Methodology & trust

How a kilogram earns its place in your report

This page explains the machinery behind the promises on the overview page: how every reported number gets its lineage, what we deliberately never do, how customer data is handled, and who reviews what. No hype - just the chain every value has to survive.

Provenance: field → source document → approver → tamper-evident version → correction chain

Every value in the workpaper - a component weight, a units figure, a state/material kilogram - travels the same five-stage chain. A number that has not completed the chain is visibly an estimate or a gap; it cannot silently become part of the record.

1
Field. Each data point is a named field on a versioned workpaper - a jar weight, a state units figure, a plastic component count - never a loose spreadsheet cell. Every kilogram is computed as units × component weights, so each output cell has named inputs.
2
Source document. A field cannot be approved without a source document, and the link records the exact reference - document, page or cell, and timestamp. The source inventory carries document hashes; supplier outreach evidence is filed alongside. Divergent sources block approval until a human resolves them with a recorded rationale.
3
Approver. A named person approves each field and each completed version. Internal review and your data approval are separate recorded events - so "who checked this, and when" always has an answer. Estimates are flagged as estimates until replaced with actuals.
4
Sealed version. Once a workpaper version is signed off, it is sealed - hash-verified and write-blocked (tamper-evident). The numbers behind the report you submitted stay exactly as approved. Export is not submission: you submit in the portal, and your receipt/status is recorded as an external event - the evidence that closes the loop.
5
Correction chain. When an estimate is replaced with an actual, a supplier corrects a weight, or an allocation input changes, a new linked version is created with a recorded reason. The old version is preserved and the audit trail is append-only - which is exactly what a CAA validation request wants to see.

Why immutability matters: a validation request asks how a number was built at the time you reported it. A workpaper that can quietly rewrite itself cannot answer that question - a correction chain can.

What we deliberately do not do

We do not log into or automate CAA/state portals, do not determine producer status or exemptions (those are recorded decisions by you and your reviewer/counsel), do not quote or optimize fees (fee figures in our workpapers are labeled illustrative planning math; CAA invoices under approved rate schedules), and do not cover all states - we go deep on OR/CO/CA and track MN/MD/WA/ME deadlines only.

This is the same boundary stated on the overview page, verbatim, because it does not change with the audience: producer status, exemptions, and submission are decisions and actions that belong to you, your reviewer, and your counsel. We record those decisions; we never make them.

How customer data is handled

No consumer-AI processing

No customer data enters consumer AI tools. If any model-assisted processing is used, it happens only under commercial no-training terms - or not at all, at your election, recorded in the engagement terms.

Controls before any real data

Before any customer document enters the workspace, a binding checklist applies: contracts (NDA/DPA), written customer data authorization, a named reviewer with recorded scope, an approved commercial no-training AI path (or none), an isolated workspace, MFA, least-privilege access, encryption, access and audit records, malware scanning on upload, and backup/recovery.

Retention with a purpose

The reviewed workpaper, substantiation pack, source inventory (with hashes), and full version history are retained for the engagement's agreed retention period so a CAA validation request is a same-week answer - and everything is exportable to you on demand.

Deletion, honestly stated

At the end of an engagement, data is exported to you and deleted on request under the agreed retention/deletion procedure. One honest caveat: an active retention obligation or legal hold blocks deletion until it lapses - and that block is itself recorded, not silent.

The review model: recorded decisions, attributed people

Software surfaces problems; it never decides them. Every material decision passes through a person whose role and reasoning are on the record — and we state plainly who that person is for each engagement, rather than implying a bench that has not been contracted.

ElementHow it works
Who reviewsScan and close workpapers are reviewed against our documented internal QA checklist by the engagement lead before delivery. Where an engagement's statement of work includes qualified professional review, a named, contracted reviewer is assigned before we accept the project - the software records their qualification and scope. No qualified reviewer is presumed: self-serve workspaces run policy-sampled review and disclose exactly that.
Recorded decisionsWho decided, what they decided, the basis, and the date - captured for every resolution, approval, and correction, in an append-only audit log.
Separation of eventsInternal review and your data approval are separate recorded events on every workpaper version - two signatures, two timestamps, never merged.
Blocking checksA field with no source document, or with unresolved divergence between sources, cannot be approved. The remediation queue is worked to zero, every resolution attributed to a named owner; nothing is waved through.
Your decisions stay yoursProducer status, exemptions, and what to submit are decisions you make with your reviewer or counsel. We record the decision, its basis, and its date - we never compute it.

Trust & security: the honest current state

What is shipped and continuously tested today, what is planned, and the language we refuse to inflate. Ask for the procurement pack to get all of it in writing.

ControlStatus
Workspace isolation with cross-tenant attack tests; named accounts; MFA; salted PBKDF2 (600k) passwords; server-side session revocationShipped & tested
SHA-256 hashing on every document; field-level provenance with structured citation fragments; malware scanning that fails closed; encryption at rest for stored objectsShipped & tested
Sealed, hash-verified completed versions (tamper-evident) with an append-only audit trail enforced at the database layerShipped & tested
Deterministic human-judgment gates: no approval without a source, contradictions block, exports never advance regulatory state, no legal conclusions from softwareShipped & tested
Storage-level WORM retention lock (until it lands we say "tamper-evident", never "immutable")Planned
E&O / cyber insurance (bound at first paid engagements, before any regulated-data work that requires it; current status stated in writing on request)Planned
SOC 2 (control baseline targets OWASP ASVS L2 / NIST SSDF now; certification when buyer demand justifies it)Planned

Service commitments are process commitments: intake acknowledgment in one business day, critical missing-data notice in two, any frozen workpaper and its evidence packet retrievable in 24 hours. We never guarantee a regulatory outcome, agency acceptance, or supplier behavior.

Frequently asked questions

Which dates does this work revolve around?

The CY2025 reporting deadlines are behind us: Oregon, Colorado, and California annual supply reports, California's baseline producer report (CY2023 data), and the MN/MD/WA interim reports were due May 31, 2026, and California's individual source-reduction plan date (August 1, 2026) has also passed. What is live now is what follows a filing: CAA currently expects California early-fee invoices in August 2026, based on CY2025 supply data; validation, Adjustment, and Correction windows are open on filed reports (Reporting Policy V2, §§3.10–3.12); and the next annual cycle is building. Fee payments began July 1, 2025 in Oregon and January 2026 in Colorado. Dates per the Circular Action Alliance producer resource center (circularactionalliance.org), retrieved 2026-08-15 - regulatory state drifts, so verify against the official source before relying on any date here.

Do you submit our reports in the portal?

No. You submit in the portal; we prepare the portal-entry workpaper and record your receipt/status as evidence. We never claim remediation cures noncompliance - we make the remediation defensible.

Who decides producer status and exemptions?

You, with your reviewer or counsel. We record the decision, its basis, and its date - we never compute it. The same goes for any question that determines whether and what you must report.

Do you calculate or optimize our fees?

No. Any fee figures in our workpapers are labeled illustrative planning math. Invoicing happens through CAA under approved rate schedules - we do not quote, compute, or optimize fees.

Which states do you cover?

We go deep on Oregon, Colorado, and California, and track MN/MD/WA/ME deadlines only. If your obligations sit mostly outside that footprint, we will say so on the first call - a large purchase would be irrational, and we'll tell you that for free.

Can numbers change after sign-off?

Not silently. Completed workpaper versions are sealed and tamper-evident; corrections create linked versions with recorded reasons. Estimates are flagged as estimates, then replaced with actuals through a recorded correction - so every kilogram stays traceable to units × component weight and its source document.

Is my data used to train AI models?

No customer data enters consumer AI tools. Model-assisted processing happens only under commercial no-training terms - or not at all, at your election.

What does the free exposure scanner do with what I enter?

Nothing leaves your browser. The 2-minute EPR Status & Exposure Scanner runs entirely client-side - nothing is uploaded, nothing to install, and closing the tab discards everything, including any packaging BOM you paste.

Exposure views and any fee-adjacent figures are illustrative planning math, never a quote. Verify every date and obligation against the official state and CAA sources before relying on it.