One of the components in processing archival records is recognizing potential concerns in making the records available to the public.  Usually this involves restricting financial records, identifying privacy issues, and looking for potential legal issues with the ultimate goal always toward access.

Harris County established the United States’ earliest pollution unit in November 1953. Having only nuisance laws available to go after polluters, Director Dr. Walter Quebedeaux (seen here) was an unrelenting advocate for clean air, water, and soil.  He angered corporate interests and government officials by using whatever means necessary to obtain compliance including appearing on local media to gain the support of the public.  When he died suddenly in 1976, the department began to pursue a course of “gently nudging” and “working with” polluters.

Although federal and state laws existed allowing the county to sue polluters, few criminal or civil suits were brought by Harris County against major polluters after Dr. Quebedeaux's death.  Pollution Control had been gutted.  Inadequately funded by Commissioners Court and buried bureaucratically, Pollution Control didn’t have the resources to go after major polluters, so they concentrated on the complaints that were easier to investigate.

On March 17, 2019, a fire started that burned for 60 hours at the Intercontinental Terminals Company on the Houston Ship Channel in heavily populated East Harris County.  Pollution Control did not have the personnel, equipment, or resources to monitor the fire and warn the public about hazardous conditions. 

Two weeks later another dangerous fire broke out at KMCO in Crosby only 10 miles from the first fire.  A newly elected Commissioners Court responded by providing much-needed funding for Pollution Control and the Fire Marshall’s Office.  At the end of April, the director of Pollution Control retired.

In mid-April, the County Archives was informed it would be receiving over 425 cubic feet of records, including Administrative Records (3 cubic feet), Legal Records (12 cubic feet), Scrapbooks (32 volumes), Printed Materials (86 items), Complaints and Investigations (180 cubic feet), Photographs (24.5 cubic feet), Maps (15 items) and Audio-Visual Materials (6 items) 1953 - 2010.  The amounts in parenthesis indicate the extent of records after processing.

The largest series, Complaints and Investigations, comprised over 360 cubic feet of unprocessed records.  These ranged from complaints about a neighbor burning trash to investigations of the most egregious polluters in Harris County.

Unfortunately, no retention guidelines were followed in maintaining the records.  Records with the retention of only a few years were interfiled with those that needed to be retained permanently.

Why is this a risk? 

We had to reduce the physical bulk of the series without destroying records that documented long-lasting environmental damage.

With no clear-cut guidelines and little assistance from the Pollution Control office staff, we needed to determine which files to keep and which could be destroyed.

To help determine what to keep versus what to destroy, the project archivist and the County Archivist determined the index points we would use to evaluate the case files. (See slide)

We then inventoried 5 boxes chosen randomly and entered the information into an excel spreadsheet. Not surprisingly, we found significant correspondence interfiled with the Complaints and Investigations. According to our calculations, we would be saving only 15 percent of the case files.

Then we sent an explanation of the project and the results to the former records manager for the county, the retired pollution control director, the acting pollution control director, the Pollution Control public information staff member, and the environmental division of the County Attorney’s Office.

Then we waited.

We received responses from the former Records Manager and Pollution Control Director relatively quickly.  They were both encouraging but didn’t offer any specific advice except to be sure to add cleaners to our list of possible environmental polluters.

Then we waited.  We continued research into the environmental history of Harris County, including the notorious French Limited case on the San Jacinto River.

We received encouraging feedback from the compliance officer at Pollution Control.  She checked her records against our inventory.  Out of 262 entries, she had only 4 suggestions: adding historical violations, county departments, multiple violations from the same polluter, and even minor complaints if they occurred on locations with historic violations such as the San Jacinto River.

We now had the information needed to develop the parameters to begin processing the Complaints and Investigations.  Each folder or file was examined, and if any part of it met the above criteria, it was saved.

The result was 180 cubic feet of records, or 50% was saved according to bulk from 1967–2010, with most of the records from the 1980s. [There had been a fire in the early 1970s, and most of those records were lost.]

Although the Public Information Officer from Pollution Control objected to any reduction in the collection's size prior to our project, we have received no requests for records after sending updated inventories for all photographs and case files.  We have kept those records with potential long-term environmental damage and eliminated those with little or no environmental impact.

When the Houston Ship Channel was developed as an inland seaport with cotton warehouses and compresses in the early 20th century, little thought was given to what would become of the waterway in just a few decades.  The cotton warehouses are gone, and highly toxic by-products take the place of former paper plants and oil refineries.

The risk the Harris County Archives acknowledged was to not save the historical records documenting the harm done to the environment.  Using records management principles, pilot projects, asking for comments from those experienced in the field, and researching, we successfully mitigated that risk. We made these valuable records available to the public.

Click here to access the Pollution Control Records Finding Aid.