Operators being held accountable, or business as usual?
BACKGROUND: As you know, we have helped publicize the shocking report that our friends at PSR Colorado, Sierra Club, and FracTracker Alliance released two months ago. They showed that most oil and gas companies in Colorado had been illegally ignoring rules adopted in 2022, which required chemical disclosures for all “downhole operations” conducted on or after July 31, 2023. The state regulators at the ECMC have not explained their lack of enforcement, nor have they issued any notices of alleged violation (NOAVs), levied fines, or revoked any oil company’s license to operate in Colorado.
THE LATEST: In the two months since the PSR report, most of the companies that were previously in violation of the rules have started submitting the required chemical disclosures, albeit late (see the chart above provided by our colleagues at EcoCarto). We’re finally getting a better understanding of the chemicals used in hydraulic fracturing that were previously withheld as “trade secret.” In fact, we’ve found 32 of them.
As of July 27, 2025, the ECMC Chemical Disclosures data contain 4,986 chemical entries for 169 locations and 180 distinct chemical CAS Numbers. These are the 32 chemicals that have never before been disclosed to FracFocus for any Colorado frac job, according to their CAS Number, as well as their general purpose in oil & gas extraction.
| CAS Number | Chemical Name | Purpose | Disclosures |
|---|---|---|---|
| 64366-70-7 | Alkyl Oxirane Polymer | Surfactant | 55 |
| 65322-65-8 | 1-(1-Naphthylmethyl)Quinolinium Chloride | Clay Stabilizer | 26 |
| 5392-40-5 | Citral | Fragrance | 19 |
| 75-75-2 | Methanesulfonic Acid | pH Adjuster | 19 |
| 7681-11-0 | Potassium Iodide | Tracer | 19 |
| 7440-09-7 | Potassium | Clay Stabilizer | 12 |
| 7440-70-2 | Calcium | Crosslinker | 12 |
| 68037-05-8 | Alkyl Ether Sulfate | Surfactant | 11 |
| 1338-39-2 | Sorbitan Monolaurate | Emulsifier | 9 |
| 1340-69-8 | Quaternium 18-Bentonite | Thickener | 9 |
| 2425-54-9 | 1-Chlorotetradecane | Corrosion Inhibitor | 9 |
| 814-29-9 | TributyLPhosphine Oxide | Foaming Agent | 9 |
| 9082-00-2 | Thylene Oxide-Propylene Oxide Copolymer Glycerol Ether | Defoamer | 7 |
| 68649-44-5 | Amino Methylene Phosphonic Acid Salt | Scale Inhibitor | 5 |
| 9065-11-6 | Acrylic Polymer Dispersion | Friction Reducer | 5 |
| 134959-78-7 | 2-Propenoic Acid, Polymer With 2-Propenamide And Sodium 2-Methyl-2-[(1-Oxo-2-Propen-1-Yl)Amino]-1-Propanesulfonate (1:1) | Friction Reducer | 3 |
| 227310-69-2 | Poly(Oxy-1,2-Ethanediyl), .ALPha.-(Carboxymethyl)-.Omega.-Hydroxy-, C16-18 And C18-Unsatd. Alkyl Ethers | Surfactant | 3 |
| 24634-61-5 | Potassium Sorbate | Preservative | 3 |
| 532-32-1 | Sodium Benzoate | Preservative | 3 |
| 68920-66-1 | Alcohols, C16-18 And C18-Unsaturated, Ethoxylated | Surfactant | 3 |
| 9004-54-0 | Dextran | Fluid Loss | 3 |
| 9004-98-2 | Poly(Oxy-1,2-Ethanediyl), .ALPha.-(9Z)-9-Octadecen-1-Yl-.Omega.-Hydroxy | Surfactant | 3 |
| 110224-99-2 | Phosphinocarboxylic Acid | Scale Inhibitor | 2 |
| 5995-42-6 | Hydroxyethylamino-Di (Methylene Phosphonic Acid) | Scale Inhibitor | 2 |
| 129813-58-7 | Benzene, Mono-C10-13-Alkyl Derivs | Solvent | 1 |
| 17354-14-2 | Solvent Blue 35 | Colorant | 1 |
| 595585-15-2 | D-Glucurono-D-Gluco-6-Deoxy-L-Mannan, Acetate, Calcium Magnesium Potassium Sodium Salt | Thickener | 1 |
| 64741-85-1 | Raffinates (Petroleum), Sorption Process | Base Fluid | 1 |
| 68171-44-8 | Formaldehyde, Polymer With 4-(1,1-Dimethylethyl)Phenol, 4-NonyLPhosphinocarboxylic Acid | Emulsifier | 1 |
| 70714-66-8 | [[(Phosphonomethyl)Imino]Bis[Ethylenenitrilobis(Methylene)]]Tetrakisphosphonic Acid, Ammonium Salt | Scale Inhibitor | 1 |
| 7632-05-5 | Phosphoric Acid, Sodium Salt | pH Adjuster | 1 |
| 9002-85-1 | Polyvinylidene Chloride | Film Former | 1 |
WHAT DOES IT MEAN? And why have these chemicals never been disclosed before in FracFocus by operators for their Colorado frac jobs? Presumably, it’s because they comprise proprietary or trade secret formulas (for example, methanesulfonic acid is a newer ingredient used in acid fracturing as a substitute for hydrochloric acid). It’s possible these chemicals are more commonly disclosed in other states.
WHAT IS NEXT? Now awakened to the situation, the state regulators at ECMC can do their job and assess whether these potentially toxic “secret” chemicals are safe. We have a right to know if these chemicals are nominally “safe” because of extreme accidents like last April’s explosion in Galeton, Colorado spread clouds of fracking chemicals high into the air and contaminated homes, livestock, and agricultural land for miles around, as well as the hundreds of smaller reported spills across Weld County.
While they’re at it, ECMC must also ensure that all oil and gas companies are fully disclosing all of the chemicals they use at all of their wells. In fact, we learned a couple days ago that ECMC sent warning letters to companies still in violation of the 2022 law – a classic example of “too little, too late.” Instead of sending these toothless reminder letters, ECMC should have imposed harsh retroactive penalties for the years of non-compliance that have already occurred, and charged additional daily fines for each day that companies remain out of compliance.
This whole debacle demonstrates that ECMC must improve its regulatory oversight in the future so that Coloradans don’t have to depend on citizen-led investigations and grassroots organizations to expose the blatantly illegal actions of multinational oil and gas corporations.
