Newsletter #66
November 24, 2020

We thought that you would be would want to know that the Final Risk Evaluation for Trichloroethylene, commonly known as TCE, was released today by the U.S. Environmental Protection Agency.

TCE was one of the major toxic chemicals released from IBM’s operation in Endicott. We didn't need to have this new report to tell us that those exposed to it have been put in harm's way for several decades, but it is good that this "final" report is now available.

NoBurnBroome's concerns about the toxic releases from SungEel's lithium-ion battery operation include the facts that known human carcinogens and PFAS chemicals will be released into Endicott's health-compromised community. We all know that this an unreasonable risk for Endicott and that is why we are fighting it.

The following are the KEY POINTS from the Non-technical Summary of the TCE Risk Evaluation,

After evaluating 54 conditions of use of TCE, EPA determined that TCE presents an unreasonable risk under 52 conditions of use. This includes unreasonable risks to health of workers and ONUs [occupational non-users] during occupational exposures, and to consumers and bystanders during exposures to consumer uses.

These unreasonable risks include potential immunosuppression from acute exposures, and autoimmunity and cancer from chronic exposures.

The conditions of use with unreasonable risks are several, including use in various industrial and commercial uses including as a solvent for cleaning.

The conditions of use that EPA determined do not present an unreasonable risk include distribution in commerce and consumer use in pepper spray.

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•• EPA’s summary page on the TCE Risk Evaluation includes links to many subsets of their evaluation,

••• NoBurnBroome has this information online at

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Some Excerpts

Kidney cancer (page 244/803)
The TCE IRIS assessment concluded that TCE is “carcinogenic to humans” based on convincing evidence of a causal relationship between TCE exposure in humans and kidney cancer. A review of TCE by the International Agency for Research on Cancer (IARC) also supported this conclusion (IARC, 2014). The carcinogenic classification was based on a review of more than 30 human studies, including studies in TCE degreasing operations, and meta‐analyses of the cohort and case‐ control studies. Relative risk estimates for increased kidney cancer were consistent across a large number of epidemiological studies of different designs and populations from different countries and industries (Appendix C, (U.S. EPA, 2011b). This strong consistency of the epidemiologic data on TCE and kidney cancer argues against chance, bias, and confounding as explanations for the elevated kidney cancer risks (U.S. EPA, 2011e).
Other cancers (page 245/803)
There is limited evidence of increased risk for esophageal cancer following TCE exposure in males only. The reasonably available evidence is not statistically sensitive enough for informing quantitative evaluations of esophageal cancer risk from TCE. There is some evidence of association for bladder or urothelial cancer and high cumulative TCE exposure, however the reasonably available studies examine multiple sites and do not completely account for potential confounding factors. In several studies examining the relationship between TCE exposure and cancer of the brain or central nervous system (CNS), the data does not provide strong evidence in either direction, although there is some association of TCE exposure with CNS cancers in children (U.S. EPA, 2011e).
Reproductive toxicity (page 247/803)
… Both human and animal data provide consistent evidence for male reproductive effects from TCE. Effects observed include effects on sperm, male reproductive organs, hormone levels, and sexual  mechanistic support for placental effects from metabolites, although the relevance of those studies is uncertain (Section Overall, reproductive toxicity following TCE exposure is supported by the weight of evidence. Therefore, this hazard was carried forward for dose-response analysis.
Developmental Toxicity (page 247/803)
… There is substantial evidence from both animal and human studies that TCE exposure is associated with various developmental outcomes, ranging from decreased birth weight to pre- and postnatal mortality. Other hazards also present following developmental exposure, including developmental immunotoxicity and developmental neurotoxicity. While the epidemiological literature does not consistently observe developmental effects, effects that have been observed in multiple human studies have been corroborated by animal data (Section
Overall, based on suggestive epidemiologic data and fairly consistent laboratory animal data, developmental toxicity for the above adverse outcomes following TCE exposure is supported by the weight of evidence
Developmental toxicity endpoints were considered for both acute and chronic scenarios. Although developmental studies typically involve multiple exposures, they are considered relevant for evaluating single exposures because evidence indicates that certain developmental effects may result from a single exposure during a critical window of development (Davis et al., 2009; Van Raaij et al., 2003). This is consistent with EPA’s Guidelines for Reproductive Toxicity Risk Assessment (U.S. EPA, 1996) and Guidelines for Developmental Toxicity Risk Assessment (U.S. EPA, 1991), which state that repeated exposure is not a necessary prerequisite for the manifestation of developmental toxicity. This is a health protective assumption. Cancer Hazards (page 250/803)
... The IRIS Toxicological Review of TCE (U.S. EPA, 2011e) also cited other lines of supporting evidence for TCE carcinogenicity in humans by all routes of exposure:
“First, multiple chronic bioassays in rats and mice have reported increased incidences of tumor with TCE treatment via inhalation and gavage, including tumors in the kidney, liver, and lymphoid tissues – target tissues of TCE carcinogenicity also seen in epidemiological studies.
“A second line of supporting evidence for TCE carcinogenicity in humans consists of toxicokinetic data indicating that TCE is well absorbed by all routes of exposure, and that TCE absorption, distribution, metabolism, and excretion are qualitatively similar in humans and rodents.”

“Finally, available mechanistic data do not suggest a lack of human carcinogenic hazard from TCE exposure.”

Perinatal death, decreased birth weight, and birth defects (page 241/803)
The Endicott, New York, and the Camp Lejeune studies focused on reproductive and developmental outcomes. Some of these studies have reported associations between parental exposure to TCE and spontaneous abortion or perinatal death, and decreased birth weight. However, other occupational and geographically‐based studies have failed to detect a positive association between TCE exposure and developmental toxicity in humans (U.S. EPA, 2011e).
ATSDR has conducted studies at Camp Lejeune, North Carolina, where individuals were exposed to VOC [Volatile organic compound] ‐contaminated drinking water (Ruckart et al., 2014, 2013). TCE was one of the main contaminants found in the drinking water. Ruckart et al. found an association between neural tube defects and TCE exposure above 5 ppb during the first trimester of pregnancy, however null to negative associations were identified between TCE exposure and other developmental effects (e.g., reduced birth weight, oral cleft defects). Yauck et al. (2004) observed a strong relative risk estimate for cardiac malformations in infants from Milwaukee, Wisconsin born to TCE-exposed mothers aged 38 years or older. In addition to older age, increased risk was also independently associated with other confounders including alcohol use, hypertension, and diabetes. Forand et al. (2012) (an update for the Endicott, NY community) reported significant relative risk estimates for low birth weight, small for gestational age, and cardiac defects. See the below section for further discussion of congenital heart defects...

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Let's ensure that this will be the last report on toxics in Endicott that residents will read

Please donate to the legal fund for the
against the Village of Endicott
This lawsuit challenges the legality of the new recycling zoning code passed on May 7, 2020, to clear the way for the SungEel project.

Lawsuit Supported by NoBurnBroome
Donate at GoFundMe

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