The following contains a number of key lessons learned during the investigation of the Kuwaiti oil well fires. These lessons learned are not intended to reflect the opinions or position of other governments or other US departments or agencies. Where appropriate recommendations are made to address or to otherwise correct noted discrepancies or shortcomings.

A. Personal Protective Equipment

In general, US troops were not well prepared to protect themselves against the acute health effects presented by the oil fire smoke. Rather, personal protective equipment was limited to MOPP gear that included the M-17A1 gas mask. While this gas mask would have been sufficient to protect the troops against various gases and particulate matter, the filter elements would have quickly become saturated with particulate matter, thereby limiting their ability to protect troops against the primary threat for which they were intended, namely chemical and biological agents. Some equipment such as cravats, nuisance dust masks, surgeons masks, etc. were available on a limited and varied basis, and were often obtained through the initiative of the troops. However, this equipment not only received limited distribution, but was also limited in the degree to which it could provide effective protection.

The general lack of effective and readily available respiratory protection may have been the result of underestimating the degree of destruction sustained by the oilfields. This could have resulted from the fact that the environmental catastrophe was unprecedented in addition to some early intelligence that projected the number of burning wells to total about 150, which was considerably less than the approximately 750 that were actually damaged and destroyed.

In the future, potential environmental hazards, and potential targets for environmental terrorism should be more fully characterized during pre-operation planning so that the appropriate personnel protective posture including protective equipment and training can be provided prior to deployment rather than after the fact.

B. Response to Environmental Terrorism

The destruction of the Kuwaiti oil fields was intended to not only degrade the economic base of Kuwait but also to provide a tactical advantage to Iraqi military operations. It was believed that the smoke, oil lakes, fire trenches, and the presence of hazardous gases associated with the crude oil would conceal Iraqi military positions and movement and also impede the advance of Coalition forces. Regardless of the intent, the oil fires provided a significant threat to human health and the environment of the region. In the future, any natural and man-made threats existing in a potential theater of operation should be identified and fully accounted for during the operational planning phase.

In terms of legal response very few direct sources of liability or relief exist for deliberate wartime destruction of the environment. Historically, the laws of war have focused on the treatment of prisoners and noncombatants, the necessity and proportionality of the use of force, and the use of weapons of mass destruction. Existing international environmental protection laws focus on standards of care and civil liability for negligent (unintentional) environmental damage and not on willful and intentional destruction to the environment. Revisions to international law and possibly to the Geneva Convention on environmental warfare may be appropriate so that existing provisions encompass a wide variety of military activities, more narrowly define any exception that may be applicable, and hold responsible parties accountable as war criminals.

C. Risk Assessment

The US EPA Superfund Risk Assessment Methodology was used to calculate excess cancer and non-cancer risk from oil fire smoke exposures. This risk assessment methodology calculates cancer and non-cancer risk based on a lifetime of exposure and was designed to provide protection not only for the general population but also for sensitive populations that included the elderly, children, and the sick. Therefore, the methodology adopted for use in this investigation provides for a somewhat conservative level of protection. This methodology may be inappropriate to apply to US troops for two reasons. First, the duration of exposure for US troops in the Persian Gulf was short-term (i.e., a few hours to several months versus lifetime), and second, it could be argued that US troops are not considered a "sensitive" population when considering non-cancer risks since they are predominantly young, healthy adults. The result of both of these factors is that estimated risk level for US troops is probably largely overstated. Therefore it may be appropriate that the DoD develop a risk assessment methodology that is more consistent with the population to be protected and also one that takes into consideration the duration of exposure.

D. Monitoring/Sampling Issues

Monitoring programs were initiated shortly after the ground war to characterize the potential impact from the oil fires to human health and the environment. Air quality monitoring began in Kuwait in March 1991 more than a month after the oil fires began. Initial efforts to conduct monitoring were varied in scope, typically short-term in duration, to some extent duplicative in scope, and involved various and numerous US and international organizations. It wasn’t until May 1991 that a comprehensive long-term monitoring program was initiated. This program, however, missed the first three months and the most intense period of the fires (firefighting efforts began in March 1991). To account for this gap, data was "back-filled" using computer atmospheric dispersion modeling. Furthermore, databases containing the results of monitoring activities are numerous and varied making data/information search and retrieval laborious and time intensive. To avoid similar problems in the future a number of recommendations involving mobilization, clearance, and funding should be implemented. These include:

The monitoring activities conducted after the cessation of hostilities were for the most part responsive and comprehensive. From both a qualitative and quantitative perspective the air quality data collected was sufficiently robust to allow for the characterization of the nature and extent of ambient contamination, however, it may not be entirely appropriate to support the exposure assessment and risk characterization investigations that followed. For example, there is some discussion that ambient monitoring may not necessarily be the most effective way to assess the potential dose to personnel during deployment, especially under conditions in which troops are subjected to short-term intense exposures.

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