FracFocus Trade Secrets in Louisiana

Summary: Trade secrets in FracFocus, an instrument of transparency, explicitly conceal the identity of chemicals. This masking has long been controversial. Open-FF found 15,700 trade secrets in Louisiana records. These records spanned all years and 85.5% of published disclosures. About 1,520,000,000 pounds of trade secret chemicals have been reported. In this post, we summarize the broad patterns of trade secret use in Louisiana 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.¹

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 the subject of debate of how to balance industry’s need to protect proprietary formulas with the public’s right to know about substances injected underground.

Broad Patterns in Louisiana

Quantity of chemicals masked as trade secrets:

1,520,000,000 pounds

Frequency of Claims: How common are trade secret claims in Louisiana?

Across all valid Louisiana chemical records, 16.9% are marked as trade secrets. Trade secret claims appear in 85.5 % of all disclosures.

And the breakdown of the frequency of trade secrets within Louisiana disclosures is: 

Compared to Other States: How does the trade secret use in Louisiana compare to other fracking states?

Louisiana ranks number six for frequency of trade secret disclosures among the major fracking states.

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Examples of Trade Secret Use in Louisiana

We summarize 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 GEP HAYNESVILLE, LLC in Red River County. (Click on images to open map and disclosure.)

In this disclosure, 54% of ingredients are listed as trade secrets. The list of trade secrets for that fracking job are:

TradeName	IngredientName	CASNumber	mass (pounds)
Ingredient Container	sand	Proprietary	29,000,000
Ingredient Container	copolymer of acrylamide and sodium acrylate	Proprietary	119,000
Ingredient Container	inorganic salt 1	Proprietary	32,500
Ingredient Container	proprietary	Proprietary	17,300
Ingredient Container	inorganic salt 2	Proprietary	5,420
Ingredient Container	biopolymer	Proprietary	3,230

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. In Louisiana, many disclosures mask the identity of the proppant. More than 30 disclosures report more than 20 million pounds each in such cases.

Example: Consider the well operated by Southwestern Energy in Natchitoches County.

In this well, a single trade secret entry is reported with a mass of 2,610,000 pounds, representing a significant portion of the total fluid volume. This is not a proppant but the chemical identity of this large-mass material is withheld.

Louisiana has 683 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 GEP HAYNESVILLE, LLC in Sabine County.

The disclosure for that well utilizes a systems approach format but still conceals the identity of 7 chemicals, which means 58% of ingredients are listed as trade secrets. The table below lists those records with their quantity.

IngredientName	CASNumber	mass (pounds)
sand	proprietary	24,300,000
copolymer of acrylamide and sodium acrylate	proprietary	84,500
inorganic salt	proprietary	26,900
proprietary	proprietary	13,700
biopolymer	proprietary	2,310
copolymer of acrylamide and sodium acrylate	proprietary	92
isoparaffinic solvent	proprietary	61

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 Louisiana’s trade secrets that are also reported without informative values for “Purpose”.

IngredientName	count
proprietary	529
no hazardous ingredients	150
non-hazardous ingredients	94
proprietary ingredient	93
other components below reportable levels	76
trade secret	45
undisclosed	27
contains no hazardous substances in concentrations above cut-off values according to the competent authority	21
non-hazardous	15
proprietary component	10
proprietary blend	10
3rd party proprietary	6

Implications for Louisiana

The patterns and examples of trade secret usage in Louisiana’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.

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Title image credit: Becky Mansfield (modified by author)

1. Map images ©OpenStreetMap; Disclosure tables screenshot from FracFocus PDFs. ↩︎