Comment submitted by Harlan Kanoa N Sheppard, Manager, HD Hazard Control LLC

Dear EPA, I am an abatement contractor in Hawaii (Region IX). Briefly, I strongly support additional coverage of the RRP rule. Being a contractor who works significantly in healthcare settings, I am very cogent of environmental contaminants and what can be an immediate effect on the public. While I recognize that I am an interested party, I do believe in the core of the rule-making as a means of protecting the public and encouraging greater diligence in contractors. Having reviewed the discussion guide, I have the following comments: While it is tempting to treat all unknown material as lead-containing until proved otherwise (identically to asbestos regs), I believe that this may be overly broad and put the rule itself at risk due to it being onerous. The measures set forth by EPA for the RRP rule already seem quite sufficient, if they were more thoroughly implemented and enforced. Here in my state, there is a flagrant disregard for the rule which can be easily seen by touring any neighborhood. The rule needs to include P&CBs and to be enforced rigorously (at least long enough to create industry wide recognition of the matter). Sincerely, Harlan Kanoa N Sheppard Manager, HD Hazard Control