Comment submitted by Holden Looper

4,772 characters, still under the limit. Here's the updated version: --- I work in asbestos abatement, lead remediation, and environmental testing, primarily on jobs tied to insurance restoration following fire, water, and storm damage. I am submitting this comment to raise a use case I do not believe is reflected in the current framing of this risk management effort: asbestos abatement performed in the context of insurance claims following property damage emergencies. In my region, approximately 50 to 60 percent of homes built before 1984 that we test come back positive for asbestos containing materials. This is not a rare or marginal condition of use. It is a routine reality in the building stock that insurance restoration contractors encounter every week, which makes the timing and authorization issues described below a recurring, not occasional, public health concern. Legacy asbestos exposure is often discussed in the context of planned demolition and renovation work, and workers who cut, sand, or grind asbestos containing material on a regular basis. That framing does not capture a distinct and recurring scenario: a tree falls through a roof, a fire causes a ceiling collapse, or an emergency plumbing repair requires opening a wall or ceiling cavity, and the building contains legacy asbestos in textured ceiling material, floor tile, pipe wrap, or insulation. In these situations the hazard is created suddenly and sits in the open air of an occupied or soon to be reoccupied structure until it is addressed. The obstacle is not technical and it is not a lack of qualified contractors. It is that insurance carriers and adjusters, who control funding and authorization for this work, do not treat asbestos abatement as a true emergency service the way they treat board up, water extraction, or temporary roof tarping. Carriers frequently require a full estimate, multiple rounds of approval, and sometimes additional inspection before authorizing abatement, even when the damaged material is confirmed asbestos containing and actively friable. Jobs exist where damaged asbestos containing material has sat exposed for multiple weeks while a claim moved through carrier approval. During that time, occupants, other contractors on site, and first responders are potentially exposed to airborne fibers, not because the work is difficult, but because the entity controlling payment did not recognize the urgency. This creates a perverse outcome. The same legacy asbestos hazard this risk evaluation found poses an unreasonable risk to human health is, in the property insurance context, treated as a line item to be negotiated rather than a hazard to be abated immediately. Contractors are left choosing between proceeding without confirmed payment to protect occupants, or waiting on approval while a known hazard remains in place. Neither choice should be necessary, and the current regulatory definition of emergency renovation was not built with insurance claims timelines in mind, leaving contractors, adjusters, and regulators all working from different informal understandings of when a hazard like this qualifies as an emergency. I respectfully request that any risk management rule resulting from this Part 2 evaluation include explicit recognition that asbestos abatement necessitated by sudden, unplanned property damage, such as storm, tree, fire, or water intrusion events that disturb or expose legacy asbestos containing material, qualifies as emergency work. Specifically, I ask the Division to: 1. Define a clear, workable standard for when sudden property damage that exposes or disturbs legacy asbestos containing material qualifies as an emergency condition of use, separate from planned renovation or demolition, so contractors and regulators are not left to interpret the line case by case. 2. Make clear in guidance to insurance carriers and adjusters that abatement of confirmed or suspected friable asbestos containing material following a covered loss event should be authorized and proceed on an emergency basis, consistent with how carriers already treat water mitigation and board up, rather than being subject to the standard estimate approval cycle. 3. Ensure any documentation or notification requirements in the final rule can realistically be met on an emergency timeline, so the rule itself does not become another source of delay between hazard discovery and abatement. I support EPA's effort to develop a practical, science based rule for legacy asbestos. I ask that the rule account for the reality that a meaningful share of legacy asbestos disturbance happens not on a contractor's planned schedule, but on an insurance carrier's claims schedule, and that the two are often not aligned with the urgency the hazard actually presents. Thank you for the opportunity to comment.