Pre-demolition asbestos management begins with an inspection for asbestos. If the quantity of RACM exceeds NESHAP action levels, the following regulated sequence of events, each performed by contractors licensed by the Texas Department of Health (TDH), must occur:

TxDOT surplus and salvage property procedures entail transferring the title to buildings and other improvements to the salvage contractor before demolition. However, TDH will not necessarily recognize the severability of improvements from the land and may consider TxDOT liable for the salvage contractor's non-compliance with NESHAP requirements.

To avoid potential liability for violations of NESHAP requirements by the salvage contractor, contract for asbestos inspection, abatement planning, notification, air and water monitoring, and reporting. Include the abatement plan (i.e., specification) in the bid package for the salvage contract. The salvage contractor must subcontract abatement activities using the specification developed by TxDOT's asbestos contractor.

In most cases, cost recovery from the former property owner for asbestos abatement is not possible because the requirement for abatement is triggered by demolition of the building before construction. Therefore, the abatement is classified as preventative action instead of corrective action.