Summary: Trade secrets in FracFocus, an instrument of transparency, explicitly conceal the identity of chemicals. This masking has long been controversial. Open-FF found 28,900 trade secrets in Pennsylvania records. These records spanned all years and 71.9% of published disclosures. About 211,000,000 pounds of trade secret chemicals have been reported. In this post, we summarize the broad patterns of trade secret use in Pennsylvania between 2014 and early 2025. We also illustrate the types of trade secrets patterns in the state with local examples. This post is part of a series reporting on “holes” in FracFocus.
FracFocus is a public online database that provides information about the chemicals used in hydraulic fracturing (fracking) across the United States. While intended to promote transparency, a significant portion of the disclosed chemical information is often withheld as “trade secrets.” This practice has been a subject of debate, balancing industry’s need to protect proprietary formulas with the public’s right to know about substances injected underground.
Background
- The analysis on this page used FracFocus data download on April 20, 2025.
- Labeling of trade secrets is not standardized in the FracFocus data. Open-FF curates the data to make examining all trade secrets possible. See the documentation.
Broad Patterns in Pennsylvania
Quantity of chemicals masked as trade secrets:
211,000,000 pounds
Frequency of Claims: How common are trade secret claims in Pennsylvania?
Across all valid Pennsylvania chemical records, 14.1% are marked as trade secrets. Trade secret claims appear in 71.9 % of all disclosures.
And the breakdown of the frequency of trade secrets within Pennsylvania disclosures is:
Compared to Other States: How does the trade secret use in Pennsylvania compare to other fracking states?
Pennsylvania has a relatively low rate of disclosures with trade secrets compared to most other states.
Pennsylvania has a few unique features in relation to trade secrets. The state has a trade secret registry for fracking chemicals. Although the list is quite long, only about 10% of them appear in FracFocus as ingredient names. Perhaps they are used more frequently in the state-held disclosures (found at this site under “Completion Reports (Unconventional)”) but we have not evaluated that. However, not everything that is claimed as a trade secret in FracFocus uses these state registry names; more than 700 trade secret names are not on state list.
Examples of Trade Secret Use in Pennsylvania
Examining specific examples to highlight the various ways the trade secret designation is applied. Here are some typical scenarios we observed:
Large Percentage of Records as Trade Secrets
In some disclosures, a substantial proportion, sometimes even the majority, of the listed ingredients are marked as trade secrets. This leaves the public with very little information about the chemical composition of the fracturing fluid used in that specific well.
Example: Consider the well operated by EQT Production in Greene County. (Click on images to open map and disclosure.)
In this disclosure, 46% of ingredients are listed as trade secrets. The list of trade secrets for that fracking job are:
| TradeName | IngredientName | CASNumber | mass (pounds) |
|---|---|---|---|
| Ingredient Container | complex amine compound | Proprietary | 31,400 |
| Ingredient Container | substances/mixtures corrosive to metal | Proprietary | 13,400 |
| Ingredient Container | surfractant | Proprietary | 2,610 |
| Ingredient Container | ethoxylated alcohols | Proprietary | 523 |
| Ingredient Container | phosphonic acid salt | Proprietary | 420 |
| Ingredient Container | modified thiourea polymer | Proprietary | 43 |
| Ingredient Container | ethoxylated alcohols | Proprietary | 7 |
Individual Trade Secret Records That Are High Mass
Occasionally, a single ingredient marked as a trade secret represents a significant mass or percentage of the total fluid volume reported in a disclosure. This means a large component of the fracturing fluid’s composition is entirely unknown.
Example: Consider the well operated by Chesapeake Operating, Inc. in Bradford County.
In this well, a single trade secret entry is reported with a mass of 345,000 pounds, representing a significant portion of the total fluid volume. The chemical identity of this large-mass material is withheld, and given the name from the state’s trade secret list: “WST-Scale Inhibitor-00014”
Pennsylvania has 156 trade secret records with masses over 100,000 pounds.
Systems Approach Disclosures with Trade Secret Records
FracFocus disclosures are often published in the “systems approach” format that decouples product names from chemical identity. FracFocus claims that this practice “decreases the use of trade secrets in disclosures, thereby improving public transparency.” Analyses by Trickey et al. and Underhill et al. disprove that claim across the FracFocus data. Instead, we often find system approach disclosures with multiple trade secret claims – because there is nothing to compel companies to include the chemical identity.
Example: Consider the well operated by Repsol O&G, LLC. in Bradford County.
The disclosure for that well utilizes a systems approach format but still conceals the identity of 7 chemicals, which means 50% of ingredients are listed as trade secrets. The table below lists those records with their quantity, which for this disclosure are relatively small amounts.
| IngredientName | CASNumber | mass (pounds) |
|---|---|---|
| fatty acids, tall oil | Proprietary | 156 |
| ethoxylated alcohols | Proprietary | 156 |
| olefins | Proprietary | 62 |
| inorganic salt | Proprietary | 55 |
| alkyl alcohol | Proprietary | 53 |
| armine triphosphate | Proprietary | 49 |
| oxyalkylated alcohol | Proprietary | 27 |
Trade Secret Records Without Any Hints About Material Type
While it is sometimes claimed that operators must supply coarse categories for trade secrets, the data tell a different story. Some trade secret entries provide no descriptive information, such as a functional category (such as “friction reducer,” “surfactant”) or chemical group (“ethoxylated alcohol”), about the material. This makes it impossible to even guess the potential role or nature of the withheld substance.
Examples: The following table lists some of the reported IngredientNames for Pennsylvania’s trade secrets that are also reported without informative values for “Purpose”.
| IngredientName | count |
|---|---|
| proprietary | 1151 |
| non-hazardous substances | 1008 |
| trade secret | 210 |
| proprietary ingredient | 25 |
| trade secret ingredient | 17 |
| proprietary blend | 16 |
| proprietary material | 6 |
Implications for Pennsylvania
The patterns and examples of trade secret usage in Pennsylvania’s FracFocus data highlight the limitations of the database in providing
chemical transparency. While trade secret protection is a legal right when formalized, its extensive use in fracking disclosures raises questions for regulators, researchers, and the public regarding potential environmental and health impacts. Understanding how and where trade secrets are used is a crucial step in evaluating the effectiveness of public disclosure requirements in the state.
Colorado’s recent law requiring enhanced disclosure in a way that still protects intellectual property may serve as a model to improve overall transparency.
References
Trickey, Kevin, Nicholas Hadjimichael, and Prachi Sanghavi. “Public Reporting of Hydraulic Fracturing Chemicals in the USA, 2011–18: A before and after Comparison of Reporting Formats.” The Lancet Planetary Health 4, no. 5 (May 1, 2020): e178–85. https://doi.org/10.1016/S2542-5196(20)30076-0.
Underhill, Vivian, Gary Allison, Holden Huntzinger, Cole Mason, Abigail Noreck, Emi Suyama, Lourdes Vera, and Sara Wylie. “Increases in Trade Secret Designations in Hydraulic Fracturing Fluids and Their Potential Implications for Environmental Health and Water Quality.” Journal of Environmental Management 351 (February 1, 2024): 119611. https://doi.org/10.1016/j.jenvman.2023.119611.
Title image credit: Becky Mansfield (modified by author)