An estimated 200 soldiers from the 325^th 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, 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 deficiencies and hazards, painting activities continued at these two facilities with 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 protection, a number of soldiers directly involved in CARC painting may have suffered adverse respiratory effects from exposures to HDI and solvents. However, this investigation cannot definitively link CARC painting operations to illnesses reported by Gulf War veterans except in a small number of cases, involving a limited number of personnel, where soldiers were 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.

The following section contains a number of important lessons developed during the investigation of CARC painting performed in the Kuwait theater of operations. Where appropriate, the Office of the Special Assistant recommends the following courses of action to address the noted shortcomings.

We determined that pre-deployment and post-deployment CARC-painting operations outside of the Kuwait theater of operations were outside the scope of our investigation.

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 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 planning should incorporate measures to meet occupational safety and health standards even under constrained conditions. Prior planning should improve the military’s ability to quickly establish field-expedient, but safe, CARC paintings sites. Advance training should raise the level of awareness of potential hazards 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 plan for the assignment of an on-site safety professional to provide training, awareness, and monitoring.

In general, US troops tasked to spray paint vehicles in-theater were not trained to carry out their mission, were not fully aware of the occupational safety and health hazards of CARC painting, and were not prepared or equipped to protect themselves against potential paint related hazards. In addition, despite repeated warnings from health and safety specialists in-theater, operational commanders did not fully appreciate the hazards associated with spray painting CARC. 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 prior to deployment. The assigned units could obtain the required procedural and safety training, procure personal protective equipment, and plan for the assignment of an on-site safety professional to provide ongoing training, awareness, and monitoring.

Recent guidance from the Joint Chiefs of Staff, as part of the deployment health surveillance and readiness program addressed this issue. 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).^[174]

The lack of pre-deployment planning prevented appropriate pre-deployment occupational health screening of members of the 325^th 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 325^th 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,^[175] 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. While it is understood that Occupational Safety and Health Administration (OSHA) regulations do not apply during actual combat or during the high threat environment of the initial deployment to the Gulf region, 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 redone 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 sites;
• Assigning trained personnel to establish and oversee paint operations in advance of redeployment. Trained personnel could ensure that proper personal protective equipment was on hand before the painting operations commenced and ensure that 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 volatile organic compounds, developing water-based CARC, and reducing the levels of unreacted 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 includes all the personal protective equipment, tents, explosive proof lighting/electrical outlets, training materials, etc. for CARC painting operations for inclusion in appropriate maintenance units Table of Organization and Equipment.

• Holding commanders accountable for the health and safety of their troops and taking appropriate action to provide the necessary training, to obtain appropriate safety equipment and to ensure that the safety equipment is used and maintained as required and to taking immediate steps to resolve any identified safety and health deficiencies.

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