D.  Health and Safety Inspections of the CARC Painting Operations

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 US forces were deployed.[122]

In late 1990, an environmental health surveillance group from the 105th Medical Detachment conducted an inspection at the Anniston Ad Dammam paint site. This 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 precautions, the inspection team procured air-supplied respirators that arrived within a week. Each painter was eventually given an 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.[123]

The 325th Maintenance Company’s Ad Dammam and Al Jubayl paint sites were inspected on several occasions. In a December 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.[124]

Members of the 325th Maintenance Company experienced overexposures to CARC painting during the week of December 10, 1990. Symptoms 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." [125]

On December 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 battle dress 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 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.[126,127]

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.[128] 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 command representatives were also briefed on proper safety procedures. The inspection team left the site on December 19th, 1990. [129,130]

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.[131]

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:

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 conducted in the same manner.[133] He also expressed doubts that a quality paint job could be conducted under the existing conditions and with the available resources.[134] Specific deficiencies requiring correction prior to the redeployment painting operations included:

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.[136]

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:[137]

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.[139]

A memorandum written on April 28th, 1991, by a safety officer from the US Army Support Group[140] 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:

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.[141]

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

Several recommendations were made including:

The report concluded that the proper personal protective equipment has been made available to the soldiers. The report reiterated that it is the responsibility of a leader to ensure his or her soldiers are properly cared for by ensuring that they wear the required personal protective equipment and hearing protection.[142]

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 command and control to be lax and recommended that the site be shut down. Specifically, the following problems were cited at the 325th Al Jubayl paint site:

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.[143]

E.  Marine Corps Painting Operations

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 depleted their supplies. Marine Corps headquarters logistics offices in Quantico, Virginia, quickly located an alternate paint supplier[144] and a sole-source agreement was established with a manufacturer to provide a non-CARC tan latex coating[145] 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.[146] 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 US 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 during the paint operations.[147] 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.[148]

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.[149] Instead, the Marine Corps waited until their vehicles had returned to the continental United States to strip and repaint them.

F.  Air Force Painting Operations

The Air Force uses a more common polyurethane coating. This type of coating more closely resembles the high gloss coatings found on commercial aircraft. However, like the CARCs used by the Army and Marine Corps, the Air Force polyurethane coatings have hexamethylene diisocyanate (HDI), found also in CARC, and a number of solvents. For this reason, the Air Force follows 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 doctrine.[150]

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.[151]

G.  Post War Guidance

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:

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."[154] The guidelines within this memorandum echo the screening requirements found in Technical Guide No. 144,[155] 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:

A command surgeon from VII Corps produced 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 topics of the role of the safety manager and the need for medical history 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.[157]

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