coating" and Tape TVT 3-29 "CARC/CPP (Chemical Agent Resistant Coating/Camouflage Pattern Painting."

Testimony of Major General Robert F. Ensslin, Jr. before the Subcommittee on Oversight Investigations of the Committee on Veterans’ Affairs, House of Representatives, June 9, 1993.

Testimony of Mr. Tim Ivers and Mr. William Carpenter before the Presidential Advisory Committee (PAC), Oct. 9, 1996.

United States Environmental Protection Agency, Technology Transfer Network, Hexamethylene-1-6-Diisocyanate. www.epa.gov/ttn/uatw/hlthef/hexa-dii.html.

United States Army Environmental Hygiene Agency "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide No. 144, Aug. 24, 1987.

United States Army Environmental Hygiene Agency. Operation Desert Shield / Desert Storm, History of Participation by the US Army Environmental Hygiene Agency, 1992.

1.  Military Specifications

All color variations of CARC must meet stringent military specifications. The typical formulation of these finishes consists of three primary groups of raw materials: the resin or binder system, the pigment package, and the solvents.

As a means of standardizing the paint formulations manufactured by private contractors for the military, the system of military specifications (MIL SPEC) is used. The military specification lists all the requirements of the paint, which describes types and composition of materials, color and spectral reflectance properties, and label markings.

One of these military specifications, MIL-C-46168 specifies a two-component system and references nineteen colors, including Tan 686A. The specification is available in two types, type II and type IV. Type II is the older version with a standard amount of volatile organic compounds (VOC). Type IV is a modified formula that has a reduced VOC content of up to 3.5 pounds per gallon or 420 grams per liter.[178] Volatile organic compounds can be an occupational health hazard, as well as an environmental concern. VOCs react with the atmosphere, resulting in the production of air pollutants that are components of smog. Volatile organic compounds are also a source of occupational health hazards.

The other topcoat specification is MIL-C-53039, a single component system. MIL-C-53039 references nineteen colors with Tan 686A as one its colors. This specification has only one type and has a VOC content that does not exceed 3.5 pounds per gallon or 420 grams per liter.[179] Both the two-component and one-component paint systems were used in theater.[180] See Tab D for a chart showing the different colors and variations of CARC used in theater.

2.  Qualified Products List

The military uses the qualified products list as another control measure to ensure the consistency, quality, and performance of its paints. The qualified products list (QPL) is a list of approved suppliers. The Army Research Laboratory has rigorously tested the products of the manufacturers listed on the QPL for conformance to all specifications of performance and composition. Only products from suppliers listed on the QPL are normally procured for use on government material.[181]

The resin systems used in the Army’s camouflage coatings are polyureas and polyurethane-type materials. The pigments can be a variety of colors and provide the low-gloss properties as well as color to the paint. The solvents used are generally standard hydrocarbon-based materials that assist in package viscosity and spraying properties. The following formulations are representative of two component, or MIL-C-46168, camouflage coatings, and list the major ingredients found in these paints. Note that the formulations for the tan and green coatings are very similar, with the principle differences residing in the pigments. (Note: Information provided by US Army Research Laboratory.)

As discussed in this report, Tan 686 was used initially in the Kuwait theater of operations. A modified version of this paint, Tan 686A, was later used due to its ability to reduce the amount of solar heat vehicles would absorb. Green 383 was used during the redeployment painting operation. Figure 11 shows the different variations of the CARCs used in theater. Note that there is a two component and one component version of each paint, both of which were used in theater. Also, there were two different types of the two component paint used, Type II and Type IV.

Figure 11. CARC variations used in theater

1. Tan 686A, two-component coating:

Part A

Resins:

• Polyester, Bayer Desmophen 650A/65
• Polyester, Bayer Multron R221/75

Pigments:

• Titanium dioxide - imparts color
• Yellow iron oxide - imparts color
• Chrome oxide - imparts color
• Carbazole violet - imparts color
• Silica - flattening agent
• Diatomaceous silica - flattening agent

Solvents

• Methyl isoamyl ketone (MIAK) - viscosity and spray properties
• Methoxypropanol acetate (PM Acetate) - viscosity and spray properties
• Xylene - viscosity and spray properties
• Aromatic 100 - spray properties<

Part B

Resin:

• Hexamethylene diisocyanate (HDI), Bayer Desmodur N751

Solvent:

• N-Butyl acetate - viscosity and spray properties

2. Green, 383, two-component coating:

Part A

Resins:

• Polyester, Bayer Desmophen 650A/65
• Polyester, Bayer Multron R221/75

Pigments:

• Chrome oxide - imparts color
• Cobalt – chrome green, - imparts color
• Magnesium ferrite - imparts color
• Carbazole dioxazine - imparts color
• Silica - flattening agent
• Diatomaceous silica - flattening agent

Solvents:

• Methyl isoamyl ketone (MIAK) - viscosity and spray properties
• Methoxypropanol acetate (PM acetate) - viscosity and spray properties
• Xylene - viscosity and spray properties
• Aromatic 100 - spray properties

Part B

Resin:

• Hexamethylene diisocyanate (HDI), Bayer Desmodur N751

Solvent:

• N-Butyl acetate - viscosity and spray properties

This information is based on the MSDSs for CARC paints and the NIOSH Pocket Guide to Chemical Hazards, DHHS (NIOSH) Publication No. 99-115, April 1999.

• LEL - Lowe Explosive Limit
• PEL - Permissible Exposure Limit (OSHA)
• REL - Recommended Exposure Limit (NIOSH)
• TLV - Threshold Limit Value
• TWA - Time Weighted Average
• IDLH - Immediately Dangerous to Life or Death

Most of the standards established by occupational health authorities are based on routine time-weighted exposures over a working lifetime, typically 8 hours per day, 40 hours per week. Two exceptions are the short-term exposure limit (STEL) and the ceiling limit.

The STEL is defined as a 15-minute time-weighted average that should not be exceeded at any time during the workday. The STEL allows for brief excursions above the 8-hour time-weighted average, as long as the daily average exposure is less than the standard. In contrast, the ceiling standard is a limit that should never be exceeded at anytime during the workday.

The Occupational Safety and Health Administration (OSHA) establishes legally enforceable occupational exposure limits to substances. OSHA sets these standards in the form of permissible exposure limits (PELs). Currently, OSHA does not have a permissible exposure limit for HDI as either a monomer or a prepolymer. (Note: HDI may be present in CARC as either a monomer or a partially reacted prepolymer, also called an oligomer. This is significant because the monomer is more volatile and usually exists as a vapor after CARC has been sprayed. On the other hand, the prepolymer is less volatile and is usually present as an aerosol mist or droplet after CARC has been sprayed.)

The National Institute for Occupational Safety and Health (NIOSH) developed a recommended exposure limit (REL) for HDI monomer of 35 �g/m3 or 0.005 parts per million (ppm), but has not established a recommended exposure limit for the HDI prepolymer.[182] The NIOSH REL is a time-weighted-average value for a normal working lifetime (up to 10 hours per day, 40 hours per week, for 40 years). NIOSH also established a ceiling value of 140 �g/m3 (0.020 ppm) for HDI monomer.[183] A ceiling value is a concentration that should not be exceeded during any part of the working exposure; if instantaneous monitoring is not feasible, the ceiling must be assessed as a 10-minute time-weighted-average (TWA) exposure for HDI.[184] Though the NIOSH recommended exposure limits have undergone study, they have not completed the regulatory review process to become legally enforceable OSHA standards.

The American Conference of Governmental Industrial Hygienists (ACGIH) has also established threshold limit values (TLV� ). [Note: Threshold limit values are registered trademarks of the American Conference of Governmental Industrial Hygienists.] Threshold limit values refer to airborne concentrations of substances and represent conditions under which it is believed that nearly all workers may be repeatedly exposed day after day without adverse health effects. However, because of wide variation in individual susceptibility, a small percentage of workers may experience discomfort from some substances at concentrations at or below the threshold limit value (TLV� ). A smaller percentage may be affected more seriously by aggravation of a pre-existing condition or by development of an occupational illness.[185] The TLV� for HDI monomer is 34 �g/m3 (0.005 ppm).[186] The level of exposure above the threshold determines the severity of the adverse health effect. The American Conference of Governmental Industrial Hygienists considers threshold limit values to be recommendations to be used as guidelines for good practice.[187]

An exposure limit for the HDI prepolymer has not been established by OSHA, NIOSH or ACGIH. Oregon is the only state OSHA program that has established an exposure limit. Oregon's 8-hour time-weighted average limit for HDI prepolymer is 500 �g/m3 with a ceiling level of 1000 �g/m3.[188] In addition, Bayer Chemicals, a leading producer of HDI, established a corporate recommended ceiling level for HDI of 0.02 ppm.[189]

Despite the prevalence of occupational health and safety exposure limits and regulations in the military workplace during peacetime, regulations from the Occupational Health and Safety Administration (OSHA) do not apply in combat situations. Though the Department of Defense states that all DOD personnel worldwide fall under OSHA regulations, exemptions or exceptions from this oversight for military personnel apply in military-unique operations and workplaces (e.g., a wartime setting).[190] However, the Department of Defense retains its obligation to protect the health of its servicemembers at all times.

When troops and vehicles deployed to the Gulf for Operation Desert Shield in 1990, a detailed body of doctrine already existed for the use of CARC and the establishment of paint sites. Military technical guides, manuals, and bulletins, as well as OSHA regulations, clearly detail the necessary procedures involved in establishing CARC painting operations.

Army Technical Guide Number 144, "Guidelines for Controlling Health Hazards in Painting Operations" clearly spells out the procedures for proper set-up and testing from the initial stages of the operation. As Technical Guide No. 144 explains, "… statistically valid personal samples must be collected for HDI ... results determine the required types and level of respiratory protection and engineering controls."[191] Not only is personnel testing required for paint site set-up and annual monitoring, but also when any change occurs in an existing site’s process, controls, or personnel. Such change requires additional environmental and personnel monitoring.

All types of monitoring are performed in conjunction with a standardized medical surveillance process. A pre-placement, or baseline health evaluation, is the first step in medical surveillance. Baseline determination involves three main steps:

1. determining an individual’s medical and occupational history, with emphasis on prior exposure to HDI, allergies, respiratory disease, and smoking;
2. a physical examination with attention to the respiratory system; and
3. clinical laboratory tests (e.g., chest x-ray, pulmonary function tests).

An annual physical examination and a pulmonary function test should follow the establishment of baseline data.[192]

The use of proper respiratory protection, particularly in spray painting operations, is vital when working with CARC. Due to the significant toxicity and lack of odor-threshold warning properties associated with HDI, OSHA dictates the use of only positive-pressure air-supplied respirators.[193,194] This guidance is echoed by the National Institute for Occupational Safety and Health (NIOSH),[195] and the Department of the Army.[196] A positive-pressure air-supplied respirator is one in which the pressure inside the mask is higher than the outside environment. Clean, supplied air constantly flows into the mask from a tube for inhalation, while exhaled air exits the mask through vents. Either a full face respirator or a half-face respirator with goggles is appropriate.

Unlike spray painting operations, brush or roller painting does not cause significant aerosolization of paint constituents, and exposures to HDI are at much lower levels. In large open bays and outdoors, the potential for overexposure when using brush and rollers is remote.[197]Workers painting or mixing CARC must use not only respiratory protection, but they must wear eye protection and clothes that provide full skin coverage and protection from contact with CARC. Gloves and coveralls are particularly important, especially gloves.[198] As noted earlier, HDI is both a skin and eye irritant.

Beyond physical personal protective equipment, training and the dissemination of information on the hazards associated with CARC application also reduce the risks of worker exposure. Material safety data sheets (MSDS), which detail hazards, protective measures, and chemical formulation, accompany all batches of paint. Federal regulation[199] requires that material safety data sheets be filed in a location readily accessible to workers exposed to a hazardous substance, such as CARC. Federal law also requires the use of material safety data sheets in training new workers.[200]

In 1988, the U.S. Army Safety Center produced a safety support pamphlet about CARC painting that was available as a reference for civilian and military safety offices. This comprehensive guide discusses the required safety equipment and procedures for a CARC painting operation. The pamphlet also explained each of the potential components of a CARC system—the primers, solvents, and topcoats—and the dangers of each. (Primers were not used in the painting process during Operations Desert Shield/Storm.) In addition, the pamphlet included suggestions on ways that safety professionals could train personnel to work safely with CARC.[201]

The military uses material safety data sheets (MSDS) to ensure that health and safety information associated with a product is available to the users. The military also uses MSDSs to ensure full disclosure of information regarding the types of raw materials used in the formulations. Material safety data sheets accompany each product. Federal regulations[202] require that all material safety data sheets be filed in a location readily accessible to workers potentially exposed to hazardous substances, such as CARC.[203] In practice, the material safety data sheets are usually taken from the package of paint cans and then filed.

Military regulations and standard operating procedures require conformance to, and compliance with, public law and national consensus standards for the hazard communication program (HAZCOM). DOD Instruction 6050.5, the DOD Hazard Communication Program, outlines responsibilities and procedures for a comprehensive hazard communication program that includes training for DOD personnel in potential occupational health hazards. DOD personnel are to be informed of safe work practices and are to be trained in the selection, use, and availability of personal protective equipment (PPE) to prevent injuries and illnesses. It states that it is the DOD policy to protect personnel from the adverse effects of workplace hazardous materials and waste, to reduce chemically related injuries and illnesses, and to establish and maintain a standardized hazardous materials information system. Each service and component is required to establish and maintain hazard communication programs that conform to the requirements of DOD Instruction 6050.5 and comply with the Occupational Safety and Health Administration (OSHA) hazard communication requirements.[204]

Following publication of the interim Chemical Agent Resistant Coating (CARC) Environmental Exposure Report (EER) on Feb. 22, 2000, comments were received from various veterans and from the Presidential Special Oversight Board (PSOB). This updated report has been written to include information based on additional research, interviews with veterans, consultation with subject matter experts, and new information that we have obtained since publication of the interim CARC EER. This report follows the same format as our interim report with limited editing to improve readability.

Based on new information from veterans the discussion of the civilian painters from Anniston, Alabama was modified to reflect that several of the painters have reported medical problems which they have associated with their exposure to CARC during the Gulf War. In addition, a paragraph was added to address the PSOB's request that we describe the efforts OSAGWI has taken to implement lesson learned and to enumerate the agencies with which OSAGWI has coordinated.

1. Headquarters, Department of Army message, Subject: "Army Adoption of Chemical Agent Resistant Coating (CARC)," May 6, 1983.
2. Lead Sheet #15187, Interview with Army Research Laboratory research chemist, Feb. 25, 1998, p 1-2.
3. Lead Sheet #15187, Interview with Army Research Laboratory research chemist, Aug. 9, 1999, p. 3.
4. Lead Sheet #15187, Interview with Army Research Laboratory research chemist, Aug. 9, 1999, p. 3.
5. Lead Sheet #15187, Interview with Army Research Laboratory research chemist, Aug. 9, 1999, p. 4.
6. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 2-3, 2-5, 3-1, 5-1, 7-1.
7. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 5-1.
8. Memorandum for All Medical Facility/SGPB from Detachment 1, HSC/OEMI, Subject: "Consultative Letter, AL-OE-BR-CL-1998-0105, 1,6-Hexamethylene Diisocyanate Exposures During Polyurethane Spay Painting Operations," Aug. 28, 1999, p. 1-2.
9. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 7-1.
10. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 2-4.
11. Lead Sheet #14228, Interview with 325th Maintenance Company painter, Jan. 21, 1998, p. 2.;
12. Lead Sheet #14237, Interview with 3rd Armored Calvery Regiment painter, Jan. 22, 1998, p.1;
13. Lead Sheet #14254, Interview with 325th Maintenance Company painter, Jan. 26, 1998, p. 2;
14. Lead Sheet #14369, Interview with CARC paint site inspector, Feb. 6, 1998, p. 1;
15. Lead Sheet #14978, Interview with 325th Maintenance Company painter February 10, 1998, p. 1.
16. Gerr, F. and R. Letz, "Organic Solvents," Environmental and Occupational Medicine, 1998, p. 1094-1095.
17. Memorandum from US Army Environmental Hygiene Agency for Headquarters, Department of Army, Subject: "Health Effects Anticipated Following Occupational Exposure to Chemical Agent Resistant Coating (CARC) Paint," August 23, 1993, p. 2.
18. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 2-1.
19. Lead Sheet #20618, Interview with 22nd Support Command safety officer, December 8, 1998, p. 3.
20. Memorandum from U.S. Army Environmental Hygiene Agency for Headquarters, Department of Army, Subject: "Health Effects Anticipated Following Occupational Exposure to Chemical Agent Resistant Coating (CARC) Paint," Aug. 23, 1993, p. 2.
21. Memorandum from US Army Environmental Hygiene Agency for Headquarters, Department of Army, Subject: "Health Effects Anticipated Following Occupational Exposure to Chemical Agent Resistant Coating (CARC) Paint," Aug. 23, 1993, p. 2.
22. U.S. Environmental Protection Agency, Technology Transfer Network, Hexamethylene-1-6-Diisocyanate. www.epa.gov/ttn/uatw/hlthef/hexa-dii.html, (as of Dec. 14, 1998).
23. Memorandum from U.S. Army Environmental Hygiene Agency for Headquarters, Department of Army, Subject: "Health Effects Anticipated Following Occupational Exposure to Chemical Agent Resistant Coating (CARC) Paint," August 23, 1993, p. 2.
24. Banks, D.E., "Respiratory Effects of Isocyanates," Environmental and Occupational Medicine, 1998, p. 542.
25. Banks, D.E., "Respiratory Effects of Isocyanates," Environmental and Occupational Medicine, 1998, p. 541-542.
26. Banks, D.E., "Respiratory Effects of Isocyanates," Environmental and Occupational Medicine, 1998, p. 542.
27. Memorandum from US Army Environmental Hygiene Agency for Headquarters, Department of Army, Subject: "Health Effects Anticipated Following Occupational Exposure to Chemical Agent Resistant Coating (CARC) Paint," August 23, 1993, p. 2.
28. Bernstein, D.I., "Allergic Reactions to Workplace Allergens," Journal of American Medical Association, Dec. 10, 1997, p. 1907-1913.
29. Banks, D.E., "Respiratory Effects of Isocyanates," Environmental and Occupational Medicine, 1998, p. 540-542.
30. Chan-Yeung, M. and J.L. Malo, "Occupational Asthma," The New England Journal of Medicine, July 13, 1995, Volume 333, No. 2, p. 107-112.
31. "Preventing Asthma and Death from Diisocyanate Exposure," DHHS (NIOSH) publication no. 96-111, 1996, www.cdc.gov/niosh/asthma.html (as of Nov. 12, 1999).
32. Banks, D.E., "Respiratory Effects of Isocyanates," Environmental and Occupational Medicine, 1998, p. 540-542.
33. Banks, D.E., "Respiratory Effects of Isocyanates," Environmental and Occupational Medicine, 1998, p. 541-542.
34. Chan-Yeung, M. and J.L. Malo, "Occupational Asthma," The New England Journal of Medicine, July 13, 1995, Volume 333, No. 2, p. 107-112.
35. Chan-Yeung, M. and J.L. Malo, "Occupational Asthma," The New England Journal of Medicine, July 13, 1995, Volume 333, No. 2, p. 107-112.
36. Banks, D.E., "Respiratory Effects of Isocyanates," Environmental and Occupational Medicine, 1998, p. 547-548.
37. "Preventing Asthma and Death from Diisocyanate Exposure," DHHS (NIOSH) publication no. 96-111, 1996, www.cdc.gov/niosh/asthma.html (as of November 12, 1999).
38. Cormier, Y., "Hypersensitivity Pneumonitis," Environmental and Occupational Medicine, 1998, p. 457-465.
39. Gerr, F and R. Letz, "Organic Solvents," Environmental and Occupational Medicine, 1998, p. 1094.
40. Memorandum from US Army Environmental Hygiene Agency for Headquarters, Department of Army, Subject: "Health Effects Anticipated Following Occupational Exposure to Chemical Agent Resistant Coating (CARC) Paint," Aug. 23, 1993, p. 2-3.
41. Gerr, F. and R. Letz, "Organic Solvents," Environmental and Occupational Medicine, 1998, p. 1091, 1096.
42. Memorandum from US Army Environmental Hygiene Agency for Headquarters, Department of Army, Subject: "Health Effects Anticipated Following Occupational Exposure to Chemical Agent Resistant Coating (CARC) Paint," August 23, 1993, p. 3-4.
43. Gerr, F. and R. Letz, "Organic Solvents," Environmental and Occupational Medicine, 1998, p. 1096.
44. Memorandum from U.S. Army Environmental Hygiene Agency for Headquarters, Department of Army, Subject: "Health Effects Anticipated Following Occupational Exposure to Chemical Agent Resistant Coating (CARC) Paint," August 23, 1993, p. 3.
45. Gerr, F. and R. Letz, "Organic Solvents," Environmental and Occupational Medicine, 1998, p. 1091, 1094.
46. Gerr, F. and R. Letz, "Organic Solvents," Environmental and Occupational Medicine, 1998, p. 1097.
47. Gerr, F. and R. Letz, "Organic Solvents," Environmental and Occupational Medicine, 1998, p. 1098.
48. Gerr, F. and R. Letz, "Organic Solvents," Environmental and Occupational Medicine, 1998, p. 1095.
49. Gerr, F. and R. Letz, "Organic Solvents," Environmental and Occupational Medicine, 1998, p. 1102.
50. Annex B (Port Operations) to 1st ID(F) Operation Desert Shield/Storm AAR Background Papers, p. B-11.
51. Annex B (Port Operations) to 1st ID(F) Operation Desert Shield/Storm AAR Background Papers, p. B-12.
52. Lead Sheet #15359, Interview with 593rd Area Support Group commanding officer, March 6, 1998, p. 1.
53. Annex B (Port Operations) to 1st ID(F) Operation Desert Shield/Storm AAR Background Papers, p. B-12.
54. Annex B (Port Operations) to 1st ID(F) Operation Desert Shield/Storm AAR Background Papers, p. B-12, B-13.
55. Annex B (Port Operations) to 1st ID(F) Operation Desert Shield/Storm AAR Background Papers, p. B-13.
56. Annex B (Port Operations) to 1st ID(F) Operation Desert Shield/Storm AAR Background Papers, p. B-13.
57. "VII Corps CARC Paint Operation," Appendix 19 to Annex A to 1st ID (F) Operation Desert Shield/Storm AAR of VII Corps Debarkation and Onward Movement, p. A-19-1.
58. "Painting Instructions for Army Materiel," US Army Technical Manual (TM) 43-0139, July 27, 1988, p. 3-1.
59. "Painting Instructions for Army Materiel," US Army Technical Manual (TM) 43-0139, July 27, 1988.
60. MG Dyer, Travis N., Point Paper from United States Army Director of Personnel, "Issue: Safety During Desert Shield Mobilization," November 19, 1990.
61. CINCUSAREUR message, Subject: "CARC Touch-up/Spot Painting Policy," Oct. 15, 1990.
62. Memorandum from Headquarters Department of the Army, 3d Brigade, 1st Infantry Division (Forward), through Commander, 176th Maintenance Battalion, for Commander 325th Maintenance Company, Subject: "VII Corps CARC Painting Policy," December 27, 1990.
63. Army Materiel Command message, Subject: "Chemical Agent Resistant Coating (CARC) Update," Feb. 6, 1991.
64. Annex J (Service Support) to 3AD Operations Order 90-10, p. J-9.
65. Lead Sheet #18049, Interview with 593rd Area Support Group senior supply sergeant, July 15, 1998, p. 1.
66. U.S. Army Environmental Hygiene Agency, Operation Desert Shield / Desert Storm, History of Participation by the U.S. Army Environmental Hygiene Agency, 1992, p. 2-19.
67. Lead Sheet #18141, Interview with site manager for the Anniston Ad Dammam paint site, July 16, 1998, p. 1.
68. Lead Sheet #18143, Interview with DOD civilian painter at Anniston Ad Damman paint site, July 16, 1998, p. 1.
69. Lead Sheet #18305, Interview with DOD civilian painter at Anniston Ad Dammam paint site, July 27, 1998, p. 1.
70. Lead Sheet #18301, Interview with DOD civilian painter at Anniston Ad Dammam paint site, July 27, 1998, p. 1.
71. Lead Sheet #18143, Interview with DOD civilian painter at Anniston Ad Damman paint site, July 16, 1998, p. 1.
72. Lead Sheet #18141, Interview with site manager for the Anniston Ad Dammam paint site, July 16, 1998, p. 1; Lead Sheet #18146, Interview with DOD civilian painter at Anniston Ad Dammam paint site, July 16, 1998, p. 1; Lead Sheet #18305, Interview with DOD civilian painter at Anniston Ad Dammam paint site, July 27, 1998, p. 1.
73. Lead Sheet #18143, Interview with DOD civilian painter at Anniston Ad Damman paint site, July 16, 1998, p. 1; Lead Sheet #18146, Interview with DOD civilian painter at Anniston Ad Dammam paint site, July 16, 1998, p. 1; Lead Sheet #18305, Interview with DOD civilian painter at Anniston Ad Dammam paint site, July 27, 1998, p. 1; Lead Sheet #18301, Interview with DOD civilian painter at Anniston Ad Dammam paint site, July 27, 1998, p. 1.
74. Lead Sheet #26418, Interview with DOD civilian painter at Anniston Ad Dammam paint site, March 29, 2000, p. 2; Lead Sheet # 26328, Interview with DOD civilian painter at Anniston Ad Dammam paint site, April 7, 2000, p. 1-2; Lead Sheet #18143, Interview with DOD civilian painter at Anniston Ad Dammam paint site, April 11, 2000, p. 2-3; Lead Sheet #18301, Interview with DOD civilian painter at Anniston Ad Dammam paint site, May 4, 2000, p. 1.
75. Lead Sheet #27246, Interview with U.S. Army Occupational Medicine Staff Officer, June 28, 2000.
76. Lead Sheet #17526, Interview with 900th General Supply Maintenance Company painter, Jan. 12, 1999, p.1.
77. Lead Sheet #18141, Interview with site manager for the Anniston Ad Dammam paint site, July 16, 1998, p. 1.
78. Lead Sheet #18259, Interview with 900th General Supply Maintenance Company maintenance warrant officer, July 22, 1998, p. 1; Lead Sheet 18328, Interview with DOD civilian painter at Anniston Ad Dammam paint site, July 28, 1998, p. 1; Lead Sheet #18051, Interview with 900th General Supply Maintenance Company shop officer, July 15, 1998, p. 1.
79. Lead Sheet #15190, Interview with 325th Maintenance Company painter, Feb. 25, 1998, p. 2.
80. Lead Sheet #15359, Interview with 593rd Area Support Group commanding officer, March 6, 1998, p. 1.
81. Lead Sheet #15120, Interview with 325th Maintenance Company commanding officer, Feb. 17, 1998, p. 1.
82. Lead Sheet #15853, Interview with 325th Maintenance Company painter, April 6, 1998, p. 1.
83. "Logistical Concerns Requiring Assistance."
84. "Paint Operations at Al Jubayl," equipment tally.
85. Lead Sheet #15853, Interview with 325th Maintenance Company painter, April 6, 1998, p. 1.
86. Lead Sheet #14254, Interview with 325th Maintenance Company painter, January 26, 1998, p. 1-2.
87. Photo taken by US Army Support Group safety officer.
88. 325th Maintenance Company, Daily Report - Al Jabail Port Paint Facility, Dec. 21, 1990 to Jan. 26, 1991, website: http://www.gulflink.health.mil/declassimages/army/19960116/011696_117_8_001.html
89. 325th Maintenance Company, Daily Report - Al Jabail Port Paint Facility, Dec. 21, 1990 to Jan. 26, 1991, website: http://www.gulflink.health.mil/declassimages/army/19960116/011696_117_8_001.html
90. Lead Sheet #14346, Interview with 325th Maintenance Company mechanic, Feb. 4, 1998, p. 1; Lead Sheet #15190, Interview with 325th Maintenance Company painter, Feb. 25, 1998, p. 2; Lead Sheet #14228, Interview with 325th Maintenance Company painter, January 21, 1998, p. 1-2; Lead Sheet #14978, Interview with 325th Maintenance Company painter, Feb. 10, 1998, p. 1.
91. Lead Sheet #15853, Interview with 325th Maintenance Company painter, April 6, 1998, p. 1; Lead Sheet #14254, Interview with 325th Maintenance Company painter, Jan. 26, 1998, p.1; Lead Sheet #14346, Interview with 325th Maintenance Company mechanic, Feb. 4, 19998, p. 1; Lead Sheet #14228, Interview with 325th Maintenance Company painter, Jan. 21, 1998, p. 1-2; Lead Sheet #14978, Interview with 325th Maintenance Company painter, Feb. 10, 1998, p. 1.
92. Lead Sheet #15853, Interview with 325th Maintenance Company painter, April 6, 1998, p. 1; Lead Sheet #14978, Interview with 325th Maintenance Company painter, Feb. 10, 1998, p. 1.
93. Lead Sheet #24332, Interview with air compressor manufacturer representative, July 14, 1999, p. 1.
94. Lead Sheet #15853, Interview with 325th Maintenance Company painter, April 6, 1998, p. 1; Lead Sheet #14346, Interview with 325th Maintenance Company mechanic, Feb. 4, 1998, p. 1; Lead Sheet #14978, Interview with 325th Maintenance Company painter, Feb. 10, 1998, p. 1.; Lead Sheet #21577, Notes from watching video of paint site inspections taken by 22nd Support Command safety officer, Feb. 5, 1999, p. 1.
95. Photo taken by 325th Maintenance Company commanding officer.
96. Tape TVT 3-40, "(CARC) Chemical Agent Resistant Coating," and Tape TVT 3-29, "CARC/CPP (Chemical Agent Resistant Coating/Camouflage Pattern Painting," were in existence during Desert Shield/Storm.
97. Lead Sheet #14346, Interview with 325th Maintenance Company mechanic, Feb. 4, 1998, p. 1; Lead Sheet #14978, Interview with 325th Maintenance Company painter, Feb. 10, 1998, p. 1; Lead Sheet #15190, Interview with 325th Maintenance Company painter, Feb. 25, 1998, p. 1.
98. Lead Sheet #14346, Interview with 325th Maintenance Company mechanic, Feb. 4, 1998, p. 1; Lead Sheet #19487, Interview with 325th Maintenance Company painter, Oct. 16, 1998, p. 1; Lead Sheet #14228, Interview with 325th Maintenance Company painter, Jan. 21, 1998, p. 2; Lead Sheet #14978, Interview with 325th Maintenance Company painter, Feb. 10, 1998, p. 2; Lead Sheet #15190, Interview with 325th Maintenance Company painter, Feb. 25, 1998, p. 2; Lead Sheet #14254, Interview with 325th Maintenance Company painter, Jan. 26, 1998, p. 2; Lead Sheet #15853, Interview with 325th Maintenance Company painter, April 6, 1998, p. 1; Lead Sheet #21081, Interview with 325th Maintenance Company painter, Jan. 13, 1999, p. 2.
99. Hypersensitivity pneumonitis is a condition in which lung tissue is highly sensitive and easily inflamed by certain stressors. This is a type of chronic pneumonia caused by a chemical such as HDI or certain microorganisms.
100. Lead Sheet. #15853, Interview with 325th Maintenance Company painter, April 6, 1998, p. 1; Lead Sheet #15190, Interview with 325th Maintenance Company painter, Feb. 25, 1998, p. 2.
101. VII Corps message, Subject: "Commander's SITREP #55," March 12, 1991.
102. VII Corps safety officer, "Jubail Paint Site Safety Information."
103. VII Corps safety officer, "Jubail Paint Site Concept of Operations."
104. VII Corps Redeployment LNO Coordinator Notes #6, SUPCOM Evening Brief, 23 MAR 91, March 25, 1991.
105. VII Corps Redeployment LNO Coordinator Notes #24, SUPCOM Evening Stand-up, 12 Apr 91, April 13, 1991.
106. Lead Sheet #21577, Notes from watching video of paint site inspections taken by 22nd Support Command safety officer, Feb. 5, 1999, p. 1.
107. VII Corps LNO to 22D SUPCOM Notes #35, SUPCOM Morning Stand-up 23 APR 91, April 24, 1991.
108. Journal of a 22nd Support Command safety officer, p. 11.
109. Journal of a 22nd Support Command safety officer, p. 13.
110. Lead Sheet #21577, Notes from watching video of paint site inspections taken by 22nd Support Command safety officer, Feb. 5, 1999, p. 1.
111. Journal of a 22nd Support Command safety officer, p. 8.
112. Journal of a 22nd Support Command safety officer, p. 13-14.
113. Lead Sheet #15853, Interview with 325th Maintenance Company painter, April 6, 1998, p. 1-2; Lead Sheet #15190, Interview with 325th Maintenance Company painter, Feb. 25, 1998, p. 1.
114. Photo taken by US Army Support Group safety officer.
115. Lead Sheet #19604, Map provided by U.S. Army Support Group safety officer, Feb. 10, 1999.
116. Army Materiel Command/U.S. Army Support Group (Provisional), Operation Desert Storm Saudi Arabia, safety officer, 15 January 1991 - 21 July 1991, briefing slides.
117. Lead Sheet #19604, Interview with US Army Support Group safety officer, October 22, 1998, p. 3.
118. Lead Sheet #21577, Notes from watching video of paint site inspections taken by 22nd Support Command safety officer, Feb. 5, 1999, p. 1-2.
119. Photo taken by US Army Support Group safety officer.
120. Lead Sheet #20618, Interview with 22nd Support Command safety officer, Feb. 16, 1999, p. 2.
121. Photo taken by US Army Support Group safety officer.
122. Memorandum from USASG-F to Commander, 22nd Support Command (TAA), Subject: "Kuwait Passes for Official Duty," June 21, 1991.
123. Lead Sheet #19604, Interview with US Army Support Group safety officer, Oct. 22, 1998, p. 2.
124. "E-10 CARC Painting Operations."
125. Lead Sheet #19604, Map provided by U.S. Army Support Group safety officer, Feb. 10, 1999.
126. Lead Sheet #14234, Interview with 3rd Armored Calvary Regiment painter, Jan. 22, 1998, p. 1; Lead Sheet #14237, Interview with 3rd Armored Calvary Regiment painter, Jan. 22, 1998, p. 1-2.
127. Lead Sheet #15548, Interview with 24th Infantry Division painter, March 24, 1998, p. 1; Lead Sheet #15881, Interview with 89th Military Police Brigade painter, April 7, 1998, p. 1.
128. ARCENT message, Subject: "Occupational Medicine/Industrial Hygiene Support to DESCOM," Oct. 29, 1990, p. 1.
129. Lead Sheet #14270, Interview with 105th Medical Detachment environmental science officer, January 28, 1998, p. 1.
130. Memorandum from 12th Medical Detachment for Commander, 176th Maintenance Battalion, Subject: "Industrial Hygiene and Safety Evaluation of 'CARC' Painting Operations," December 20, 1990, p. 2.
131. Memorandum for Record from Safety Director, Subject: "Hazard report, CARC painting operation," Dec. 15, 1990.
132. Lead Sheet #14379, Interview with 12th Medical Detachment industrial hygienist, Feb. 9, 1998, p. 1; Lead Sheet #14369, Interview with CARC paint site inspector, Feb. 6, 1998, p. 1.
133. Memorandum for Record from SUPCOM, Surgeon/CDR, SUPCOM Med Grp (Prov), Subject: "CARC Painting," p. 1, website: http://www.gulflink.health.mil/declassdocs/army/19961108/110596_aug96_decls1_0002.html (as of Jan. 21, 2000)
134. Lead Sheet #14390, Interview with 12th Medical Detachment occupational medicine physician, July 8, 1999, p. 2.
135. Memorandum for Record from SUPCOM, Surgeon/CDR, SUPCOM Med Grp (Prov), Subject: "CARC Painting," p. 1, website: http://www.gulflink.health.mil/declassdocs/army/19961108/110596_aug96_decls1_0002.html (as of Jan. 21, 2000)[
136. Memorandum from 12th Medical Detachment, for Commander, 176th Maintenance Battalion, Subject: "Industrial Hygiene and Safety Evaluation of 'CARC' Painting Operation," Dec. 20, 1990, p. 1.
137. Memorandum from 12th Medical Detachment for Commander, 176th Maintenance Battalion, Subject: "Industrial Hygiene and Safety Evaluation of 'CARC' Painting Operations," Dec. 20, 1990, p. 2.
138. Memorandum from 12th Medical Detachment for Commander, 176th Maintenance Battalion, Subject: "Industrial Hygiene and Safety Evaluation of 'CARC' Painting Operations," Dec. 20, 1990, p. 2-3.
139. Memorandum Record from Department of the Army, Army Materiel Command, United States Army Support Group, Subject: "Paint Operations in SWA," April 5, 1991, p. 1.
140. Memorandum Record from Department of the Army, Army Materiel Command, United States Army Support Group, Subject: "Paint Operations in SWA," April 5, 1991, p. 3.
141. Memorandum Record from Department of the Army, Army Materiel Command, United States Army Support Group, Subject: "Paint Operations in SWA," April 5, 1991, p. 1-2.
142. Lead Sheet #20572, Interview with DOD civilian safety manager for VII Corps in theater, December 3, 1998, p. 1-2.
143. Memorandum from Headquarters 22nd SUPCOM, for Director, 22nd SUPCOM Safety, Subject: "Chemical Agent Resistant Coating (CARC) Paint Operations, Ports of Dammam and Jubayl," April 28, 1991, p. 1-2.
144. Memorandum from Army Materiel Command for 22nd SUPCOM Safety Officer, Subject: "Paint Operations," April 20, 1991, p. 1.
145. Memorandum from Headquarters 22nd SUPCOM, For Director, 22nd SUPCOM Safety, Subject: "Chemical Agent Resistant Coating (CARC) Paint Operations, Ports of Dammam and Jubayl," April 28, 1991, p. 3-4.
146. Memorandum for Record, from USASG Safety Officer, Subject: "Paint Operations," April 28, 1991, p. 1-2.
147. Memorandum from USASG Safety Officer for 22nd SUPCOM Safety Officer, Subject: "Paint Operations," April 20, 1991, p. 1.
148. Memorandum from Department of the Army, Medical Group (Provisional) Preventive Medicine Team to Commander, SUPCOM Medical Group, Subject: Potential Medical Hazards at the Damman Port CARC Paint Site, May 26, 1991, p. 2.
149. Memorandum from Department of the Army Preventive Medicine Team, through Commander, SUPCOM Medical Group, Subject: "Assessment of the Al Jubayl CARC Paint Site," June 12, 1991, p. 1-2.
150. Headquarters Marine Corps message, Subject: "Requirements for Temporary Desert Camouflage Paint," Aug. 28, 1990.
151. Lead Sheet #17979, Interview with Marine Corps System Command engineer, July 13, 1998, p. 1.
152. Lead Sheet #18072, Interview with USMC Master Gunnery Sergeant, July 15, 1998, p. 1.
153. Lead Sheet #18072, Interview with USMC Master Gunnery Sergeant, July 15, 1998, p. 1.
154. Lead Sheet #18072, Interview with USMC Master Gunnery Sergeant, July 15, 1998, p. 1.
155. Lead Sheet #18072, Interview with USMC Master Gunnery Sergeant, July 15, 1998, p. 1.
156. Lead Sheet #15187, Interview with Army Research Laboratory research chemist, March 8, 1999, p. 2; and Lead Sheet #27367, Interview of Navy industrial hygiene personnel, July 24, 2000.
157. Lead Sheet #22086, Interview with Air Force bioenvironmental engineer in-theater, March 3, 1999, p. 1; and Lead Sheet #27367, Interview of Navy industrial hygiene personnel, July 24, 2000.
158. "Standing Operating Procedures (SOP) CARC Painting Operations."
159. "Standing Operating Procedures (SOP) CARC Painting Operations, revised copy, May 7, 1991."
160. Memorandum from Department of the Army Medical Group (Provisional) Preventative Medicine Team to Commander, Medical Group (Provisional), Subject: "Physical Examinations and Medical Monitoring of Troops Conducting CARC Painting Operations," May 28, 1991, p. 1.
161. A discussion of the requirements found in "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, is found in this report in Section III. Description of CARC and Tab E., Occupational Safety and Health Guidance.
162. Memorandum from Department of the Army Medical Group (Provisional) Preventive Medicine Team to Commander, Medical Group (Provisional), Subject: "Physical Examinations and Medical Monitoring of Troops Conducting CARC Painting Operations," May 28, 1991, p. 1-2.
163. Memorandum from Headquarters, VII Corps Redeployment Command, to Commander, VII Corps Redeployment Command, Subject: "Health and Safety Recommendations for CARC Painting Sites," June 4, 1991.
164. Lead Sheet #15654, Interview with Occupational medicine physician at Fort Stewart, March 31, 1998, p. 1.
165. Lead Sheet #15190, Interview with 325th Maintenance Company painter, Jan. 4, 1999, p. 2; Lead Sheet #21081, Interview with 325th Maintenance Company painter, January 13, 1999, p. 2.
166. Letter from Charles T. Canady, Congress of the United States, House of Representatives, April 27, 1993.
167. Letter from Charles T. Canady, Congress of the United States, House of Representatives, May 28, 1993.
168. Letter from Lt. Gen. John B. Conaway, National Guard Bureau, May 20, 1993.
169. Memorandum from the National Guard Bureau for Acting Chief, National Guard Bureau, Subject: "NGB-IG Assessment of Patient Administration and Health Care for National Guard Desert Storm/Shield Veterans-Action Memorandum," June 30, 1994.
170. Testimony of Maj. Gen. Robert F. Ensslin, Jr. before the Subcommittee on Oversight Investigations of the Committee on Veterans' Affairs, House of Representatives, June 9, 1993, p. 282.
171. Final Report of the Presidential Advisory Committee (PAC) on Gulf War Veteran's Illnesses, Washington, DC: US Government Printing Office, December 1996, Executive Summary p.1. website: http://www.gwvi.ncr.gov/exsumm-f.html (as of Jan. 21, 1999)
172. Testimony of Mr. Tim Ivories and Mr. William Carpenter before the Presidential Advisory Committee (PAC), Oct. 9, 1996, website http://www.gwvi.ncr.gov/1009gulf.html (as of Jan. 21, 1999).
173. The DOD's Comprehensive Clinical Evaluation Program (CCEP) is available to all Gulf War veterans currently on active duty, active in the Reserves or National Guard, or retired from the military. The program begins with an in-depth medical evaluation.
174. Current National Guardmembers in the 325th Maintenance Company must first register in the CCEP and complete Phase I before a line of duty (LOD) investigation can begin. LOD investigations are then managed by the Headquarters of the Florida National Guard and are sent to the National Guard Bureau for determination of line of duty status.
175. Lead Sheet #21390, Interview with Florida National Guard personnel representative, Feb. 2, 1999, p. 1-2.
176. The Department of Veterans Affairs Persian Gulf War Registry is for Gulf War veterans not currently on active duty. It begins with a free, complete physical examination with basic laboratory studies.
177. Lead Sheet #21390, Interview with Florida National Guard personnel representative, Feb. 2, 1999, p. 2.
178. Lead Sheet #14336, Interview with Executive Director of the Florida Department of Veterans Affairs, Feb. 11, 1998, p. 1.
179. Banks, D.E., "Respiratory Effects of Isocyanates," Environmental and Occupational Medicine, 1998, p. 542.
180. Memorandum from the Joint Chiefs of Staff to Under Secretary of Defense for Personnel and Readiness, et. al., Subject: "Deployment Health Surveillance and Readiness," Dec. 4, 1998, p. 3.
181. DD Form 2697, Report of Medical Assessment, November 1995.
182. Military Specification, Coating, Aliphatic Polyurethane, Chemical Agent Resistant, MIL-C-46168D(ME), May 21, 1987, p. 2.
183. Military Specification, Coating, Aliphatic Polyurethane, Chemical Agent Resistant, MIL-C-53039A(ME), Nov. 23, 1988, p. 9.
184. Material safety data sheet taken off a paint can in theater, 686 Tan, Type II, MIL-C-46168D; Lead Sheet #21577, Notes from watching video of paint site inspections taken by 22nd Support Command safety officer, Feb. 5, 1999, p. 1.
185. Lead Sheet # 15187, Interview with Army Research Laboratory research chemist, Aug. 9, 1999, p. 4.
186. U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, NIOSH Pocket Guide to Chemical Hazards, June 1994, p. 160.
187. U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, NIOSH Pocket Guide to Chemical Hazards, June 1994, p. 160.
188. U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, NIOSH Pocket Guide to Chemical Hazards, June 1994, p. x.
189. 1999 TLVs ï¿½ and BEIs�: Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, Cincinnati, OH: American Conference of Governmental Industrial Hygienists, 1999, p. 3.
190. 1999 TLVs ï¿½ and BEIs� Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, Cincinnati, OH: American Conference of Governmental Industrial Hygienists, 1999, p. 41.
191. 1999 TLVs ï¿½ and BEIs�: Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, Cincinnati, OH: American Conference of Governmental Industrial Hygienists, 1999, p. 4.
192. Memorandum for All Medical Facility/SGPB from Detachment 1, HSC/OEMI, Subject: "Consultative Letter, AL-OE-BR-CL-1998-0105, 1,6-Hexamethylene Diisocyanate Exposures During Polyurethane Spay Painting Operations," Aug. 28, 1999, p. 1-2.
193. Bayer Corporation, Hexamethylene Diisocyante Based Polyisocyantes Health and Safety Information, Pittsburgh, PA: Bayer Corporation, 1999, p. 2.
194. Department of Defense Instruction, 6055.1, "DOD Safety and Occupational Health (SOH) Program," Aug. 19, 1998, p. 2.
195. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 2-1. Note: A personal sample is taken with a monitoring device on the person to measure the amount of an individual's exposure.
196. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 7-3.
197. U.S. Department of Labor, Occupational Safety and Health Administration, "OSHA Standards Interpretation and Compliance Letters," March 3, 1986. Website http://www.osha-slc.gov/OshDoc/Interp_data/I19860303.html.(as of Jan. 21, 1999)
198. OSHA has subsequently revised its respiratory guideline to allow for the use of air purifying respirators in polyurethane (CARC) painting operations. OSHA Instruction CPL 2-0.120, Inspection Procedures for the Respiratory Protection Standard of Sept. 25, 1998, established a new policy such that "where an effective change schedule is implemented, air purifying gas and vapor respirators may be used for hazardous chemicals, including those with few or no warning properties." This policy, however, was not in effect during the time period addressed in this report.
199. Letter from the National Institute for Occupational Safety and Health (NIOSH), Aug. 7, 1990. 0271.
200. Headquarters, Department of the Army, Technical Manual 55-1500-345-23, "Painting and Marking of Army Aircraft," June 12, 1986, p. 8-16.
201. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 2-3.
202. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 2-5.
203. U.S. Department of Labor, Occupational Safety and Health Administration, Hazard Communication Standards, 29 CFR 1910.1200 (b)(3)(ii).
204. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 4-1.
205. Industrial Safety and Installation Support, "Chemical Agent Resistant Coating, A Safety Support Pamphlet," Fort Novosel (formerly Fort Rucker), Alabama, Jan. 9, 1988.
206. U.S. Department of Labor, Occupational Safety and Health Administration, Hazard Communication Standards, 29 CFR 1910.1200.
207. U.S. Army Environmental Hygiene Agency, "Guidelines for Controlling Health Hazards in Painting Operations," Technical Guide 144, Aug. 24, 1987, p. 4-1.
208. Department of Defense, Instruction 6050.5, "DOD Hazard Communication Program," May 6, 1996, p. 1-6.