united states Office of Enforcement and Compliance Assurance (2201 A)
ASenSymenta' Pro1ection EPA 300-B-15-004 December 2015
eDisclosure User's Guide
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
Prepared with assistance from
CGI Federal
NOTICE
This guide does not necessarily represent final EPA decisions or positions. It is intended to illustrate
how EPA's eDisclosure system operates. EPA reserves the right to revise the system's operational
features. This guide does not supersede any statutory or regulatory requirements, is subject to change,
and is not independently binding on either EPA or covered entities. Additionally, if a conflict exists
between this guide and the statutory or regulatory requirements, or the eDisclosure system, the conflict
must be resolved in favor of the statute or regulation.
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EPA eDisclosure User's Guide
Table of Contents
1. I ntroduction 8
1.1. Creating a New CDX Account 9
1.2. Adding a New Role 23
2. eDisclosure Landing Page 34
2.1. Violation Disclosure Tab 35
2.2. Disclosure Search Tab 37
3. Disclosing New Violations 39
3.1. Note to Submitters and POC Information 41
3.2. Section 1: Voluntary Disclosure 43
3.3. Section 2: Add Violation 45
3.4. Section 3: Submit Disclosure 51
4. Requesting Correction Extensions 55
4.1. Correction Extensions for Audit Policy Disclosures 55
4.2. Correction Extensions for Small Business Compliance Policy Disclosures 59
5. Previously Disclosed EPCRA Violations 61
5.1. Note to Submitters and POC Information 63
5.2. Section 1: Voluntary Disclosure 64
5.3. Section 2: Add Violation 66
5.4. Section 3: Submit Disclosure 68
5.5. Section 4: Attachments 70
6. Add Violations 72
7. Withdraw Violations 74
8. Compliance Certification Forms 76
8.1. Audit Policy-EPCRA Compliance Certification Form 78
8.2. Audit Policy Non-EPCRA Compliance Certification Form 89
8.3. Small Business Compliance Policy-EPCRA Compliance Certification Form 97
8.4. Small Business Compliance Policy Non-EPCRA Compliance Certification Form 107
8.5. Compliance Certification Tab 114
9. System Determinations 122
9.1. Ineligibility Due to Untimely Violation Disclosure 122
9.2. Not Eligible for Category 1 or Category 2 122
9.3. Ineligible Due to Timeout of a Compliance Certification Form 123
9.4. Electronic Notice of Determination (eNOD) 123
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9.5. Acknowledgement Letter 124
10. Sharing Violation Disclosures 126
List of Figures
Figure 1-1 CDX Home Page 9
Figure 1 -2 CDX Terms and Conditions Page 10
Figure 1-3 Select Program Service 11
Figure 1-4 Select Role 12
Figure 1-5 User Information 13
Figure 1-6 Organization Information 14
Figure 1-7 Organization Information-Email and Phone Number 14
Figure 1 -8 CDX Confirmation 15
Figure 1-9 Email Confirmation 15
Figure 1-10 Account Confirmation Log In 16
Figure 1-11 CDX Registration: Additional Verification 17
Figure 1-12 LexisNexis Identity Verification 18
Figure 1-13 Challenge Questions 19
Figure 1-14 Electronic Signature Agreement Page 20
Figure 1-15 Certification Statement 21
Figure 1-16 Signature Ceremony 22
Figure 1-17 MyCDX Page 23
Figure 1-18 MyCDX Page-Add Program Service 23
Figure 1-19 Add Program Service List 24
Figure 1-20 Select Role 25
Figure 1-21 Select an Organization 26
Figure 1-22 CDX Registration: Additional Verification 27
Figure 1-23 LexisNexis Identity Verification 28
Figure 1 -24 Challenge Questions 29
Figure 1 -25 Electronic Signature Agreement Page 30
Figure 1 -26 Certification Statement 31
Figure 1 -27 Signature Ceremony 32
Figure 1-28 MyCDX Page 33
Figure 2-1 Warning Notice and User Agreement 34
Figure 2-2 Violation Disclosure Landing Page 35
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Figure 2-3 Expand All 36
Figure 2-4 Details Page 36
Figure 2-5 Disclosure Search 37
Figure 2-6 Violation Search Results 38
Figure 3-1 Disclose New Violations 39
Figure 3-2 Disclose New Violations 40
Figure 3-3 Note to Submitters and POC Information 42
Figure 3-4 Section 1: Voluntary Disclosure 44
Figure 3-5 Section 2: Add Violation 45
Figure 3-6 Select Violations table 47
Figure 3-7 Facilities Management 48
Figure 3-8 Add Facilities 49
Figure 3-9 Save Selected Facilities 49
Figure 3-10 Facility Details 50
Figure 3-11 Manage Facilities Tab 51
Figure 3-12 Section 3: Submit Disclosure 51
Figure 4-1 Request Correction Extension Hyperlink 56
Figure 4-2 Request Correction Extension Page 58
Figure 4-3 Request Correction Extension Hyperlink 60
Figure 5-1 Disclose Previously Disclosed EPCRA Violations 61
Figure 5-2 Disclose Previously Disclosed EPCRA Violations 62
Figure 5-3 Note to Submitters and POC Information 63
Figure 5-4 Section 1: Voluntary Disclosure 65
Figure 5-5 Section 2: Add Violation 66
Figure 5-6 Select Violations table 67
Figure 5-12 Section 3: Submit Disclosure 68
Figure 5-13 Section 4: Add Attachments 71
Figure 6-1 Add Violation Page 73
Figure 7-1 Withdraw Violations 74
Figure 7-2 Withdraw Violations Confirmation Message 74
Figure 7-3 Withdraw: No Violation Status 75
Figure 8-1 Go to Compliance Certification Page Hyperlink 77
Figure 8-2 General Information 79
Figure 8-3 Specific Noncompliance I nformation 79
Figure 8-4 Add Violation Fields 81
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Figure 8-5 Add Chemical 82
Figure 8-6 Section 1. Chemical Name Look-up tool 82
Figure 8-7 Mixture Sections 84
Figure 8-8 III. Audit Policy Conditions 85
Figure 8-9 Save and Submit buttons 85
Figure 8-10 Compliance Certification Warning Message 85
Figure 8-11 Read Only Compliance Certification Form 86
Figure 8-12 Certification Section 87
Figure 8-13 eSignature Widget 87
Figure 8-14 Certification Confirmation 88
Figure 8-15 General Information 90
Figure 8-16 Specific Non-Compliance Information 91
Figure 8-17 Add Chemical 92
Figure 8-18 Chemical Name Look-up tool 92
Figure 8-19 Audit Policy Conditions 93
Figure 8-20 Save and Submit buttons 93
Figure 8-21 Compliance Certification Warning Message 93
Figure 8-22 Read Only Compliance Certification Form 94
Figure 8-23 Certification Section 95
Figure 8-24 eSignature Widget 95
Figure 8-25 Certification Confirmation 96
Figure 8-26 General I nformation 98
Figure 8-27 II. Specific Noncompliance Information 99
Figure 8-28 Add Violation Fields 100
Figure 8-29 Add Chemical 101
Figure 8-30 Section 1. Chemical 101
Figure 8-31 Mixture Sections 103
Figure 8-32 Small Business Compliance Policy Conditions 104
Figure 8-33 Save and Submit buttons 104
Figure 8-34 Compliance Certification Warning Message 104
Figure 8-35 Read Only Compliance Certification Form 105
Figure 8-36 Certification Section 105
Figure 8-37 eSignature Widget 106
Figure 8-38 Certification Confirmation 106
Figure 8-39 General I nformation 108
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Figure 8-40 II. Specific Non-Compliance Information 109
Figure 8-41 Add Chemical 110
Figure 8-42 Chemical Name Look-up tool 110
Figure 8-43 III. Audit Policy Conditions 111
Figure 8-44 Save and Submit buttons 111
Figure 8-45 Compliance Certification Warning Message 111
Figure 8-46 Read Only Compliance Certification Form 112
Figure 8-47 Certification Section 112
Figure 8-48 eSignature Widget 113
Figure 8-49 Certification Confirmation 113
Figure 8-50 Compliance Certification Tab 114
Figure 8-51 Compliance Certification Forms Ready for Review and Submittal 115
Figure 8-52 Review and Certify Compliance 116
Figure 8-53 Certifying Multiple Compliance Certification Forms 116
Figure 8-54 Review Screen for Batch Certification 117
Figure 8-55 Section IV. Certification 118
Figure 8-56 eSignature Widget 118
Figure 8-57 Certification Confirmation 119
Figure 8-58 Compliance Certification Forms that Need to be Finished 120
Figure 8-59 Compliance Certification Form 121
Figure 9-1 Ineligibility Letter 123
Figure 9-2 Notice of Determination 124
Figure 9-3 Acknowledgement Letter 125
Figure 10-1 Sharing Tab 126
Figure 10-2 List Pop-up 127
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1. Introduction
This document is a User's Guide for the eDisclosure Voluntary Disclosure system developed
within EPA's Central Data Exchange (CDX). eDisclosure provides a new streamlined approach
to more efficiently processing disclosed violations submitted to the Agency under the Audit
Policy and Small Business Compliance Policy.
EPA believes strongly in the benefits of the Audit Policy and the Small Business Compliance
Policy: to encourage companies to self-police, disclose, correct and prevent violations. These
benefits can be achieved in a manner that saves transaction costs, increases efficiency, and
provides quicker decisions. In response to suggestions from regulated entities, EPA has decided
to modernize implementation of self-disclosure policies by creating a centralized web-based
"eDisclosure" portal to process self-disclosed violations.
Each disclosure will be processed through the eDisclosure portal as either a "Category 1" or a
"Category 2" disclosure.
Category 1 Disclosures include EPCRA violations that meet all Audit Policy or Small Business
Compliance Policy conditions, but do not include: (1) CERCLA 103/EPCRA 304 chemical
release reporting violations; or (2) EPCRA violations with significant economic benefit as
defined by EPA.
For disclosures that qualify as Category 1, the eDisclosure system will automatically issue an
electronic Notice of Determination (eNOD) confirming that the violations are resolved with no
assessment of civil penalties, conditioned on the accuracy and completeness of the submitter's
certified eDisclosure.
Category 2 Disclosures include: (1) all non-EPCRA violations; (2) EPCRA violations where the
violator can only certify compliance with Audit Policy Conditions 2-9 (i.e., discovery was not
systematic), and (3) EPCRA/CERCLA violations excluded from Category 1.
For disclosures that qualify as Category 2, the eDisclosure system will automatically issue an
electronic Acknowledgement Letter (AL) confirming EPA's receipt of the disclosure, and
promising that EPA will make a determination as to eligibility for penalty mitigation if and when
it considers taking an enforcement action for environmental violations.
This document provides a guide on how to use the system for the following actions:
1. Disclose Violations
2. Disclose Previously Disclosed EPCRA Violations
3. Request Extensions
4. Certify Compliance
5. Share Access to Disclosures
NOTE: The screen shots provided in this document contain the names of facilities used during
the development and testing of the eDisclosure portal. Inclusion of such facility- and company-
specific data is for illustrative purposes only, and is not intended to represent or imply that any
such entities had or have actual violations of the law
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1.1. Creating a New CDX Account
The eDisclosure application is accessible via EPA's CDX application. First time users will need
to create a new account and register for eDisclosure.
When creating a new CDX account you will:
• Select a Program Service and associated role
• Establish a user name and password
• Set security questions
• Select an organization
• Provide contact information.
CDX is accessible at https://cdx.epa.gov . This will take you to the Central Data Exchange home
page. Click on the "Register with CDX" button to start creating a new account as shown in
Figure 1-1.
You can also use the following URL:
https://cdx.epa.gov/RegistrationRequest?Dataflow=eDisclosure. This will route you directly to
the Terms and Conditions page.
Figure 1-1 CDX Home Page
fr Central Data Exchange
Welcome
Welcome to the Environmental Protection Agency (EPA) Central Data Exchange (CDX) - the Agency's electronic reporting site. The
Central Data Exchange concept has been defined as a central point which supplements EPA reporting systems by performing new
and existing functions for receiving legally acceptable data in various formats, including consolidated and integrated data.
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In either case, you will be routed to the CDX Terms and Conditions page. Use the scroll bar to
read the complete terms and conditions. Click on the "I Accept" radio button and the "Proceed"
button when ready (Figure 1-2). You will not be able to proceed with registration until the Terms
and Conditions have been accepted.
Figure 1-2 CDX Terms and Conditions Page
United States Environmental Protection Agency
Recent Announcements
^ Terms and Conditions
Terms and Conditions
The access and use of CDX Registration for the electronic submittal of environmental information require the creation of a
user ID and password that I must maintain and keep confidential. I will review the following steps concerning the creation
and maintenance of a user ID and password.
Warning Notice
In proceeding and accessing U.S. Government information and information systems, you acknowledge that you fully
understand and consent to all of the following:
1. you are accessing U.S. Government information and information systems that are provided for official U.S. Government
purposes only;
2. unauthorized access to or unauthorized use of U.S. Government information or information systems is subject to criminal,
civil, administrative, or other lawful action;
3. the term U.S. Government information system includes systems operated on behalf of the U.S. Government;
4. you have no reasonable expectation of privacy regarding any communications or information used, transmitted, or stored
on U.S. Government information systems;
S at anv timp fhp i I S finvprnmpnt mav fnr anv tawfi il nnvprnmpnf ni irnno^ wifhnnt nntirp monitor intprrpnt oparrh
I Accept
I Decline
On the Program Service selection screen, you will see all available Programs within CDX. You
will need to select eDisclosure. You can scroll through the list and click "eDisclosure: Voluntary
Disclosure System" from the Active Program Services List; or filter the list by typing the
program name in the text box as shown in Figure 1-3.
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Figure 1-3 Select Program Service
>>EPA
Home About Recent Announcements Terms and Conditions Help
CDX, Core CDX Registration
1. Program Service j 2. Role Access ^ 3. User and Organization > 4. Confirmation
Begin typing a program service name or related keywords to filter the list of available services (e.g., air quality system, AQS, or
Clean Air Act).
Active Program Services List
eD
ACRES: Assessment Cleanup and Redevelopment Exchange System
CEDRI: Compliance and Emissions Data Reporting Interface
CROMERRS: CROss-Media Electronic Reporting Rule Services
CSPP: Submissions for Chemical Safety and Pesticide Programs
eDisclosure: Voluntary Disclosure System
LEAD: Lead-Based Paint Program
OTAQEMTS: Office of Transportation and Air Quality EPA Moderated Transaction System
OTAQWaiverCredits: Cellulosic Biotuel Waiver Credits Pay.gov Application
PSP: Pesticide Submission Portal
You will then be prompted to select a role from the dropdown field. Selecting Discloser/Certifier
will display a description of the role duties as shown in Figure 1-4. Click on the "Request Role
Access button" to proceed.
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Figure 1-4 Select Role
&EPA
Home About Recent Announcements Terms and Conditions Help
CDX, Core CDX Registration
1. Program Service >< y 2. Role Access ^ 3. User and Organization > 4. Confirmation
I Con] • . :
Registration Information
Program Service
Role
Voluntary Disclosure System
Not selected
Select a role from the drop down list and provide any required additional information, if applicable.
By clicking Request Role Access, you understand that you intend to disclose to the United States Environmental Protection Agency
(EPA) potential violations of Federal Environmental Laws, regulations, and/or requirements. EPA will assess your disclosure and
provide a notice of determination or acknowledgement letter in accordance with Audit Policy/ Small Business Compliance Policy.
Select Role
Request Role Access
Disdoser/Certifier
On the following screen, you will need to provide your user and organization information. For
the "Part 1: User Information" section you will need to enter a User ID, personal information, a
password, and security questions. Make note of this information, as it will be used to access
eDisclosure. Please see Figure 1-5 to view all required fields. On-screen messages will be
displayed if you do not meet the User ID and password requirements.
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Figure 1-5 User Information
Please fill out all required fields marked with an asterisk(*}
Mr
-Please Select-
Part 1: User Information
The program you are registering for requires additional proof of identity. Later in the registration process you will be given
the option to use LexisNexis, an identity proofing service. LexisNexis will pull your first, middle and last name exactly as it is
entered on this page.
User ID *
Title *
First Name *
Middle Initial
Last Name *
Suffix
Password *
Re-type Password *
Security Question 1 *
Security Answer 1 *
Security Question 2 *
Security Answer 2 *
Security Question 3 *
Security Answer 3 *
-Please Select-
-Please Select-
-Please Select-
In "Part 2: Organization Info", you will need to select an organization. Note that you should
select the organization on whose behalf you are disclosing. The organization may or may not be
the same organization you are employed by (Figure 1-6). Enter the organization name and click
on the "Search" button. A list of organization names will display for you to select from. If you
can't find the organization you are searching for, you will be given the option to submit a request
to add a new organization.
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Figure 1-6 Organization Information
Part 2: Organization Info
Search for your organization using the text box below. You may search by entering the Organization Name or the
Organization ID.
Select the organization you are disclosing a violation on behalf of. The organization may or may not be the same
organization you are employed by (i.e. if you are legal representation).
Once you select the organization it will display on the screen and you will be prompted to enter
an email address and phone number as displayed in Figure 1-7. When ready, click on the
"Submit Request for Access" button.
Figure 1-7 Organization Information-Email and Phone Number
Part 2: Organization Info
ABC SYSTEMS
123 ELM ST
ALEXANDRIA, VA, US
22021
Email *
Re-enter Email *
Phone Number *
Phone Number Ext
Fax Number
Wrong organization information? Back to Search Results, Use advanced search or request that we add your organization.
Submit Request for Access
A confirmation screen will display indicating you will receive an email confirmation message
with additional steps to complete registration. (Figure 1-8).
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Figure 1-8 CDX Confirmation
About Recent Announcements Terms and Conditions Help
Confirmation
1. Program Service <* ^ 2. Role Access *S \/ 3. User and Organization *f } 4. Confirmation
A few more steps...
You will soon receive an email confirmation message (at paulette.elvir@cqifederal.com) asking you to follow a link to activate
your user account. Follow that link to complete your registration. Please contact the help desk if you have any issues at 888-
890-1995 or (970) 494-5500 for International callers.
Confirmation Number cd885923-e34c-4233-8699-de9a<:5f50565
Return to CDX Home
You should receive an email from helpdesk@epacdx.net with Subject line "Core Registration
Email Verification Request". If you do not receive the message, please check your Spam folders.
Click on the hyperlink included in the email to confirm registration (Figure 1-9). You will not be
able to access the eDisclosure application until you click the link in your email and log in
successfully.
Figure 1-9 Email Confirmation
You have successfully crested an account with the EPA Central Data Exchange (CDX).
In order to complete your registration and begin using the system, you will need to confirm your account by clicking the hyperlink below and successfully logging in. You will need to enter the UserlD(TESTABCD) and Password that
were selected during the registration process.
https://dev, epacdx.net/Registration/Em a ilVa lid atbn?code=cd885923-e34c-4233-8699-de9ac5f60565
If you click the link and it appears to be broken, please copy and paste it into a new browser window.
Once you have successfully logged into your account, you may be required to provide additional information. Any additional information will need to be completed before you are able to access your Program Service.
Please do not respond to this message. If you have questions concerning this request, you may contact us by email at helpdesk@epaccix.net or by calling the CDX Technical Support Staff through our toll free telephone support on
388-890-1995 between Monday through Friday from 8:00 am to 6:00 pm EST/EDT. For International callers, the CDX Help Desk can also be reached at (970) 494-5500.
Sincerely
CDX Help Desk
United States Environmental Protection Agency - Central Data Exchange
You will be prompted to enter your User ID and Password as shown in Figure 1-10. When ready
click on the "Log In to CDX" button.
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Figure 1-10 Account Confirmation Log In
Home
About
Recent Announcements
Trains and Conditions
CDX* Central Data Exchange
Log In
User ID
Password
Log Into CDX
TestABCD
Register with CDX | Forgot your Password? | Forgot your User ID? | Help
Upon logging in, the CDX Registration: Additional Verification Screen will display. Due to the
nature of submitted Disclosures which must be certified, you must be identity-proofed before
gaining access to the eDisclosure application in order to meet Cross-Media Electronic Reporting
Rule (CROMERR) requirements.
CDX offers the opportunity to do so electronically by using the third party service, LexisNexis.
If you opt out of this service, you will need to print, sign and mail a paper form by clicking on
the 'sign the paper form hyperlink. Please note that when choosing the paper route you will still
be able to start disclosing a violation, but should only be able to certify compliance until EPA
has received a signed copy of the Paper CDX Electronic Signature Agreement (ESA). The
address where the ESA must be sent to will be displayed on the paper form.
To proceed with LexisNexis verification, click on the checkbox and then the "Proceed to
Verification" button as displayed in Figure 1-11. A pop-up window will display for you to enter
personal information and confirm your identity (Figure 1-12). Once you have completed the
information click on the "Submit" button.
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Figure 1-11 CDX Registration: Additional Verification
Lagged in as TESTABCD (Laaou
Home About Recent Announcements Terms and Conditions FAQ Help
CDX* CDX Registration: Additional Verification
1. Identity Verification ^ 2. Electronic Signature Agreement
The program you are registering for requires additional proof of identity. Your options are to use LexisNexis®, an independent
3rd-Party electronic identity proofing service or to print and submit a signed form through U.S. Postal Mail to the U.S.
Environmental Protection Agency,
Note: By clicking [Proceed to Verification] you understand the service is voluntary and that you are validating personally
identifying information including the last 4 digits of SSN against a 3rd-Party service LexisNexis®, which will return evidence of
validation of your personally identifying information back to the U.S. Environmental Protection Agency. The U.S. EPA will not
collect or retain sensitive, personally identifying information such as your Social Security Number (SSN); however, EPA will
receive evidence of identity validation which may be used to identify you for legal purposes.
You may sign the paper form if you do not want to use the automatic verification process.
Note: You will receive a limited number of attempts to complete identity verification. Please review all personal
information carefully prior to submitting. If you need to modify the personal information listed below, please
contact the CDX Help Desk.
First Name: Paulette
Last Name: Elvir
I have reviewed the name presented above and I would like to proceed with LexisNexis. Additional LexisNexis Identity
Proofing Guidance
Proceed to Verification
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Figure 1-12 LexisNexis Identity Verification
LexisNeXJS" Verification for EPA
* Required Fields
Authorized Representative
Last Name *
First Name '
Middle Name
Elvir
Paulette
SSM (Last 4) T
Home Address
Home City'
Home State'
Home Zip "
- State -
Home Phone
Date of Birth
Copyright © 2015 LexisNexis. All rights Reserved. Terms & Conditions | Privacy 81 Security
Once your identity has been verified via LexisNexis, you will be required to select five challenge
questions and answers. Enter the required information and click on the "Save Answers" button as
displayed in Figure 1-13. Please make note of your answers since they will be used during
electronic signature process of the compliance certification.
If LexisNexis is unable to verify your information, you will be defaulted to the paper route.
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B Contact Us
Lugged in as TESTABCD (Logout)
Figure 1-13 Challenge Questions
Home About Recent Announcements Terms and Conditions FAQ Help
CDX? Central Data Exchange
CDX Registration: Additional Verification
1. Identity Verification^ ^ 2. Electronic Signature Agreement
You are registered for a program that reguires eSignature PIN Verification. Please select five (5) challenge questions and
answers. The questions that you select should be questions that you can remember, but difficult for anyone else to guess.
Select 5 Challenge Questions and Answers
After your 5 Challenge Question and Answers have been saved, you will be directed to the
Electronic CDX Electronic Signature Agreement page, which is an agreement between yourself
and CDX that will authorize your electronic signature. Once the ESA has been signed, you will
be authorized to sign information for eDisclosure. Click the 'Sign Electronically' button in order
to proceed as shown in Figure 1-14.
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Figure 1-14 Electronic Signature Agreement Page
S Contact ils
Logged in as TE5TERDISC1 (Log out)
CDX; CDX Registration: Additional Verification
1. Identity Verification V ^ 2. Etectronic Signature Agreement
Electronic CDX Electronic Signature Agreement
The CDX electronic signature agreement (ESA) is an agreement between yourself and CDX that will authorize your electronic signature. By signing the ESA you agree to
adhere to the conditions listed on the agreement below. Once the ESA has been signed, you will be authorized to sign and/or encrypt information for your data flow. For
any questions regarding the CDX ESA please contact the CDX Help Desk.
U.S. Environmental Protection Agency
ELECTRONIC SIGNATURE AGREEMENT
In accepting the electronic signature credential issued by the U.S. Environmental Protection Agency (EPA) to sign electronic documents
submitted to EPA's Central Data Exchange (CDX). and as a representative for:
Electronic Signature Holder Company Information
Organization Name:
Address:
City. State. Zip:
Province:
Country:
Phone Number:
E-mail Address:
Registrant's Name:
CDX User Name:
ABC
123 MAIN ST
FAIRFAX. VA 22030
US
(703)888-9996
paulette.elvirScgifederal.com
Mrs Paulette Elvir
TESTERDISC1
Skin Electronically
You will then be prompted to accept the electronic signature certification statement (Figure
1-15). After accepting you will be prompted first for your CDX password, and then will be asked
to answer one of your five secret questions (selected in Figure 1-13). Once both have been
provided correctly, you will be able to click the 'Sign' button as shown in Figure 1-16.
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Figure 1-15 Certification Statement
Electronic CDX Electronic Signature Agreement
•
-
I .S. Environmental Protection Agency
ELECTRONIC SIGNA1TRE AGREEMENT
:.iibminei:l TO I' D
I certify, Linder penalty of law that the information
provided in this document is, to the best of my
knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for
submitting false information, including the possibility of
fines and imprisonment for knowing violations.
Electronic ^ignatnrt? Holder C
•
I
.. . ... !
I
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Figure 1-16 Signature Ceremony
CD/C CDX Registration: Additional Verification
Electronic Signature Agreemen
2.Answer Secret Question
Question:
Where did you graduate from high
school?
Answer:
school
of tile cwupii! ;
- - :>atory
- .... , . . _ ' .
• :
. . .: . . : ... , . . •..
• ' : • - ud ^m familini with the inr-
submitie J111 Un -; uficant
At this point, your registration is complete. You will be taken to your MyCDX page where you
will see the eDisclosure Program Service and role. You may now access your Disclose/Certify
role by clicking on the hyperlink on your MyCDX page (Figure 1-17).
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Figure 1-17 MyCDX Page
v>EPA
Home About Recent Announcements Terms and Conditions FAQ Help
CDX. Central Data Exchange
a Contact Us
Logged in asTESTERDISCl I'Log out!
Inbox I My Profile | Submission History
Status T Program Service Name ~ Role
£ eDisclosure: Voluntary Disclosure Disclose/Certify
System
CDX Service Availability
See the status for ail program services
News and Updates
No news/updates.
Add Program Service • Manage Your Program Services
1.2. Adding a New Role
If you have an existing CDX account and have previously registered for other Program Services,
you can add a new role to access eDisclosure.
Log in to your CDX account by entering your User ID and Password on the home page. On your
MyCDX page click on the "Add Program Service" button as shown in Figure 1-18.
Figure 1-18 MyCDX Page-Add Program Service
Inbox | j My Profile [] Submission History
<« Manage
Status * Program Service Name
' Role
IEPB: Exchange Network Grant bxchange Network Grant
Semi-Annual Reporting Forms Semi-Annual Reporting Forms
CDX Service Availability
See the status for all program services
Add Program Service I • Manage Your Program Services
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You will be prompted to select a program service from the list as shown in Figure 1-19. You can
select eDisclosure from the list of program services or type it in the text field.
Figure 1-19 Add Program Service List
United States Environmental Protection Agency
Home About Recent Announcements Terms and Conditions FAQ Help
- Edit Account Profile
Logged in 35 TESTERABC (
1. Program Service
2. Role Access
3. Organization Information
Begin typing a program service name or related keywords to filter the list of available services (e.g., air quality system, AQS, or
Clean Air Act).
Active Program Services List
ACRES: Assessment Cleanup and Redevelopment Exchange System
CEDRI: Compliance and Emissions Data Reporting Interface
CROMERRS: CROss-Media Electronic Reporting Rule Services
CSPP: Submissions for Chemical Safety and Pesticide Programs
eDisclosure: Voluntary Disclosure System
LEAD: Lead-Based Paint Program
OTAQEMTS: Office of Transportation and Air Quality EPA Moderated Transaction System
OTAQWaiverCredits: Cellulosic Biofuel Waiver Credits Pay.gov Application
PSP: Pesticide Submission Portal
In the Role Access screen, select the Disclose/Certify role from the dropdown field and click on
the "Request Role Access" button (Figure 1-20).
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Figure 1-20 Select Role
Home About Recent Announcements Terms and Conditions FAQ Help
CDX. Edit Account Profile
Logged in as TESTERABC (Log out)
1. Program Service •*
Registration Information
Role Access ^ 3. Organization Information
Program Service
Role
Voluntary Disclosure System
Not selected
Select a role from the drop dowti list and provide any required additional information, if applicable.
By clicking Request Role Access, you understand that you intend to disclose to the United States Environmental Protection Agency
(EPA) potential violations of Federal Environmental Laws, regulations, and/or requirements. EPA will assess your disclosure and
provide a notice of determination or acknowledgement letter in accordance with Audit Policy/ Small Business Compliance Policy.
Select Role
Request Role Access
Discloser/Certifler
You will then be asked to select an organization. You can either select a current organization or
request to add a different organization. Select the organization on whose behalf you are
disclosing a violation. The organization may or may not be the same organization you are
employed by. Once you have selected an organization, click on the "Submit Request for Access"
button (Figure 1-21).
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Figure 1-21 Select an Organization
CD& Edit Account Profile
Loosed in as TESTEfWBC flog out!
1. Program Service ^
Registration Information
Role Access ^ ^3. Organization Information
Program Service
Role
Voluntary Disclosure System
Disdoser/Certifier
• Select a Current Organization
Request to Add an Organization
Select an organization from the dropdown list.
Select the orcan'zation you are disc osing a violat'on on behalf of. The organ'zaticin may or may not be the same orcan'zation you
are employed by (i.e. if you are legal representation).
Submit Request far Access
If you have previously done Identity Proofing for the same organization with your CDX account,
you will be routed directly to your MyCDX page and the eDisclosure Program Service and role
will display in your list of services. You will not be able to access the "Disclose/Certify"
hyperlink until EPA eDisclosure Management approves your role. Once approved, you will
receive an email letting you know that your CDX role has been activated by EPA. You will now
have access to your Disclose/Certify role by clicking on the hyperlink on your MyCDX page.
If you have previously done Identity-Proofing for a different organization with your CDX
account, you will be routed directly to the Electronic CDX Electronic Signature Agreement page.
You will need to sign a new ESA for the new organization, and your role will remain in a
'Pending' state until EPA eDisclosure Management approves your role. Once approved you will
receive an email letting you know that your CDX role has been activated by EPA. You will now
have access to your Disclose/Certify role by clicking on the hyperlink on your MyCDX page
If you have not done ID-Proofing for a previous role, the CDX Registration: Additional
Verification Screen will display. On this screen you will have the choice to either sign a paper
form by clicking on the sign the paper form hyperlink; or you may proceed with LexisNexis
identity verification (Figure 1-22). Please note that when choosing the paper route you will still
be able to start disclosing a violation, but should only be able to certify compliance until EPA
has received a signed copy of the Paper CDX Electronic Signature Agreement (ESA). The
address where the ESA must be sent to will be displayed on the paper form.
To proceed with LexisNexis verification, click on the checkbox and then the "Proceed to
Verification" button as displayed in Figure 1-22. A pop-up window will display for you to enter
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personal information and confirm your identity (Figure 1-23). Once you have completed the
information click on the "Submit" button.
Figure 1-22 CDX Registration: Additional Verification
Logged in as TESTABCD (Logout)
Home About Recent Announcements Terms and Conditions FAQ Help
CDX; CDX Registration: Additional Verification
1. Identity Verification y 2. Electronic Signature Agreement
The program you are registering for requires additional proof of identity. Your options are to use LexisNexis®, an independent
3rd-Party electronic identity proofing service or to print and submit a signed form through U.S. Postal Mail to the U.S.
Environmental Protection Agency.
Note: By clicking [Proceed to Verification] you understand the service is voluntary and that you are validating personally
identifying information including the last 4 digits of SSN against a 3rd-Party service LexisNexis®, which will return evidence of
validation of your personally identifying information back to the U.S. Environmental Protection Agency. The U.S. EPA will not
collect or retain sensitive, personally identifying information such as your Social Security Number (SSN); however, EPA will
receive evidence of identity validation which may be used to identify you for legal purposes.
You may sign the paper form if you do not want to use the automatic verification process.
Note: You will receive a limited number of attempts to complete identity verification. Please review all personal
information carefully prior to submitting. If you need to modify the personal information listed below, please
contact the CDX Help Desk.
First Name: Paulette
Last Name: Elvir
I have reviewed the name presented above and I would like to proceed with LexisNexis. Additional LexisNexis Identity
Proofing Guidance
Proceed to Verification
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Figure 1-23 LexisNexis Identity Verification
LexisNeXJS" Verification for EPA
* Required Fields
Authorized Representative
Last Name *
First Name '
Middle Name
Elvir
Paulette
SSM (Last 4) T
Home Address
Home City'
Home State'
Home Zip "
- State -
Home Phone
Date of Birth
Copyright © 2015 LexisNexis. All rights Reserved. Terms & Conditions | Privacy 81 Security
Once your identity has been verified via LexisNexis, you will be required to select five challenge
questions and answers. Enter the required information and click on the "Save Answers" button as
displayed in Figure 1-24. Please make note of your answers since they will be used during
electronic signature process of the compliance certification.
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B Contact Us
Lugged in as TESTABCD (Logout)
Figure 1-24 Challenge Questions
Home About Recent Announcements Terms and Conditions FAQ Help
CDX? Central Data Exchange
CDX Registration: Additional Verification
1. Identity Verification^ ^ 2. Electronic Signature Agreement
You are registered for a program that reguires eSignature PIN Verification. Please select five (5) challenge questions and
answers. The questions that you select should be questions that you can remember, but difficult for anyone else to guess.
Select 5 Challenge Questions and Answers
After your 5 Challenge Questions and Answers have been saved, you will be directed to the
Electronic CDX Electronic Signature Agreement page, which is an agreement between yourself
and CDX that will authorize your electronic signature. Once the ESA has been signed, you will
be authorized to sign information for eDisclosure. Click the 'Sign Electronically' button in order
to proceed as shown in Figure 1-25.
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Figure 1-25 Electronic Signature Agreement Page
S Contact ils
Logged in as TE5TERDISC1
CDX; CDX Registration: Additional Verification
1. Identity Verification V ^ 2. Etectronic Signature Agreement
Electronic CDX Electronic Signature Agreement
The CDX electronic signature agreement (ESA) is an agreement between yourself and CDX that will authorize your electronic signature. By signing the ESA you agree to
adhere to the conditions listed on the agreement below. Once the ESA has been signed, you will be authorized to sign and/or encrypt information for your data flow. For
any questions regarding the CDX ESA please contact the CDX Help Desk.
U.S. Environmental Protection Agency
ELECTRONIC SIGNATURE AGREEMENT
In accepting the electronic signature credential issued by the U.S. Environmental Protection Agency (EPA) to sign electronic documents
submitted to EPA's Central Data Exchange (CDX). and as a representative for:
Electronic Signature Holder Company Information
Organization Name:
Address:
City. State. Zip:
Province:
Country:
Phone Number:
E-mail Address:
Registrant's Name:
CDX User Name:
ABC
123 MAIN ST
FAIRFAX. VA 22030
US
(703)888-9996
paulette.elvirScgifederal.com
Mrs Paulette Elvir
TESTERDISC1
Skin Electronically
You will then be prompted to accept the electronic signature certification statement (Figure
1-26). After accepting, you will be prompted first for your CDX password, and then you will be
asked to answer one of your secret questions. Once both have been provided correctly, you will
be able to click the 'Sign' button as shown in Figure 1-27.
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Figure 1-26 Certification Statement
Electronic CDX Electronic Signature Agreement
•
-
I .S. Environmental Protection Agency
ELECTRONIC SIGNA1TRE AGREEMENT
:.iibminei:l TO I' D
I certify, Linder penalty of law that the information
provided in this document is, to the best of my
knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for
submitting false information, including the possibility of
fines and imprisonment for knowing violations.
Electronic ^ignatnrt? Holder C
•
I
.. . ... !
I
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Figure 1-27 Signature Ceremony
CD/C CDX Registration: Additional Verification
Electronic Signature Agreemen
2.Answer Secret Question
Question:
Where did you graduate from high
school?
Answer:
school
of tile cwupii! ;
- - :>atory
- .... , . . _ ' .
• :
. . .: . . : ... , . . •..
• ' : • - ud ^m familini with the inr-
submitie J111 Un -; uficant
At this point your registration is complete. You will be taken to your MyCDX page where you
will see the eDisclosure Program Service and role. You will now access your Disclose/Certify
role by clicking on the hyperlink on your MyCDX page (Figure 1-28).
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Figure 1-28 MyCDX Page
Recent Announcements Terms and Conditions
CDX. Central Data Exchange
Logged in as TESTERABC Hog out)
Inbox My Profile Submission History ]
flS Manage
Status •* Program Service Name
• Role
eDisclosure: Voluntary Disclosure Disclose/Certify
System
IEPB: Exchange Network Grant Exchange Network Grant
Semi-Annual Reporting Forms Semi-Annual Reporting Forms
CDX Service Availability
See the status for all program services
News and Updates
No news/updates.
Add Program Service H Manage Your Program Services
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2. eDisclosure Landing Page
To access the eDisclosure portal, click on the "Disclose/Certify" hyperlink on your MyCDX
page. You will then be prompted to read a Warning Notice and User Agreement. Please read
carefully and click on the "Proceed" button when ready (Figure 2-1). You will then be routed to
the Violation Disclosure tab.
Figure 2-1 Warning Notice and User Agreement
MyCDX Inbox My Profile
You are here: MyCDX* Warning Notice and User Agreement
WARNING NOTICE AND USER AGREEMENT
In proceeding and accessing this U.S. Government eDisclosure system, you acknowledge that you fully understand
and consent to all of the following:
1. This system allows regulated entities to disclose potential violations of federal environmental laws, regulations,
and requirements, and may result in the issuance of an electronic Notice of Determination (eNOD) or
Acknowledgement Letter (AL) pursuant to EPA's Audit Policy or Small Business Compliance Policy.
2. Any information entered onto this electronic system is voluntarily submitted and automatically becomes part of
an enforcement investigation case file.
3. All information submitted must be truthful under penalty of law, and all such information will be retained by EPA
and potentially could be publicly disclosed in response to requests under the Freedom of Information Act (FOIA)
or for other lawful government purposes.
4. You are not submitting any confidential business information (CBI). EPA will consider any CBI claims to be
waived if such information is uploaded onto this system.
5. You are not submitting other private information the disclosure of which would constitute an unwarranted
invasion of any person's privacy (e.g., social security numbers, birth dates, medical records, personal financial
information, or other private information).
6. If your disclosure requires the submission of such private or confidential business information, you must contact
the eDisclosure Help Desk to arrange for secure transmittal of any necessary and appropriate information.
If you would like to view a short video describing how the eDisclosure system works, please click here.
I Exit
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2.1. Violation Disclosure Tab
The Violation Disclosure tab displays tables for both Open and Closed Violations. Open
violations are those which have not yet reached resolution. Closed violations have completed the
compliance certification and have reached resolution. If this is your first time opening the
application, you will not see any disclosures in these tables. If you also wish to view disclosures
that others have shared with you, please click on the Sharing tab at the top of the page.
Figure 2-2 Violation Disclosure Landing Page
8 Contact Us
Logged in asTESTERABC (Log out)
MyCDX Inbox My Profile
Violation Disclosure
Compliance Certification | [ Disclosure Search 11 Sharing 11 Manage Facilities
You are here: MvCDX» Open and Closed Disclosures
This page is where you can enter information about potential civil (but not criminal) violations of environmental law that you wish
to voluntarily disclose to EPA and to view a listing of your open and closed disclosures. For more information about, or to edit, a
disclosure, click on the Details hyper-link in the Available Actions column.
Disclose New Violations
Disclose Previously Disclosed EPCRA Violations
?-
The Open Disclosures table below shows all of your open disclosures. Once Compliance Certifications are submitted for all
violations in a Disclosure Group, it will no longer display in the Open Disclosures table. To view the details of any such closed
disclosures, please see the Closed Disclosures table below or click here to do a search of your Closed Disclosures. If you also wish
to view disclosures that others have shared with you, please click on the Sharing tab at the top of the page.
Open Disclosures
Disclosure Initiation Date
Available
Actions
12/07/15 In Progress - Disclosure(s) & Compliance Certification(s) Pending
Details
The table below shows all of your closed disclosures.
Closed Disclosures
Collapse all
Disclosure Name
Available
Actions
r*j Disclosures Found
Click on the "Expand All" hyperlink to view more details for the disclosures listed in either
table. This will display information on the facilities, statutes and sections reported for a specific
violation (Figure 2-3).
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Figure 2-3 Expand All
Ciiclc: ,rs Name 1 Disclosure Initiation Date I Status Dions'
• :3[_FEDERAL-115 08/01/2015 In Progress - Discbsure(s> & Compliance Certification(sj Pending Details
V Violation Group 1
T A&B BROWN, INC.
T Clean Water Act (CWA)
311 Oil and Hazardous Substance Lability
T CGI_FEDERAL-125 06/15/2015 Draft-No Disclosures Submitted Details
T Violation Group 1
T A 1 AUTO PARTS
» Clean Air Act (CAA)
112E Asbestos
112C Hazardous Air Pollutants
T Violation Group 2
T ACADIA CRAWFISH CHANGED
» Clean Air Act (CAA)
I12H General Duty/Accidental Release
114 Record keeping, Enspection, Information Request
118 Control of Pollution from Federal Facilities
Clicking on the "Details" hyperlink will take you to the details page for that specific violation
disclosure.
Figure 2-4 Details Page
MyCDX Inbox My Profile I 1 Compliance Certification Disclosure Search Sharing Mar
age Facilities
You are here: MvCDX» Violation Disclosure
Violation Disclosure
NOTE TO SUBMITTERS: Violations must be disclosed within 21 days of discovery. NOTE also that if you are seeking an electronic
Notice of Determination (eNOD), you cannot add provisions to your list of EPCRA violations after the 21-day period has passed.
Those seeking eNODs are strongly encouraged to list all possible EPCRA violations within 21 days and can withdraw any
unnecessary provisions prior to certifying compliance (e.g., where further legal analyses indicates that no such violation of that
provision actually occurred).
For a detailed how-to description of eDisclosure or for questions please visit the eDisclosure Help Desk.
(* Indicates Required Fields)
Organization Point of Contact (POC) Information
First Name: Paulette
Last Name: Elvir
CDX User: PAULETTE.ELVIR
Note that you can always return to the landing page by clicking on the "Violation Disclosure"
tab.
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2.2. Disclosure Search Tab
The Disclosure Search tab will allow the user to enter search criteria to access both open and
closed violations that they have access to, or have been granted access to by another user.
Figure 2-5 Disclosure Search
MyCDX [| Inbox [| My Profile [] Violation Disclosure [| Compliance Certification |
You are here: MvCDX» Disclosure Search
Disclosure Search
| Sharing Manage Facilities
Search
Specify search criteria below. If you do not enter any criteria, all violations will be listed.
Voluntary Disclosure Name
Disclosure Submission Date
Facility Program Id
Facility Registry Id
Facility Name
Disclosure Status
Statute
Statute Section
The search criterion includes the following:
• Voluntary Disclosure Name
• Disclosure Submission Date
• Facility Program ID
• Facility Registry ID
• Facility Name
• Disclosure Status
• Statute
• Statute Section
Click on the "Search" button to view the results. The "Reset" button will reset your selection and
allows you to start a new search.
Search Results will be displayed in a grid as shown in Figure 2-6. Click on the "Details"
hyperlink to view complete information for a specific violation disclosure.
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Figure 2-6 Violation Search Results
MyCDX y Inbox [| My Profile [| Violation Disclosure Compliance Certification
You are here: MvCDX» Disctasure Search Results
Search Results
Expand all | Collapse all | Back
1 1 Disclosure Name Disclosure Initiation Date
CE-127 Test 10/26/2015 10:39:17 AM
Test ABC 10/14/2015 2:21:25 PM
Test CE-158 10/27/2015 2:34:59 PM
U Sharing | Manage Facilities
to search
«? 11
In Progress - Compliance
Certification s) Pending
In Progress - Disdosure(s) &
Compliance Certifkation(s) Details
Pending
In Progress - Compliance
Certification(s) Pending
COX Help Desk: 588-890-1395 | (970) 491-5500 tar callers from Puerto Rico and Guaoi
EPA Home Privacy and Security Notice Accessibility
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3. Disclosing New Violations
To disclose new violations click on the "Disclose New Violations" button located in the top
section of landing page as shown in Figure 3-1.
Figure 3-1 Disclose New Violations
MyCDX Inbox My Profile
Violation Disclosure i
Compliance Certification Disclosure Search Sharing Manage Facilities
You are here: MvCDX» Open and Closed Disclosures
This page is where you can enter information about potential civil (but not criminal) violations of environmental law that you wish
to voluntarily disclose to EPA and to view a listing of your open and closed disclosures. For more information about, or to edit, a
disclosure, click on the Details hyper-link in the Available Actions column.
Disclose New Violations
Disclose Previously Disclosed EPCRA Violations
The Open Disclosures table below shows all of your open disclosures. Once Compliance Certifications are submitted for all
violations in a Disclosure Group, it will no longer display in the Open Disclosures table. To view the details of any such closed
disclosures, please see the Closed Disclosures table below or click here to do a search of your Closed Disclosures. If you also wish
to view disclosures that others have shared with you, please click on the Sharing tab at the top of the page.
Open Disclosures
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EPA eDisclosure User's Guide
The Violation Disclosure page will display as shown in Figure 3-2.
Figure 3-2 Disclose New Violations
M,. , , : ,1
Violation Disclosure
v:nt I rj SUBMIT T£R5 : VWatiom must bed&lowd within Jl itays of dtecov-w ¥. NOTE: filso thiit If you ar* seeking «» etecborilc
JWMte of DetefmtoaOon (*NOO), you cannot add provisions to yout li^ or EPCRA vtobrttere aft* ii« tPCRA viriLiUkwr* VH'hm Jl ttty. BIKJ : .in svlllnji.iw ,i«v
-.ji ii M-. i-v-.ii y i.i n vKjim* |)fu>r lofMtiryiogttimpllanc* (<>.g., wfntv ImtluN l-.^iul iuwil^t lrnlic,«v% lt»ui iki
foe a detailed liow -to ilescrlgtlon of eblsctosuie 01 for questKxis p
< ' li vfc.
Uruani/auon Fomt ol Conlacl (POC) Inlormalian
Tlrvl Kdinr: PMiMte
Hvii
PAUl£TTt.tLVIH
CGI FEDERA1
CGI FEDERAL
pautette^h* ^ctfhderaLct
Vi.enni ,M y i us, I.,M n<- Name:
e Statits:
Inlttiittaii Date:
c Pull* y:
2 Add Violation
Violation Dlstovery D,....„
IB KAMEHWEMA fc-IC-hV* i
MBMMKtWC
lUMMRXni Rtl-TSW) ^!SSfrWflttiV*!"
1 UIOMMSM» «HX«5«H' AWUrn KIUKI «HO TkCMNCHOCV
M-Ki;'«t*UHC-, MmnMj «c
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1.KTBBMA "Biu.v-Cwf.wt.-Fj Art
SOW* Sa(» DfiMam iVMn Art
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Listed btknv M, Die unw dluiovmy «•(>'•' vmlatiOiiv tlial •/••*""•' .iriilli^j. M »'-- .nJilwl vkriattan* IJoVd a
y date OiM it dHTnvnl tjisn Wur di«ta«^ Usi«i Wnw. yuu tnu$t «*J Bw vlolsittafW. in * rww DrVlWajiw Giot*> b
ish to ad
to tin-
[OMHF4H 1sa*tv.»H
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The Violation Disclosure screen includes several sections as follows:
1. Note to Submitters
2. Organization Point of Contact (POC) Information
3. Section 1: Voluntary Disclosure
4. Section 2: Add Violation
5. Section 3: Submit Disclosure
^SJJ^oteJo^Submitt^
The top section of the Violation Disclosure screen includes a note to submitters reminding them
that violations must be disclosed within 21 days of discovery in order to qualify for penalty
mitigation. A "Help Desk" link is available in case you need more information or have specific
questions on eDisclosure.
The Organization Point of Contact (POC) section includes information you entered during the
registration process as shown in Figure 3-3. This information is read-only and includes the
following fields:
1. First Name
2. Last Name
3. CDXUserlD
4. Organization: Remember this organization is the one you are disclosing on behalf of. The
organization may or may not be the same organization you are employed by.
5. Email Address
6. Phone Number
Note: If users need to make updates to their first name last name email, they will need to contact
the helpdesk.
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Figure 3-3 Note to Submitters and POC Information
MyCDX
Inbox
My Profile
Compliance Certification Disclosure Search Sharing Manage Facilities
You are here: MyCDX» Violation Disclosure
Violation Disclosure
NOTE TO SUBMITTERS: Violations must be disclosed within 21 days of discovery. NOTE also that if you are seeking an electronic
Notice of Determination (eNOD), you cannot add provisions to your list of EPCRA violations after the 21-day period has passed.
Those seeking eNODs are strongly encouraged to list all possible EPCRA violations within 21 days and can withdraw any
unnecessary provisions prior to certifying compliance (e.g., where further legal analyses indicates that no such violation of that
provision actually occurred).
For a detailed how-to description of eDisclosure or for questions please visit the eDisdosure Help Desk.
(* Indicates Required Fields)
Organization Point of Contact (POC) Information
First Name: Paulette
Last Name: Elvir
CDX User: PAULETTE.ELVIR
Organization: CGI FEDERAL
Email Address: paulette.elvir@cgifedeial.com
Phone Number: (703) 227-6281
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3.2. Section 1: Voluntary Disclosure
Section 1 captures general information on the violation disclosure as show in Figure 3-4. It
includes the following fields:
1. Voluntary Disclosure Name: This is a text field where the user will enter a name for the
corresponding violation disclosure. To allow users to easily retrieve the disclosure in the
future, disclosers must assign a unique name to identify the disclosure and distinguish it
from other disclosures made on behalf of the same entity. For example, disclosers may
wish to include the name of the entity, facility, and/or legal requirements at issue (e.g.,
ABC Company-Smalltown Refinery-EPCRA 313).
2. Disclosure Status: This is a system generated status for the potential violation(s) the user
has entered into eDisclosure. Only one of the following four status options will display:
a. Unsaved Draft: displays when a user initiates a disclosure and has not saved any
violations.
b. Draft-No Disclosure(s) Submitted: violation(s) are in draft and have not been
submitted by the user.
c In Progress - Disclosure(s) and Compliance Certification(s) Pending: the user
has disclosure(s) that have not been submitted, as well as disclosure(s) that have
been submitted and have Compliance Certification(s) pending.
d. In Progress - Compliance Certification(s) Pending: all disclosures have been
submitted and have Compliance Certification(s) pending for one or more of the
submitted disclosures.
3. Disclosure Initiation Date: This is a system generated date corresponding to when the
user first began to input data into eDisclosure information about potential violations.
4. Disclosure Policy: A discloser of potential violation must select the incentive policy
under which it seeks penalty mitigation. The field has a dropdown with the following two
options:
a. Audit Policy
b. Small Business Compliance Policy
Note that each field has a "?" symbol that includes help text that provides information on the
corresponding fields. Click on the "?" symbol to view the help text (Figure 3-4).
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Figure 3-4 Section 1: Voluntary Disclosure
Section 1: Voluntary Disclosure
Voluntary Disclosure Name:
Disclosure Status: In Progress - Disclosure(s) 8t Compliance Certifkation(s) Pending O
Disclosure Initiation Date: 9/1/2015 ©
* Disclosure Policy: -- Please Select Policy —
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3.3. Section 2: Add Violation
Section 2 allows the user to enter detailed information on a specific violation disclosure. It
includes fields that will capture the violation discovery date, facilities and section and statutes
that may have been violated as displayed in Figure 3-5. Fields in Section 2 include help text
made available by clicking on the "?" symbol.
Figure 3-5 Section 2: Add Violation
Section 2: Add Violation
* Violation Discovery Date:
Disclosure Group Name:
?
'?' Disclosure Group 2
* Select Facility: ®
If no facilities are listed below, click on the green Manage Facilities button to add any needed facilities.
Select I Registry ID
Program ID | Facility Name
Facility Address
110020519134
110005235351
110057635545
110090063351
Q
EDISC85423
EDISC85421
EDISC85420
EDISC85426
AMERICAN COLOR GRAPHICS INC
AMERICAN ENERGY RESTAURANT
EQUIPMENT
APPLIED SCIENCE AND TECHNOLOGY
VINTAGE 2
5101 S VALLEY INDUSTRIAL BLVD SHAKOPEE MN, 55379-
1821
7542 FULLERTON CT SPRINGFIELD VA, 22153
9207 SHOTGUN COURT SPRINGFIELD VA, 22153
654 HUNGRY STREET, SUITE 777 CHESTER VA, 23836
Manage Facilities
* Select Violations:
CAA Clean Air Act
CERCLA Compreliensive Environmental Response, Compensation, and Liability Act
CWA Clean Water Act
EPCRA Emergency Planning and Community Right-to-Know Act
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
MCRBMA Mercuiy-Containing And Rechargeable Battery Management Act
MPRSA Marine Protection, Research and Sanctuaries Act (Ocean Dumping Act)
RCRA Resource Consei'vation and Recovery Act
SDWA Safe Drinking Water Act
TSCA Toxic Substances Control Act
Save Violation
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Follow these steps to add a violation in Section 2:
1. Violation Discovery Date: Enter the date on which the violation was discovered. In order
to meet the prompt disclosure condition, disclosures must be made within 21 days of
discovery. By clicking on the Violation Discovery Date box, a calendar will display,
highlighting in green the discovery dates that would make a disclosure submitted today a
prompt disclosure under EPA's Audit Policy or Small Business Compliance Policy.
Note that if discovery occurred on the same day for all facilities and violations below,
you may specify a single discovery date. If discovery dates vary for some violations,
choose the appropriate discovery date for the selected violations and click "Save
Violation" button then choose other discovery dates for other violations.
2. Disclosure Group Name: This is a system generated name for the group of violations the
user is disclosing. Once you click on the "Save Violation" button, you have finished
disclosing for a group. A new Disclosure Group Name automatically will be generated
for the next set of violations. Note that the disclosure group has one same Violation
Discovery Date.
3. Select Facility: Select one or more facilities for which the above Violation Discovery
Date applies. You may select all facilities if all potential violation being disclosed were
discovered on the same date (e.g., through the same audit). If a different Violation
Discovery Date applies to some listed facilities, they cannot be combined in a single
disclosure group and separate disclosure groups must be submitted. Click on the
"Manage Facilities" button if you have not previously selected violations. See Section
3.3.1 for more information.
4. Manage Facilities: Users who wish to disclose potential violations at facilities not already
listed on the page can add such facilities to the disclosure, provided the disclosed
violations for such newly added facilities were discovered on the same Violation
Discovery Date (e.g., in the same audit). If a different Violation Discovery Date applies
to such additional facilities, they cannot be added to this disclosure group and a separate
disclosure group must be initiated and submitted. See Section 3.3.1 for more information.
5. Select Violations: Click on the "Expand All" link to see the statutory list of provisions
available in the table. Select each specific legal provision(s) that may have been violated
at the facilities selected for the disclosure. When expanded, the table displays all available
statutes and corresponding sections. You may select one or more by clicking on the
checkboxes on the left side of the table as shown in Figure 3-6. Click on the "Collapse All"
link to collapse the table when needed. Note that you can also expand individual sections
by clicking on the arrow keys next to each Statute name.
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Figure 3-6 Select Violations table
* Select Violations: 0
» CM
110
111
112
u 112B
Q 112D
O 112E
112G
LI 112H
C 1121
112K
C 112R
113A
114
EjtmmtaB Collapse aJI
Clean Air Act
Implementation Plan for National Primary and Secondary Ambient Air Quality Standards
New Source Performance Standards
Hazardous Air Pollutants
Asbestos
MACT Standards
MACT Adoption Schedule
Modification
Work Practices
Permits/Compliance Schedule
Area Source MACT
General Duty/Accidental Release
Violation of Existing Administrative Order
Record keeping, Inspection, Information Request
6. Save Violation: Clicking on this button allows you to save in draft form the violation
disclosure information that you have entered into the eDisclosure system for submission
at a later time. NOTE: Clicking on this button will not submit the disclosure, and you
must make sure to return to this disclosure and click on the Submit Selected Disclosures
button within 21 days of discovery in order for the disclosure to be considered prompt
under EPA's Audit Policy or Small Business Compliance Policy. Violation Disclosures
that have been saved in draft form will display in the table in Section 3. Disclosures can
only be submitted in Section 3 of the Violation Disclosure Form.
3.3.1. Facilities Management
When clicking on the "Manage Facilities" button you will be routed to a Facilities Management
screen as shown in Figure 3-7. The My Facilities tab will display all previously selected
facilities.
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Figure 3-7 Facilities Management
Facilities Management
The facilities list under the My Facilities tab are linked to the Organization Name that you selected when opening eDisclosure. If
you do not see your facility, it may be due to your profile having multiple organizations, please ensure you have selected the
correct organization. If you still don't see your facility list please use the Add Facilities tab. You will be able able to search for a
Facility ID by entering either an EPA Registry ID or a Program ID (TSCA, CEDRI, TRI, etc.).
Return to Violation Disclosure
My Facilities Add Facilities
Manage Facilities (4 facilities managed)
List View | Map View
The facilities selected for this data flow and role are listed below. You may add facilities by clicking the 'Add Facilities' button or
tab. The ability to edit a facility is available from the 'Facility Details' screen which is accessible by clicking the 'Details' link for
a facility in the table view or by clicking the 'Details' button on the map view. Please note that facilities with insufficient
location information may not appear on the map view.
EPA Registry ID . Program ID ©
110020519134
110005236351
110057635545
110090063351
Add Facilities
EDISC85423
EDISC85421
EDISC85420
EDI5C85426
Facility Name
AMERICAN COLOR
GRAPHICS INC
AMERICAN ENERGY
RESTAURANT
EQUIPMENT
APPLIED SCIENCE AND
TECHNOLOGY
VINTAGE 2
Facility Address i
5101S VALLEY
INDUSTRIAL BLVD Details
SHAKOPEE, MN 55379-
1821 Remove
SCOTT
7542 FULLERTON CT
SPRINGFIELD, VA 2215
3 Remove
FAIRFAX
9207 SHOTGUN COURT
SPRINGFIELD, VA 2215
3 Remove
FAIRFAX O
654 HUNGRY STREET,
SUITE 777 Details
CHESTER, VA 23836 Remove
CHESTERFIELD O
You may add new facilities by clicking on the "Add Facilities" button or tab. Enter information
for one or more fields as displayed in Figure 3-8 and click on the "Search Facilities" button.
Select one or more facilities by clicking on the radio buttons and click on "Proceed with
Selections" when ready. The selected facilities display in a table under the "Unsaved Facilities"
tab as shown in Figure 3-9. Clicking the "Save Selected Facilities" button saves the facilities you
have selected in the current session so they are available to you the next time you log in. The
saved facilities will also display in Section 2 of the Violation Disclosure form.
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Figure 3-8 Add Facilities
My Facilities Add Facilities
Find Existing Facility
< Back to My Facilities
Fill in at least two search criteria to
Facility ID
Facility Name
Facility Address
City
State
ZIP Code
1 Search Facilities I
mprove search results.
T
Figure 3-9 Save Selected Facilities
My Facilities Add Facilities tins
aved Facilities
Selected Facilities List view | Hap view
< Add Additional Facilities
Clicking the 'Save Selected Facilities' button saves the facilities you have selected in the current session so they are
available to you the next time you log in. The ability to edit a facility is available from the 'Facility Details' screen which
is accessible by clicking the 'Details' link or button for a facility.You may also remove individual facilities by clicking the
'Remove' link or button for a particular facility. Please note that facilities with insufficient location information may not
appear on the map view.
EPA Registry 1C Program ID Facility Name Facility Address
7664-Q
AMBERTONE FULLERToN ROAD Details
110057999698 Pendinq DDCCC mir- SPRINGFIELD, VA
3RESS, INC. 22153 Remove
FAIRFAX ©
I Save Selected Facilities I
The ability to edit a facility is available by clicking on the "Details" link for a facility in the table
view or by clicking the "Details" button on the map view as shown in Figure 3-10.
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Figure 3-10 Facility Details
Facilities Management
Return to Violation Disclosure
My Facilities Add Facilities
Facility Details
< Back to My Facilities
EPA Registry ID
Program ID
110057999698
EDISC84788
Program Acronym
CDX: eDisctosure - FRS: EDISC
Facility Name
AMBERTONE PRESS, INC,
Facility Address
7664-Q FULLERTON ROAD
SPRINGFIELD, VA 22153
FAIRFAX
Coordinates
Edit Facility
Note that you can go back to the Violation Disclosure form anytime by clicking on the "Return
to Violation Disclosure" button available on all screens for Facilities Management.
The user can also manage facilities by clicking on the "Manage Facilities" tab on the top of the
screen as displayed in Figure 3-11.
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Figure 3-11 Manage Facilities Tab
MyCDX Inbox My Profile Violation Disclosure Compliance Certification Disclosure Search Sharing
Manage Facilities
You are here: MyCDX» Facilities Management
Facilities Management
The facilities list under the My Facilities tab are linked to the Organization Name that you selected when opening eDisclosure. If
you do not see your facility, it may be due to your profile having multiple organizations, please ensure you have selected the
correct organization. If you still don't see your facility list please use the Add Facilities tab. You will be able able to search for a
Facility ID by entering either an EPA Registry ID or a Program ID (TSCA, CEDRI, TRI, etc.).
Return to Violation Disclosure
My Facilities Add Facilities
3.4. Section 3: Submit Disclosure
Section 3 displays a table populated with the violations that have been entered in Section 2. The
table can be expanded and collapsed by using the corresponding links on top of the table. You
can also expand individual sections by clicking on the arrow keys next to each Group, Facility,
Statute and Section name as shown in Figure 3-12.
Figure 3-12 Section 3: Submit Disclosure
Section 3: Submit '^
Listed below are disclosures that you can submit, wit
potential violations to any of the Disclosure Groups t
Disclosure Group that has the same discovery date a
discovery date that is different than your disclosures
Section 2 above.
Select
All Disclosure Croup Name
» Disclosure Group 1
hdraw, or for which you may cerl
elow, click on the "Add Violation'
s the violations that you are addi
listed below, you must add the v
Exoand a]] Collaose all
Violation Disclosure
Discovery Submission Status
Date Date
ify compliance. If you wish to add
hyperlink corresponding to the
nq. If the added violations have a
olations in a new Disclosure Group in
Available Actions
• Add Violation
Certification Statement
Clickina on this button officially submits the selected disclosures to EPA. once submitted, the eDisclosure system will use the
Violation Discovery Date to automatically calculate the date on which violations must be corrected and will use the Disclosure
Submission date to automatically calculate the date on which the disc loser must Certify Compliance. Disc losers can Certify
Compliance immediately or anytime up to the Compliance Certification deadline.
• Submit Selected Disclosures HUfl
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The table includes the following columns:
1. Select All: This column includes checkboxes for each row in the table. You will be able
to submit one or more disclosures at a time by using the checkboxes and clicking on the
"Submit Selected Disclosures" button. You can also select a checkbox at the Group,
Facility, Statute, or Section level to submit a complete disclosure group, a complete
facility, a whole statute, or a whole section. Please note that the checkboxes in this
column are for multiple disclosure submissions only and not for the "Available Actions"
column. The actions for the corresponding group, facility, statute and section levels
should be addressed individually.
2. Disclosure Group Name: This column includes the Disclosure Group Name that was
system generated when disclosing and saving a group of violations. It also lists the
facilities, statutes and sections for which the violations have been disclosed. You can use
the arrow icons to expand or collapse the groups, facilities and statutes as needed.
3. Violation Discovery Date: This is the date entered in the "Discovery Date" field in
Section 2.
4. Disclosure Submission Date: This is the date on which a section was submitted (when
you clicked the "Submit Selected Disclosures" button). Several sections may display the
same submittal date since you can submit multiple sections by using the checkboxes in
the "Select All" column.
5. Status: This column displays statuses corresponding to the sections listed in the table. The
available statuses are as follows:
a. Disclosure Submittal Due Date (MM/DD/YY) [XX Davsl: The disclosure has
been saved but has not yet been submitted. The status displays the available time
to submit the violation disclosure.
b. Compliance Certification Due Date (MM/DD/YY) [XX Days]: the disclosure has
been submitted and is waiting on Compliance Certification. The status displays
the available time frame to submit the Compliance Certification Form. The time
frame will correspond to the available period for either the Audit Policy or Small
Business Compliance Policy
c. Notice of Determination Issued (MM/DD/YY): This status indicates that the
Compliance Certification has been submitted and a Notice of Determination was
issued by the system. The status also displays the date the Notice of
Determination was issued.
d. Acknowledgment Letter Issued (MM/DD/YY): This status indicates that the
Compliance Certification has been submitted and an Acknowledgment Letter was
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issued by the system. The status also displays the date the Acknowledgment
Letter was issued.
e. Withdrawn: No Violation (MM/DP/YY): This status displays when a disclosure
has been withdrawn by the discloser before compliance certification is due. The
user indicated there was no violation and opted to withdraw within the
compliance certification due period. The status displays the date the violation was
withdrawn by the user.
f. Ineligibility Letter Issued (MM/DP/YY):This status applies to one of the
following situations:
The disclosure does not quality for an electronic Notice of Determination
(eNOD) or Acknowledgment Letter (AL) based on submitted Compliance
Certification indicating not all conditions of applicable policy being met.
The deadline for certifying compliance for the disclosure has passed. The
user failed to timely certify compliance and will not be eligible to receive
an electronic Notice of Determination (eNOD) or Acknowledgment Letter
(AL).
- The entity failed to disclose within 21 days of discovery and will not be
eligible to receive an electronic Notice of Determination (eNOD) or
Acknowledgment Letter (AL).
Available Actions: This column displays actions that are available to the user at the
group, facility, statute and section level. The available actions are:
a. Add Violation: This hyperlink allows the user to add a violation to an existing
group within the 21 day period from the violation discovery date. The hyperlink
will no longer be available once the 21 day period has expired.
b. Revise Discovery Date: This hyperlink allows the user to modify the violation
discovery date. A pop-up box will display to enter the new date. The hyperlink
will only be available when no sections within the Disclosure Group have been
submitted.
c. Withdraw Violation: When clicking on this hyperlink, the user will withdraw (or
delete, if not yet submitted) a complete violation, including all facilities, statutes
and sections. A pop-up box will display for the user to confirm the selected
action.
d. Withdraw Facility: By selecting this hyperlink, the user will withdraw (or delete,
if not yet submitted) all violations associated with the specific facility in a
Disclosure Group. A pop-up box will display for the user to confirm the selected
action.
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e. Withdraw Statute: This hyperlink allows the user to withdraw all violations
associated with the specific statute in a Disclosure Group. A pop-up box will
display for the user to confirm the selected action.
f Withdraw Section: When selecting this hyperlink, the user will withdraw (or
delete, if not yet submitted) the violation associated with the specific section in
this Disclosure Group only.
g. Go to Compliance Certification Page: This hyperlink takes the user directly to the
Compliance Certification form for the corresponding section. The user is able to
go back to the form as many times as needed before submitting it. The
information will be saved when clicking on the "Save for Later" button included
on the Compliance Certification page.
h. Request Correction Extension: This hyperlink routes to a new screen that allows
the user to request both a short term extension (with no explanation required) and
longer extensions where a justification is required. The available timeline will
correspond to the disclosure policy involved. The Request Correction screen is
discussed in detail in Section 4, Requesting Correction Extensions.
i. View Notice of Determination: This hyperlink opens a copy of the Notice of
Determination issued by the system.
j. View Acknowledgment Letter: This hyperlink opens a copy of the
Acknowledgment Letter issued by the system.
k. View Ineligibility Letter: This hyperlink opens a copy of the Ineligibility Letter
issued by the system.
The lower part of Section 3 includes a Certification Statement. Please read it carefully
before submitting and clicking on the "Submit Selected Disclosures" button.
You will be able to submit one or more disclosures at a time by using the checkboxes in
the table under the "Select All Column". Select one or more disclosures and click on the
"Submit Selected Disclosures" button. You can also select a checkbox at the Group,
Facility or Statute level to submit a complete disclosure group, a complete facility or a
whole statute. When ready, click on the "Submit Selected Disclosures" button to submit
your selections. Once the violations are submitted, the corresponding statuses are updated.
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4. Requesting Correction Extensions
The eDisclosure portal allows disclosures to request correction extensions for both Audit Policy
and Small Business Compliance Policy. The following sections list the steps to follow to request
correction extensions and explains the different timelines for both disclosure policies.
^J^Ctorrection^Ex^
To obtain an electronic Notice of Determination (eNOD), disclosers must correct their violations
within 60 days of the date of discovery for those seeking penalty mitigation under the Audit
Policy.
Category 2 disclosers seeking penalty mitigation under the Audit Policy can make an online
request to correct their violations within 30 days. Correction extension requests within 30 days
do not require the discloser to provide an extension justification.
Category 2 disclosers seeking penalty mitigation under the Audit Policy can also make an online
request for more than 30 additional days to correct their violations, provided the violation
correction date does not extend beyond 180 days after the date of discovery. To make such a
request for an extension of more than 30 days, disclosers must include in the eDisclosure system
a justification for such extension.
Upon such request, the eDisclosure system will automatically extend the Compliance
Certification Report due date by an amount equal to the correction period extension, but the
request is not considered granted or denied at the time of the request.
EPA is more likely to scrutinize requests for extension beyond 30 additional days and ultimately
may decide that correction was not prompt, if and when it considers taking an enforcement
action for environmental violations.
To request an extension, navigate to Section of the Violation Disclosure and determine the
section for which you will be requesting the extension. Extensions can only be requested at the
law section level. In the "Available Actions" column, click on the "Request Correction"
hyperlink as shown in Figure 4-1.
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Figure 4-1 Request Correction Extension Hyperlink
Select
All
Violation D
Disclosure Croup Name Discovery Su
DatE
• Disclosure Group 1
• APPLIED SCIENCE AND TECHNOLOGY
* Emergency Planning and Community Right-to-Kncw Act (EPCRA)
303 Comprehensive Emergency Response Plans 10/20/15
(Emergency Preparedness)
304 Emergency Release Notification Section 313 10/20/15
Program (Emergency Release Notification)
sefoflmne
bmissfon Status Available Actions
Date
• Withdraw Group
• Add Violation
• Withdraw Facility
• Withdrew Statute
• Withdraw Section
Compliance • Go To Compliance
11/02/15 Certification Due Certification Pace
01/04/16 [63 Days] . Request Correction
• Withdraw Section
Compliance • Go To Compliance
11/02/15 Certification Due Certification Page
01/rj4/16J63Dav5l. Request Correction
The hyperlink will direct you to a Request Correction Extension page (Figure 4-2). The page
includes the following sections:
• Section 1: Violation Information: This section displays information to the violation
disclosure you have requested an extension for. Note that the extension correction request
will not be active until you click on the "Request Extension" button on the bottom of the
page.
• Section 2: Extension History: This section includes information on previous extensions
you have requested for the violation disclosure displayed in Section 1. The table in this
section provides details on the Extension Request Date, Extended Violation Correction
Due Date and the Extended Compliance Certification Due Date. Extensions that include
justification will display a checkmark in the "Justified extension" column. The "View
Justification" column provides a "Details" hyperlink that will display detailed
information on that specific justified extension request.
• Section 3: Request Extension: This is the section where you will enter specific details on
the extension request. It displays the Current Violation Correction Due Date. Click on the
"New Violation Correction Due Date" field to enter the extension correction date. A
calendar widget displays allowing you to select a date. Once the date is selected the "New
Compliance Certification Due" will display a date that is system generated. This is the
new date on which the Compliance Certification is due. You will be able to select a date
up to 180 days.
• Section 4: Extension Justification: This section will only display if the extension period
you have selected is beyond 30 days from the initial compliance due date, and does not
extend beyond 180 days. It includes a text box to enter justification comments.
• Section 5: Add Attachments: This section will only display if the extension period you
have selected is beyond 30 days from the initial compliance due date, and does not extend
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beyond 180 days. It allows the discloser to upload one or more attachments (any file
format) with a total size limit of 50MB.
Request Extension button: Click on this button when you are ready to submit the
extension correction request. The system will generate both a pop-up message and an
email confirmation with specific information on the requested extension.
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Figure 4-2 Request Correction Extension Page
MyCDX y Inbox [| My Profile [| Violation Disclosure y Compliance Certification [| Disclosure Search y Sharing [| Manage Facilities |
You are here: MyCDX» Request Extension
Request Extension
On this page, you may request an extension of the Current Violation Correction Due Date for the violation(s) listed below. The
"Status" column in Section 1 notes the current Compliance Certification Due date. Any extensions requested for the Current
Violation Correction Due Date will automatically extend the Compliance Certification Due date by an equal number of days,
except where a Compliance Certification Due Date falls on a weekend or federal holiday, in which case it will be due on the
next business day. NOTE ALSO that any violations for which you request an extension will not be eliqible to receive an electronic
Notice of Determination (eNOD) in the eDisclosure system. Any violations subject to an extension may receive, at most, an
Acknowledgement Letter in eDisclosure. If you are seeking an eNOD for eligible EPCRA violations, do not request an extension.
Section 1: Violation Information
Violation Croup Name
Violation
Discovery Date
Disclosure
Submission
Date
Status
Disclosure Group 1
APPLIED SCIENCE AND TECHNOLOGY
Emergency Planning and Community Right-to-Know .Act (EPCRA)
304 Emergency Release Notification Section 313 Program
(Emergency Release Notification)
Compliance Certification
10/20/2015 11/2/2015 Due
1/4/2016 (63 Days)
Section 2: Extension History1?
justified Extension
Extension Request Date
Extended Violation
Correction Due Date
Extended Compliance
Certification Due Date
View Justification
No Extension History
Section 3:Request Extension (?)
Current Violation Correction Due Date:
New Violation Correction Due Date:
New Compliance Certification Due Date;
(?) 12/20/2015
Request Extension
'*'
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To obtain an electronic Notice of Determination (eNOD), disclosers must correct their violations
within 90 days of the date of discovery for those seeking penalty mitigation under the Small
Business Compliance Policy.
Category 2 disclosers seeking penalty mitigation under the Small Business Compliance Policy
can make an online request to correct their violations within 90 days. Correction extension
requests within 90 days do not require the discloser to provide an extension justification.
Category 2 disclosers seeking penalty mitigation under the Small Business Compliance Policy
can also make an online request for more than 90 additional days to correct their violations,
provided the violation correction date does not extend beyond 360 days after the date of
discovery.
To make such a request for an extension of more than 90 days, disclosers must include in the
eDisclosure system a justification for such extension.
Extensions of more than 180 days after discovery must be based on the time needed to correct
the violation(s) by putting into place pollution prevention measures.
Upon such request, the eDisclosure system will automatically extend the Compliance
Certification due date by an amount equal to the correction period extension, but the request is
not considered granted or denied at the time of the request.
EPA is more likely to scrutinize requests for extension beyond 90 additional days and ultimately
may decide that correction was not prompt, if and when it considers taking an enforcement
action for environmental violations.
To request an extension navigate to Section of the Violation Disclosure and determine the
section you will be requesting the extension for. Extension can only be requested at the section
level. In the "Available Actions" column, click on the "Request Correction" hyperlink as shown
in Figure 4-3 .
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Figure 4-3 Request Correction Extension Hyperlink
Select
All
Violation Di
Disclosure Croup Name Discovery Su
DatE
» Disclosure Group 1
• APPLIED SCIENCE AND TECHNOLOGY
5 closure
amissfon Status Available Actions
Date
• Withdraw Group
• Add Violation
• Withdraw Facility
- Emergency Planning and Community Right-to-Know Act (EPCRA) • Withdrew Statute
• Withdraw Section
Compliance • Go To Compliance
303 Comprehensive Emergency Response Hans 10/20/15 11/02/15 Certification Due Certification Page
(Emergency Preparedness) 01/04/16 [63 Days^ . Request Correction
^^^^^^^ Extension
304 Emergency Release Notification Section 313 10/20/15
Program (Emergency Release Notification)
• Withdraw Section
Compliance • Go To Compliance
11/02/15 Certification Due Certification Page
01/04/16 [63 Days]^ . Request Correction
^^^^^^^ Extension
The hyperlink will direct you to a Request Correction Extension page (Figure 4-2). This page
includes the same sections for both the Audit Policy and Small Business Compliance Policy.
Please refer to section 4.1 Correction Extensions for Audit Policy Disclosures to see a detailed
list and explanation of all sections.
Note that in the case of Small Business Compliance Policy, Section 4 (Extension Justification)
and Section 5 (Add Attachments) will only display if the extension period you have selected is
beyond 90 days from the initial compliance due date, and does not extend beyond 360 days.
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5. Previously Disclosed EPCRA Violations
eDisclosure provides a 120-day window (after the system is launched) that allows you to enter
previously disclosed EPCRA violations. These violations must have been disclosed to EPA
before the launch of the eDisclosure portal. This functionality will only be available during the
120-day window and will no longer be active after the period expires.
To disclose these violations click on the "Disclose Previously Disclosed EPCRA Violations"
button located above the Open Violations table on the landing page as shown in Figure 5-1.
Figure 5-1 Disclose Previously Disclosed EPCRA Violations
MyCDX Inbox My Profile
Violation Disclosure
Compliance Certification Disclosure Search Sharing Manage Facilities
You are here: MyCDX» Open and Closed Disclosures
This page is where you can enter information about potential civil (but not criminal) violations of environmental law that you wish
to voluntarily disclose to EPA and to view a listing of your open and closed disclosures. For more information about, or to edit, a
disclosure, click on the Details hyper-link in the Available Actions column.
Disclose New Violations
Disclose Previously Disclosed EPCRA Violations
The Open Disclosures table below shows all of your open disclosures. Once Compliance Certifications are submitted for all
violations in a Disclosure Group, it will no longer display in the Open Disclosures table. To view the details of any such closed
disclosures, please see the Closed Disclosures table below or click here to do a search of your Closed Disclosures. If you also wish
to view disclosures that others have shared with you, please click on the Sharing tab at the top of the page.
Open Disclosures
The Previously Disclosed EPCRA Violations page will display as shown in Figure 5-2.
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Figure 5-2 Disclose Previously Disclosed EPCRA Violations
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The Violation Disclosure screen includes several sections as follows:
1. Note to Submitters
2. Organization Point of Contact (POC) Information
3. Section 1: Voluntary Disclosure
4. Section 2: Add Violation
5. Section 3: Submit Disclosure
6. Section 4: Attachments
5.1. Note to Submitters and POC Information
The top section of the Violation Disclosure screen includes a note to submitters reminding them
that Previously Disclosed EPCRA Violations must be disclosed within 120 days of launch of the
system. A "Help Desk" link is available in case you need more information or have specific
questions on eDisclosure.
The Organization Point of Contact (POC) section includes information you entered during the
registration process as shown in Figure 5-3. This information is read-only and includes the
following fields:
1. First Name
2. Last Name
3. CDXUserlD
4. Organization: Remember this organization is the one you are disclosing on behalf of. The
organization may or may not be same organization you are employed by.
5. Email Address
6. Phone Number
Note: If users need to make updates to their first name last name email, they will need to contact
the helpdesk.
Figure 5-3 Note to Submitters and POC Information
Previous Violation Disclosure
NOTE TO SUBMITTERS: Previous disclosed EPCRA Violations must be submitted within 120 days after portal launch. The ability to
do so will be removed from the system once the 120 days expire. Help Desk.
(* Indicates Required Fields)
Organization Point of Contact (POC) Information
First Name: Paulette
Last Name: Elvir
CDX User: PAULETTE. ELVIR
Organization: CGI FEDERAL
Email Address: paulette.elvir@cgifederal.com
Phone Number: (703) 227-6281
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5.2. Section 1: Voluntary Disclosure
Section 1 captures general information on the violation disclosure as show in Figure 5-4. It
includes the following fields:
1. Voluntary Disclosure Name: this a text field where the user will enter a name for the
corresponding violation disclosure. To allow users to easily retrieve the disclosure in the
future, disclosers must assign a unique name to identify the disclosure and distinguish it
from other disclosures made on behalf of the same entity. For example, disclosers may
wish to include the name of the entity, facility, and/or legal requirements at issue (e.g.,
ABC Company-Smalltown Refinery-EPCRA 313).
2. Disclosure Status: This is a system generated status for the potential violation(s) the user
has entered into eDisclosure. Only one of the following four status options will display:
a. Unsaved Draft: displays when a user initiates a disclosure and has not saved any
violations.
b. Draft-No Disclosure(s) Submitted: violation(s) are in draft and have not been
submitted by the user.
c. In Progress - Disclosure(s) and Compliance Certification(s) Pending: the user
has disclosure(s) that have not been submitted, as well as disclosure(s) that have
been submitted and have Compliance Certification(s) pending.
d. In Progress - Compliance Certification(s) Pending: all disclosures have been
submitted and have Compliance Certification(s) pending for one or more of the
submitted disclosures.
3. Disclosure Resubmission Initiation Date: This is a system generated date corresponding
to when the user first began to input data into eDisclosure information about potential
violations.
4. Disclosure Policy: A discloser of potential violation must select the incentive policy
under which it seeks penalty mitigation. The field has a dropdown with the following two
options:
a. Audit Policy
b. Small Business Compliance Policy
Note that each field has a "?" symbol that includes help text that provides information on the
corresponding fields. Click on the "?" symbol to view the help text.
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Figure 5-4 Section 1: Voluntary Disclosure
Section 1: Voluntary Disclosure
Voluntary Disclosure Name: ® |lest PD 001
Disclosure Status: (g) Unsaved Draft
Disclosure Resubmission Initiation :
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5.3. Section 2: Add Violation
Section 2 allows the user to enter detailed information on a specific previous EPCRA violation
disclosure. It includes fields that will capture the violation discovery date, facilities and section
and statutes that may have been violated as displayed in Figure 5-5. Fields in Section 2 include
help text made available by clicking on the "?" symbol.
Figure 5-5 Section 2: Add Violation
Section 2: Add Violation
Violation Discovery Date *:
Disclosure Group Name:
Select Facility *: -?•
If no facilities are listed below, click on t
| Registry ID | Program ID
O 110090134882 ESTAB89142
D 110090149769 ESTAB89125
(D
.:?) Disclosure Group 1
le green Manage Facilities button to add any needed facilities.
] Facility Name | Facility Address
AAA RECYCLING INC. 12601 FAIR LAKES CIR FAIRFAX VA, 22033
ABC CORP 963 HIGHLAND DR FAIRFAX VA, 22033
I Manage Facilities •&•
* Select Violations: ®
Select | Statute/Section ID Section (Pro
gram)
EPCRA Emergency Planning and Community Right-to-Know Act
LJ 302 Substances and Facilities Covered and Notification (Emergency Preparedness)
Q 303 Comprehensive Emergency1 Response Plans (Emergency Preparedness)
D 311 Material Safety Data Sheets (MSDS) (Material Safety Data Sheets (MSDS))
312 Emergency and Hazardous Chemical Inventory Forms (Inventory of Chemicals)
O 313 Toxic Chemical Release Repoiting (TRI) (Toxics Chemical Release Inventory (TRI))
• Save Violation •
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Follow these steps to add a violation in Section 2:
1. Violation Discovery Date: Enter the date the violation was discovered on. By clicking on
the Violation Discovery Date box, a calendar will display.
Note that if discovery occurred on the same day for all facilities and violations below,
you may specify a single discovery date. If discovery dates vary for some violations,
choose the appropriate discovery date for the selected violations and then choose other
discovery dates for other violations.
2. Disclosure Group Name: This is a system generated name for the group of violations the
user is disclosing. Once you click on the "Save Violation" button, you have finished
disclosing for a group. A new Disclosure Group Name will be automatically generated
for the next set of violations. Note that the disclosure group has one same Violation
Discovery Date.
3. Select Facility: Select one or more facilities for which the above Violation Discovery
Date applies. You may select all facilities if all potential violation being disclosed were
discovered on the same date (e.g., through the same audit). If a different Violation
Discovery Date applies to some listed facilities they cannot be combined in a single
disclosure and separate disclosure groups instead must be submitted. Click on the
"Manage Facilities" button if you have not previously selected violations. See Section
5.3.1 for more information.
4. Manage Facilities: Users who wish to disclose potential violations at facilities not already
listed on the page can add such facilities to the disclosure provided the disclosed
violations for such newly added facilities were discovered on the same Violation
Discovery Date (e.g., in the same audit). If a different Violation Discovery Date applies
to such additional facilities, they cannot be added to this disclosure and a separate
disclosure group instead must be initiated and submitted. See Section 5.3.1 for more
information.
5. Select Violations: The table displays all available EPCRA sections. You may select one or
more by clicking on the checkboxes on the left side of the table as shown in Figure 5-6.
Figure 5-6 Select Violations table
* Select Violations: ®
EPCRA
D 302
303
311
312
D 313
Emergency Panning 3rd Conn unit1.' Right-to-Know Act
Substances and Facilities Covered and Notification [Emergency Preparedness)
Comprehensive Emergency Response Plans [Emergency Preparedness)
Material Safety Data Sheets (MSDS) (Material Safety Data Sheets [MSDS))
Emergency and Hazardous Chemical Inventory Forms (Inventory of Chemicals)
Toxic Chemical Release Reporting [TRI) [Toxics Chemical Release Inventory (TRI))
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Save Violation: Clicking on this button allows you to save in draft form the violation
disclosure information that you have entered into the eDisclosure system for submission
at a later time. NOTE: Clicking on this button will not submit the disclosure, and you
must make sure to return to this disclosure and click on the Submit Selected Disclosures
Violation Disclosures that have been saved in draft form will display in the table in
Section 3. Disclosures can only be submitted in Section 3 of the Violation Disclosure
Form.
5.3.1.
Facilities Management
For more information on Facility Management please refer to the Facilies Management section
discussed in Section 2: Add Violation for Disclosing New Violations.
5.4. Section 3: Submit Disclosure
Section 3 displays a table populated with the violations that have been entered in Section 2.
The table can be expanded and collapsed by using the corresponding links on top of the table.
You can also expand individual sections by clicking on the arrow keys next to each Group,
Facility, Statute and Section name as displayed in Figure 5-12.
Figure 5-7 Section 3: Submit Disclosure
Section 3: Submit Disclosi
Listed below are disclosures
potential violations to any of
Disclosure Group that has th
discovery date that is differe
Section 2 above.
Select
^|| Disclosure Croup
Name
f Disclosure Group 1
* Disclosure Group 2
re®
that you can submit, withdraw, or for which you rr
the Disclosure Groups below, click on the "Add Vi
e same discovery date as the violations that you a
nt than your disclosures listed below, you must ad
Expand all Collaose all
Violation Discovery D?scic!"uVe R^bm^Ton St
Date Submission Dace
ay certify compliance. If you wish to add
Dlation" hyperlink corresponding to the
re adding. If the added violations have a
J the violations in a new Disclosure Group in
itus Available Actions
• Add Violation
• Revise Discovery Date
• Add Violation
• Revise Discovery Date
The table includes the following columns:
1. Select All: This column includes checkboxes for each row in the table. You will be able
to submit one or more disclosures at a time by using the checkboxes and clicking on the
"Submit Selected Disclosures" button. You can also select a checkbox at the Group,
Facility or Statute level to submit a complete disclosure group, a complete facility or a
whole statute. Please note that the checkboxes in this column are for multiple disclosure
submissions only and not for the "Available Actions" column. The actions for the
corresponding group, facility, statute and section levels should be addressed individually.
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2. Disclosure Group Name: This column includes the Disclosure Group Name that was
system generated when disclosing and saving a group of violations. It also lists the
facilities, statutes and sections for which the violations have been disclosed. You can use
the arrow icons to expand or collapse the groups, facilities and statutes as needed.
3. Violation Discovery Date: This is the date entered in the "Discovery Date" field in
Section 2.
4. Original Disclosure Submission Date: This is the date on which a section was submitted
in paper form before access to the eDisclosure portal. Several sections may display the
same submittal date since you can submit multiple sections by using the checkboxes in
the "Select All" column. This is a required field and must be completed before submittal
of a violation disclosure.
5. Status: This column displays statuses corresponding to the sections listed in the table. The
available statuses are as follows:
a. Compliance Certification Due (MM/DD/YY) [XX Daysl: The violation has been
submitted and is waiting on Compliance Certification. The status displays the
available time frame to submit the Compliance Certification Form. The time
frame will be 30 days from disclosure re-submission date.
b. Notice of Determination Issued (MM/DD/YY): This status indicates that the
Compliance Certification has been submitted and a Notice of Determination was
issued by the system. The status also displays the date the Notice of
Determination was issued.
c. Acknowledgment Letter Issued (MM/DD/YY): This status indicates that the
Compliance Certification has been submitted and an Acknowledgment Letter was
issued by the system. The status also displays the date the Acknowledgment
Letter was issued.
In eligibility Letter Issued (MM/DD/YY): This status indicates the
deadline for certifying compliance for the disclosure has passed or that the
submitted Compliance Certification indicated not all conditions of the
applicable policy were met. The user failed to timely certify compliance or
submitted a certification that indicated the applicable policy was not met
and will not be eligible to receive an electronic Notice of Determination
(eNOD) or Acknowledgment Letter (AL).
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Available Actions: This column displays actions that are available to the user at the
group, facility, statute and section level. The available actions are:
a. Add Violation: This hyperlink allows the user to add a violation to an existing
group within the 21 day period from the violation discovery date. The hyperlink
will no longer be available once the 21 day period has expired.
b. Revise Discovery Date: This hyperlink allows the user to modify the violation
discovery date. A pop-up box will display to enter the new date. The hyperlink
will only be available while no section in the Disclosure Group have been
submitted.
c. Go to Compliance Certification Page: This hyperlink takes the user directly to the
Compliance Certification Form for the corresponding section. The user is able to
go back to the forms as many times as needed before submitting. The information
will be saved when clicking on the "Save for Later" button included in the
Compliance Certification Form.
d. View Notice of Determination: This hyperlink opens a copy of the Notice of
Determination issued by the system.
e. View Acknowledgment Letter: This hyperlink opens a copy of the
Acknowledgment Letter issued by the system.
f. View Ineligibility Letter: This hyperlink opens a copy of the Ineligibility Letter
issued by the system.
5^^^
This section allows you to attach support documentation. You must upload a copy of the
violation disclosure you originally submitted to EPA. Click on the "Select Attachments" button
to upload your files as shown in Figure 5-13. It allows the discloser to upload one or more
attachments (any file format) with a total size limit of 50MB.
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Figure 5-8 Section 4: Add Attachments
Section 4: Add Attachments1?1
+ Select Attachments.
Document Name
Test file.docx
The lower part of Section 4 includes a Certification Statement. Please read carefully before
submitting and clicking on the "Submit Selected Disclosures" button.
You will be able to submit one or more disclosures at a time by using the checkboxes in the table
under the "Select All Column". Select one or more and clicking on the "Submit Selected
Disclosures" button. You can also select a checkbox at the Group, Facility or Section level to
submit a complete disclosure group, a complete facility or a whole section. When ready, click on
the "Submit Selected Disclosures" button to submit your selections. Once the violations are
submitted the corresponding statuses are updated.
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6. Add Violations
The Add Violation hyperlink displays in the "Available Actions" column in Section 3 of the
Violation Disclosure form. By clicking on the hyperlink you will be able to add a facility and/or
violations associated to the Disclosure Group only. A pop-up message displays confirming your
action. Click on the "Ok" button to proceed.
You will be routed to a page similar to the violation disclosure page (see Figure 6-1). Section 2
displays violation information details on your current selections. Section 3: Add Violation,
allows you to select a facility and to select new violations. Click on the "Add Violation" button
to save your new selection(s). Confirm that the new selection(s) display in the table in Section 2.
Click on the "Back" hyperlink next to the "Add Violation" button to return to the Violations
Disclosure form.
The Add Violation hyperlink will only be available withing the 21 day violation discovery page.
After the 21 day period has expired, you will not be able to add new violations to an existing
Disclosure Group.
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Figure 6-1 Add Violation Page
MyCDX 11 Inbox [| My Profile [J Violation Disclosure [| Compliance Certification |J Disclosure Search |J Sharing |J Manage Facilities j
You are here: MvCDX» Add Violation
Add Violation
Section 1: Violation Information
Violation Group Name:
Disclosure Name:
' Disclosure Group 1
• EPCRA Test Tutorial
Section 2: Violation Information details <3>
Exund M Collaoie alj
Disclosure Croup Name
» D sclosure Group 1
- APPLIED SCIENCE AND TECHNOLOGY
» Emergency Planning and Community Right-toKnow Act (EPCRA)
303 Comprehensive Emergency Response Plans (Emergency
Preparedness)
304 Emergency Release Notification Section 313 Program
(Emergency Release Notification)
Violation Disclosure
Discovery Submission Status
Date Date
m;7n(iR n/n7/i^ Compliance Certification
Due 01/04/16 [63 Days]
inrtn'1-; n/njrt-; Compliance Certification
11/02, 15 Due nl /04/16 [63 [Javs.I
Section 3: Add Violation
* Violation Discovery Date: ® 10/20/2015
* Select Facility: ?
Select | Registry ID Program ID j Facility Name
110043733715 EDISC6S440 47-4B KAMEHAMEHA HIGHWAY
110020519134 EDISC85423 AMERICAN COLOR GRAPHICS INC
U0005236351 EDISC85421 ^Jj^ ^ RESTAURANT
110057635545 EDISCE5420 APPLIED SCIENCE AND TECHNOLOGY
110024466004 EDEC85424 C & M RUCKS DAIRY
110090063351 EDISC65426 VINTAGE 2
____ g,
* Select Violations: (?)
Exrumd .JI Collaos* all
| Facility Address
47-48 KAMEHAMEHA HIGHWAY KANEOHE , 967J
5101 S VALLEY INDUSTRIAL BLVD SHAKOPEE ,
1B21
7542 F1ILLERTON CT SPRINGFIELD , 22153
9207 SHOTGUN COURT SPRINGFIELD , 22153
22400 NW 144TH AVE OKEECHOBEE , 34972
654 HUNGRY STREET, SI ITTE 777 CHESTER , 23E
» CAA Clean Air Act
* CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
*• CWA Clean Water Act
* EPCRA Emergency Planning and Community Right-to-Know .Act
RFRA Federal Insecticide, Fungicide, and Rodenticide Act
* MCRBMA MercuiY-Containing And Rechargeable Battery Management Act
4
i5379-
36
* MPRSA Marine Protection, Research and Sanctuaries Act [Ocean Dumping Act)
* RCRA Resource Conservation and Recovery Act
SDWA Safe Dnnking Water Act
TSCA Toxic Substances Control Act
Back KMFHBBr-:
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7. Withdraw Violations
The table in Section 3 of the Violation Disclosure page includes hyperlinks in the Available
Actions column that allows you to withdraw a violation disclosure at the group, facility, statute
or section level as shown in Figure 7-1.
Figure 7-1 Withdraw Violations
Expand all Collapse all
Select Violation Disclosure
All Disclosure Croap Name Discovery Submission Status
Date Date
•
» Disclosure Group 1 •
•
* AMERICAN ENERGY RESTAURANT EQUIPMENT
• Emergency Planning and Community Right-to-Know Act (EPCRA) •
Disclosure
303 Comprehensive Emergency Response Plans 10/27/15 Submittal Die Date •
(Emergency Preparedness) 11/17/15 [14 Days]
Disclosure
304 Emeroency Release Notification Section 313 10/27/15 Submittal Due Date •
Proaram (Emergency Release Notification) 11/17/15 [14 Days]
Available Actions
Withdraw Group
.Add Violation
Revise Discovery Date
Withdraw Facility
Withdraw astute
Withdraw Section
Withdraw Section
When you click on the withdraw hyperlinks, a confirmation pop-up message displays asking the
user to confirm or cancel the selection (Figure 7-2). The message will specify whether you are
withdrawing a group, facility, statue or section level. Click "Yes, Continue Withdrawal" to
proceed.
Figure 7-2 Withdraw Violations Confirmation Message
WARNING: By selecting this, you will withdraw (or delete, if not yet
submitted) the selected section or statute. A record of any submitted but
withdrawn disclosures will remain in the eDisclosure system but the
eDisclosure system will not process such withdrawn items further. If you
change your mind later, you will have to re-enter and submit the disclosure
information prior to certifying compliance.
Are you sure you want to continue with this withdrawal?
Yes, Continue Withdrawal No, Cancel Withdrawal
Note that if the violation disclosure has been saved but not submitted, the withdraw action will
act as a delete and will permanently remove the information from the table. If the violation
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disclosure has been submitted, then the withdraw action will change the status to "Withdrawn:
No Violation [date]" as displayed in Figure 7-3.
Figure 7-3 Withdraw: No Violation Status
Section 3: Submit
?•
Listed below are disclosures that you can submit, withdraw, or for which you may certify compliance. If you wish to add
potential violations to any of the Disclosure Groups below, click on the "Add Violation" hyperlink corresponding to the
Disclosure Group that has the same discovery date as the violations that you are adding. If the added violations have a
discovery date that is different than your disclosures listed below, you must add the violations in a new Disclosure Group in
Section 2 above.
Expand all Collapse all
Select
All
u
Disclosure Croup Name
» Disclosure Group 1
Violation
Discovery
Date
» AMERICAN ENERGY RESTAURANT EQUIPMENT
» Emergency Planning and Community Right-to-Know Act (EPCRA)
303 Comprehensive Emergency Response Plans 11/01/15
(Emergency Preparedness)
Disclosure
Submission
Date
Status
Available Actions
11/03/15
Withdrawn: No
Violation 11/03/15
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8. Compliance Certification Forms
The discloser must submit a Compliance Certification form within 60 days of submitting the
initial online disclosure for Audit Policy or 90 days for Small Business Compliance Policy.
The Compliance Certification form must identify the specific violations; certify that the
violations have been corrected, and that the Audit Policy or Small Business Policy conditions
have been met.
This 60- or 90-day compliance certification deadline is subject to limited reporting extensions
that automatically apply when the violation correction deadline is extended (discussed in Section
4 Requesting Correction Extensions).
The 60- or 90-day compliance reporting deadline is different from the deadline to correct the
violations:
• The violation correction deadline runs from the date violations are discovered.
• The compliance reporting deadline runs from the date violations are disclosed (which
may be up to 21 days after discovery).
The eDisclosure portal includes different compliance certification forms based on the disclosure
policy and whether the violation disclosure is EPCRA or non-EPCRA. The following sections
will explain how to complete and submit the following types of certification forms:
1. Audit Policy-EPCRA Compliance Certification Form
2. Audit Policy-Non-EPCRA Compliance Certification Form
3. Small Business Compliance Policy-EPCRA Compliance Certification Form
4. Small Business Compliance Policy-non-EPCRA Compliance Certification Form
All compliance certification forms can be accessed from the Violation Disclosure page or the
Compliance Certification tab. In the Violation Disclosure page, Navigate to Section 3 of the form
and click on the "Go to Compliance Certification Page" hyperlink corresponding to the section
for which you want to certify compliance as displayed in Figure 8-1. The compliance
certification hyperlinks are only available for each specific law section. The hyperlink will direct
you to the Compliance Certification form for that specific law section. Compliance Certification
forms can also be accessed through the Compliance Certification tab as discussed in Section 8.5
Compliance Certification Tab.
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Figure 8-1 Go to Compliance Certification Page Hyperlink
Select
All
Disclosure Cro-uo Name
Violation
Discovery
Date
Disclosure
Submission
Dace
Status
Available Actions
• Disclosure Group 1
• AMERICAN COLOR GRAPHICS INC
» Emergency Planning and Community Right-to-Kno/v Act (EPCRA)
Compli
302 Substances and Facilities Covered and 10/28/15 11/03/15 Cej "
Notification (Emergency Preparedness) 01/04/16 [62 Days]
311 Material Safety Data Sheets I'MSDS) (Material
Safety Data Sheets (MSDS))
:.:«•• -
10/28/15 11/03/15 Certification LUt
01/04/16 [62 Days]
» Resource Conservation and Recovery .Act (RCRA)
3002 Standards Applicable to Generators of
Hazardous Waste (Gen Hazardous Waste
Management - Subtitle C - CESQG)
CorirJ
11/03/15 Certification Due
01/04/16 [62 Days]
Withdraw Group
.Add Violation
Withdraw Facility
Withdraw statute
Withdrew Section
Go To Compliance
Certification Page
Request Correction
Extension
Withdraw Section
Go To Compliance
Certification Page
Request Correction
Extension
Withdraw Statute
Withdrew Section
Go To Compliance
Certification Pace
Request Correction
Extension
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8.1. Audit Policy-EPCRA Compliance Certification Form
If you are disclosing an EPCRAviolation pursuant to the Audit Policy, follow the steps in this
section to complete the Compliance Certification form. The form also includes help text that
provides additional information on how to complete the fields. Click on the "?" symbol to view
the help text. There are three (3) different variations on the form depending on the section of
EPCRA being disclosed. The following describes the information required for an EPCRA
section 313 disclosure. Any difference will be highlighted within the descriptions.
Note: An auto-complete folder icon will display if you have entered information from previous
forms. When you click on the HR next to each field, a list of previously-entered data will display.
You can select from the list by checking on the corresponding radio button and clicking on the
"Select" button.
The General Information section of the EPCRA Audit Policy Compliance Certification Form
captures general information related to the NAICS code and last environmental compliance
certification as shown in Figure 8-2.
a. Primary NAICS code for this facility: If you are a multi-establishment facility,
use the NAICS code of the establishment that provides the most revenue for the
entire site. If you are unfamiliar with NAICS codes and their assignment to a
facility, or if you want to insure your facility is classified correctly, please refer to
http://www.naics.com/search/.
In order to start a search, click on the "Select" button. The "Name" and "NAICS
Code" fields will display. You can search for a specific code by entering
information in one or both fields. Click on the "Find" button to display matching
search results. From the search results, select the corresponding radio button and
hit the "Select" button. Your selection will populate in the "Primary NAICS code
of this facility" field.
Note: Search results will be restricted to 100 matching NAICS Codes. If more
than 100 matching results are found, you will need to provide more stringent
search criteria or search via the NAICS website.
b. Date of last environmental compliance: Click on the dropdowns to make a
selection. The dropdowns include "None" and "Unknown" options for cases
where you cannot provide specific information.
c. Last environmental compliance inspection was performed by: Enter data in the
text field.
d. Regulatory area covered by inspection: Enter data in the text field.
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Figure 8-2 General Information
You cannot certify this submission until all fields are complete.
I. General Information
Click on the (j next to each field to auto-complete with data entered in previous compliance certifications.
1. Primary NAICS code of this facility (?)
2. Date of last environmental compliance inspection by local, state or federal Agency:
d Select year T /1 Select month T | /1 If known, select day T
3. Last environmental compliance inspection was d
performed by:
4. Regulatory area covered by inspection: *-i
8.1.2. Specific Non-Compliance Information
The Specific Noncompliance Information section of the EPCRA Audit Policy Compliance
Certification Form allows the certifier to describe one or more violations. The information needs
to be provided as many times as applicable. Click on the "Add Violation" button to enter
information for each violation as shown in Figure 8-3.
Figure 8-3 Specific Noncompliance Information
II. Specific Noncompliance Information
Describe the violation(s). (This information needs to be provided as many times as applicable. For example, each year of
a multiple reporting year disclosure will have to be filled out separately.)
Add Violation
Once you click on Add Violation, a grouping of seven questions will display as shown in Figure
8-4. You will need to complete the fields as follows:
a. Remove: The Remove button allows you remove the grouping of violation questions
and answers when needed.
b. Reporting Year: select a year from the dropdown (available for Sections 312 and 313,
otherwise date noncompliance began and date returned to compliance are requested).
c. Number of full time employees at this site: Take the number of hours worked by all
full-time, part-time, and contract employees, and anyone else who contributes to the
functions of this facility. Enter the data in the text field.
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d. Physical location of the violation at the facility: Enter corresponding data in the text
field.
e. Violation Type: Select one of the following options from the dropdown (only applies
to section 313):
o Data Quality (Form A)
o Data Quality (Form R)
o Non-reporting (Form A)
o Non-reporting (Form B)
o Supplier Notification
o Other
f. Chemical Information: For each chemical that you are disclosing, specify the
chemical name, its CAS (Chemical Abstract Society) number, and how much of that
chemical was manufactured, processed or otherwise used (EPCRA §313) at the
facility, in pounds, for the year in question. Refer to sections 8.1.2.1 and 8.1.2.2.
g. Questions 6 and 7: To complete these fields you must click on the text boxes and
enter data. You also have the option to add attachments as needed for each of these
questions.
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Figure 8-4 Add Violation Fields
1. Reporting Year
2. Number of full time employees at this site during
reporting year:
3. Physical location of the violation at the facility:
4. Violation type?
•?•
5. Chemical Information, for each chemical you are disclosing for, specify the chemical name, its CAS
(Chemical Abstract Society) number, and how much of that chemical was manufactured, processed or
otherwise used (EPCRA §313) at the facility, in pounds, for the year in question. ®
Add Chemical
6. Provide the date and description of how the violation was corrected and how any harm was remediated.
Attach documents supporting your actions. For example, include written confirmation from authorities that
submittals (Tier II reports, Form R's) were received.
+ Select Attachments
7. Describe what steps were taken to prevent recurrence of the violation, and provide the date that those
measures were implemented. If the measures have not yet been implemented, provide the implementation
schedule setting forth the dates of the anticipated actions.
+ Select Attachments
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8.1.2.1. Add Chemical
In order to add a chemical to your violation, click on the "Add Chemical" button and a group of
fields display. Note that the section includes a "Remove" button at the top for you to delete an
added chemical when needed. If you select the Chemical radio button, you will see Section 1 as
shown in Figure 8-5.
Figure 8-5 Add Chemical
Chemical Information
Is this a. chemical or mixture?
• Chemical Mixture
SECTION 1. CHEMICAL
Use this button to search/find your chemical by CAS number.
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EPA eDisclosure User's Guide
Complete question "1.3 Trade or Generic Chemical Name" only if Part I, Section 2.1 of the
Form R is checked "Yes".
Under Section 3. Activities and Uses of the Toxic Chemical indicate if the manufacture of the
toxic chemical is a produce or import by clicking on the corresponding checkbox. Also select a
checkbox in the rest of the questions in Section 3.
Under Section 4. Maximum Amount of the Toxic Chemical, enter a numeric and units value in
the "Amount" field.
^8/LZZ AddJVIixture
In order to add a chemical to your violation, click on the "Add Chemical" button and a group of
fields display (figure 8-7). Note that the section includes a "Remove" button at the top for you to
delete an added chemical when needed. If you select the Mixture radio button, you will see
Section 2. Mixture Component Identity, where you will need to provide the chemical name
provided by the supplier.
Under Section 3. Activities and Uses of the Toxic Chemical: Indicate if the manufacture of the
toxic chemical is a produce or import by clicking on the corresponding checkbox. Also select a
checkbox in the rest of the questions in Section 3.
Under Section 4. Maximum Amount of the Toxic Chemical: enter a numeric and unit value in
the "Amount" field.
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Figure 8-7 Mixture Sections
Chemical Information
Is this a chemical or mixture?
Chemical * Mixture
SECTION 2. MIXTURE COMPONENT IDENTITY
Trade Or Generic CliemiCdl Name Provided by Supplier (tnportant: Itoamm of TO characters, including numbers, fetters,
spaces, ard pjnctjaton,)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
Ilmpcr.an:: Check all that apply..!
Manufacture the toxic chemical: Produce Import
Process the toxic chemical: D As a reactant
As a formulation component
I; As an article component
Repackaging
As an impurity
Otherwise use the toxic chemical: As a chemical processing aid
As a manufacturing aid
Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE AT ANY TIME
DURING THE CALENDAR YEAR
Amount
8.1.3. Audit Policy Conditions
The Audit Policy Conditions section (Figure 8-8) is for the user to indicate if all Audit Policy
conditions have been met. This section lists a total of nine conditions. Please read the
instructions for each question carefully and complete all conditions before submitting.
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Figure 8-8 III. Audit Policy Conditions
III. Audit Policy Conditions
Condition 1: Systematic Discovery of the Violation through an Environmental Audit or a Compliance
Management System * Q
The violation was discovered as part of an Environmental Audit. (Check each box that applies; all boxes must be checked
to qualify as an audit.) *
O The audit was systematic; ®
isO The audit was documented; @
The audit was periodic and future audits are scheduled; and Q
O The audit was part of an objective review. ®
Or, the violation was discovered as a result of a Compliance Management System (CMS.) (Check each box that applies;
all boxes must be checked to qualify as a CMS.) *
O Compliance policies, standards and procedures that identify how employees and agents are to meet the
requirements of laws, regulations, permits, enforceable agreements and other sources of authority for
environmental requirements;
u Assignment of overall responsibility for overseeing compliance with policies, standards, and procedures, and
assignment of specific responsibility for assuring compliance at each facility or operation;
8.1.4. Saving and Submitting
Save for Later button: This button is located at the bottom of the Compliance Certification
form (Figure 8-9). The "Save for Later" button allows you to save the form if you are not able to
complete it in one session. You can access the form from the "Go To Compliance Certification
Page" hyperlink in Section 3 of the Violation Disclosure form. You can save it as many times as
needed before you are ready for submittal.
Figure 8-9 Save and Submit buttons
Review & Submit button: This button is located at the bottom of the Compliance Certification
Page next to the "Save for Later" button. Click on the "Review & Submit" button when you are
ready to certify compliance. Remember that all required fields must be populated before
submitting. A warning message as shown in Figure 8-10 will display on top of the form if you
try to submit without completing the form correctly. The message will include a list of the fields
you have not completed.
Figure 8-10 Compliance Certification Warning Message
You cannot certify this submission until all fields are complete.
Please address the following error(s),
• Primary NAICS code must be provided.
• Date of last environmental compliance inspection is required.
• Last environmental compliance inspection was performed by is required.
« Regulatory area covered by inspection is required.
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Once you fill out all fields and click on the "Review and Submit" button you will be routed to a
read-only version of the form (Figure 8-11). This allows you to review it before submitting.
Figure 8-11 Read Only Compliance Certification Form
You are here: MyCDX» Review: EPCRA/313 Compliance Report for USDA FOREST SERVICE PLUMAS NATIONAL FOREST
Facility [EPCRA Audit Policy]
EPCRA/31 3 Compliance Report for USDA FOREST SERVICE PLUMAS NATIONAL FOREST
Facility [EPCRA Audit Policy]
I. General Information
i. Primary NAICS code of this facility Grapes, artificially drying
2. Date of last environmental compliance inspection by local, state or federal Agency:
Year: 2015; Month: January; Day: Unknown
3. Last environmental compliance inspection was
performed by:
4. Regulatory area covered by inspection:
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The bottom of the page has a Certification section. It has an "Edit" button that allows you to go
back and make changes as needed before submitting.
Read the section carefully, and when you are ready to certify compliance, click the checkbox.
The "Certify" button becomes active for you to click on, as shown in Figure 8-12.
Figure 8-12 Certification Section
IV. Certification
Name of individual submitting this
self-disclosure:
Ms. Paulette Elvir
Current date:
9/11/2015
By checking this box, I, the person whose name is displayed above, am authorized to make this
certification and certify under penalty of the law that this document was prepared under my direction and
to the best of my knowledge and belief, the information submitted is true, accurate and complete.
Furthermore, I understand that eligibility for, and any reduction of penalties under, the EPA Audit Policy is
conditioned on the truth, accuracy and completeness of this disclosure.
An electronic signature widget displays on the screen (Figure 8-13). Enter the credentials you set
up when registering with CDX. If you forgot your password you will be able to reset it by
clicking on the "Forgot Password" hyperlink included in the certification section.
Enter your credentials and click on the "Sign" button.
Figure 8-13 eSignature Widget
eSignature Widget
1. Loo In to CDX
User:
PAULETTE. ELVIR
Password:
2.Answer Secret Question
Question:
What is your favorite hobby?
Answer:
3,Sign File
Hobby 1
•
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Once you sign, a certification confirmation screen displays as shown in Figure 8-14, indicating
that the compliance certification form has been submitted. It includes general information on the
form and the system's determination. It also provides a "View Report" button to access a read-
only version of the submitted compliance certification form.
Figure 8-14 Certification Confirmation
MyCDX
Inbox 1 1 My Profile I Violation Disclosure 1 1 Compliance Certification 1 1 Disclosure Search
Sharing 1 1 Manage Facilities
You are here: MyCDX » Certified
Compliance Certification
Disclosure Name AP Example
Policy Audit Policy
Statute/Section EPCRA / 313
Compliance Report ID 1085
CROMERR Activity ID _1652e4ff-4954-45cc-abOa-743e49ffla68
Signature Date 11/5/2015
Thank you for certifying compliance. Based on the information that you submitted, the eDisdosure system is issuing a Notice of
Determination (NOD) for the disclosed violation(s) and sending it to the e-mail address(es) that you registered in the eDisclosure
system. If you do not receive such an e-mail within 1 hour, please contact the eDisclosure Help Desk. If you wish to view this
NOD in the eDisclosure system, please click here.
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8.2. Audit Policy Non-EPCRA Compliance Certification Form
If you are disclosing a non-EPCRA violation pursuant to the Audit Policy, follow the steps in
this section to complete the Compliance Certification form. Please note that you cannot certify
the submission until all fields are complete. The form also includes help text that provides
additional information on how to complete the fields. Click on the "?" symbol to view the help
text.
The General Information section (Figure 8-15) of the Audit Policy Non-EPCRA Compliance
Certification Form captures general information related to the NAICS code and last
environmental compliance certification.
a. Primary NAICS code for this facility: If you are a multi-establishment facility, use the
NAICS code of the establishment that provides the most revenue for the entire site. If
you are unfamiliar with NAICS codes and their assignment to a facility, or if you
want to insure your facility is classified correctly please refer to
http://www.naics.com/search/.
In order to start a search, click on the "Select" button. The "Name" and "NAICS
Code" fields will display. You can search for a specific code by entering information
in one or both fields. Click on the "Find" button to display matching search results.
From the search results, select the corresponding radio button and hit the "Select"
button. Your selection will populate in the "Primary NAICS code of this facility"
field.
Note: Search results will be restricted to 100 matching NAICS Codes. If more than
100 matching results are found, you will need to provide more stringent search
criteria or search via the NAICS website.
b. Date of last environmental compliance: Click on the dropdowns to make a selection.
The dropdowns include "None" and "Unknown" options for cases where you cannot
provide specific information.
c. Last environmental compliance inspection was performed by: Enter data in the text
field.
d. Regulatory area covered by inspection: Enter data in the text field.
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Figure 8-15 General Information
CERCLA/122A Compliance Report [Audit Policy]
You cannot certify this submission until all fields are complete.
I. General Information
1. Primary NAICS code of this facility
2. Date of last environmental compliance inspection by local, state or federal Agency:
| Select year T | / | Select month T | / | If known, select day T |
3. Last environmental compliance inspection was
performed by:
4. Regulatory area covered by inspection:
8.2.2. Specific Non-Compliance Information:
The Specific Non-Compliance Information section of the Non-EPCRA Audit Policy Compliance
Certification form (Figure 8-16) allows the certifier to provide details for the violation. You will
need to complete the fields as follows.
a. Fields 1-5: These are all text fields. Click on the field to enter data. Fields 2 and 4 include
help text that explain that you may include violations in statutory programs that were not
part of your submitted disclosure, provided the information submitted on this Compliance
Certification form also applies to any such newly added legal provisions.
b. Dates in questions 6 and 7: A calendar widget displays when you click on the field. The
calendar can go back months and years. You can either select a date from the calendar or
enter a date following the mm/dd/yyyy format. Question 7 includes help text that includes
a hyperlink to request an extension of the violation correction date. Clicking on the
hyperlink will direct you to the request extension page for that specific compliance
certification form.
c. Chemical Information: You can provide information for each chemical/pollutant being
disclosed. For more information see Section 8.2.2.1.
d. Questions 9 and 10: To complete these fields you must click on the text boxes and enter
data. You also have the option to add attachments as needed for each of these questions
as shown in Figure 8-16.
Note: An auto-complete folder icon will display if you have entered information for previous
forms. When you click on the icon, a list of previously entered data will display. You can
select from the list by checking on the corresponding radio button and clicking on the
"Select" button.
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Figure 8-16 Specific Non-Compliance Information
II. Specific ISIoncornpfuince Information
Describe the violation(s). Click on the ^^ next to each field to auto-complete with data entered in previous compliance
certifications.
1. Nature and description of potential violation(s): W-i
2. Citation for the potential federal violation:
3. Regulatory citation for the state provisions where "&
federally enforceable:
4. Permit provisions where applicable:
5. Physical location of tbe violation at the facility:
6. Date iioncompliance began: *L-i
~f '. Date of return to compliance:
8. Identity of Chemical/Pollutant Information, for each cher
tbe a.) chemical /pollutant name or trade name. CAS (Chern
of that chemical/pollutant was involved, in pounds.
m
[e.g., 40 CFR Part 112.3]
1C,
Kb
mm/clri/yyyy
•S |mm/ctd/yyyy
nical/ pollutant you are disclosing for. specify
cal Abstract Society> number, and r>-> how much
'». Provide tbe elate and description of bow tbe violation was corrected and bow any harm was remediated. If
correction of the violation depends upon issuance of a permit that has been applied for but not issued by
Federal, State, Local or Tribal authorities an entity may submit its compliance report without an issued
permit (provided tbe maximum extension requests have been exhausted}. Please describe the steps taken
by the entity to ensure it submitted a timely complete permit application.
Attach documents supporting yoiir actions. For example, include written confirmation from authorities that
siibmirtals (e.g.. Notice of Intent (NOT), reports, etc.} were received.
^
FT
1O. Describe wli.rl steps were taken to prevent recurrence of tile violation ..int.! provide tile elate that tliose
measures were implemented. If the measures have not yet L>eeii implemented, provide tile implementation
schedule setting forth the dates of the anticipated actions.
IB
Document Name
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8.2.2.1. Add Chemical
In order to add a chemical to your violation, click on the "Add Chemical" button and a group of
fields display as shown in Figure 8-17. You can add multiple chemicals by clicking the "Add
Chemical" button multiple times. Note that the section includes a "Remove" button at the top for
you to delete an added chemical when needed.
Figure 8-17 Add Chemical
Chemical Information _.
Use this button to search/find your chemical by CAS number.
a.l) Provide the chemical name (or common name
of the chemical) as provided on the MSDS:
a.2) CAS Number
b) Amount involved Ibs
Click on the "Search" button to search for a chemical by CAS number. Additional fields display
to help you search for the chemical name as shown in Figure 8-18.
Figure 8-18 Chemical Name Look-up tool
Chemical Information |
Use this button to search/find your chemical by CAS number.
Chemical Name bromide | and/or CAS Number
Acetyl bromide (506-96-7)
Bromide (24959-67-9)
You can search for a chemical name by entering the name and/or the CAS Number. Click on the
"Find" button when ready. A list of results displays. Click on the corresponding radio button and
hit the "Select" button. You selection will populate in fields "a.l)" and "a.2)". Complete question
"b)" Amount involved" by entering a numeric value in the field.
8.2.3. Audit Policy Conditions
The Audit Policy Conditions section is for you to indicate if all Audit Policy conditions have
been met (Figure 8-19). This section lists a total of nine conditions. Please read the instructions
for each question carefully and complete all conditions before submitting.
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Figure 8-19 Audit Policy Conditions
III. Audit Policy Conditions
Condition 1: Systematic Discovery of the Violation through an Environmental Audit or a Compliance
Management System * ®
The violation was discovered as part of an Environmental Audit. (Check each box that applies; all boxes must be checked
to qualify as an audit,) *
u The audit was systematic; Q
O The audit was documented; ®
O The audit was periodic and future audits are scheduled; and ®
The audit was part of an objective review. ®
Or, the violation was discovered as a result of a Compliance Management System (CMS.) (Check each box that applies;
all boxes must be checked to qualify as a CMS.) *
U Compliance policies, standards and procedures that identify how employees and agents are to meet the
requirements of laws, regulations, permits, enforceable agreements and other sources of authority for
enviromnental requirements;
Assignment of overall responsibility for overseeing compliance with policies, standards, and procedures, and
assignment of specific responsibility for assuring compliance at each facility or operation;
8.2.4. Saving and Submitting
Save for Later button: This button is located at the bottom of the Compliance Certification
form as shown in Figure 8-20. The "Save for Later" button allows you to save the form if you are
not able to complete it in one session. You can access the form from the "Go To Compliance
Certification Page" hyperlink in Section 3 of the Violation Disclosure form. You can save it as
many times as needed before you are ready for submittal.
Figure 8-20 Save and Submit buttons
Save for Later II Review & Submit
Review & Submit button: This button is located at the bottom of the Compliance Certification
Page next to the "Save for Later" button. Click on the "Review & Submit" button when you are
ready to certify compliance. Remember that all required fields must be populated before
submitting. A warning message will display on top of the form if you try to submit it without
completing the form correctly (Figure 8-21).
Figure 8-21 Compliance Certification Warning Message
You cannot certify this submission until all fields are complete.
Please address the following error(s).
• Primary NAICS code must be provided.
• Date of last environmental compliance inspection is required.
• Last environmental compliance inspection was performed by is required.
» Regulatory area covered by inspection is required.
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Once you fill out all fields and click on the "Review and Submit" button, you will be routed to a
read-only version of the form (Figure 8-22). This allows you to review before submitting.
Figure 8-22 Read Only Compliance Certification Form
CERCLA/122L Compliance Report [Audit Policy]
I. General Information
1. Primary NAICS code of this facility
Brewers' and distillers' flakes and grits, corn, manufacturing
2. Date of last environmental compliance inspection by local, state or federal Agency:
Year: 2013; Month: October; Day: 14
3. Last environmental compliance inspection was John Jones
performed by:
4. Regulatory area covered by inspection: Area 1
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The bottom of the page has a Certification section (Figure 8-23). It has an "Edit" button that
allows you to go back and make changes as needed before submitting.
Read the section carefully, and when you are ready to certify compliance click on the checkbox.
The "Certify" button becomes active for you to click on it.
Figure 8-23 Certification Section
IV. Certification
Name of individual submitting this
self-disclosure:
Ms. Paulette Elvir
Current date:
9/11/2015
By checking this box, I, the person whose name is displayed above, am authorized to make this
certification and certify under penalty of the law that this document was prepared under my direction and
to the best of my knowledge and belief, the information submitted is true, accurate and complete.
Furthermore, I understand that eligibility for, and any reduction of penalties under, the EPA Audit Policy is
conditioned on the truth, accuracy and completeness of this disclosure.
An electronic signature widget displays on the screen as shown in Figure 8-21. Enter the
credentials you set up when registering with CDX. If you forgot your password you will be able
to reset by clicking on the "Forgot Password" hyperlink included in the certification section.
Enter your credentials and click on the "Sign" button.
Figure 8-24 eSignature Widget
eSignature Widget
1. Loo In to CDX
User:
PAULETTE. ELVIR
Password:
2.Answer Secret Question
Question:
What is your favorite hobby?
Answer:
3,Sign File
Hobby 1
•
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Once you sign, a certification confirmation screen displays (Figure 8-25) indicating that the
compliance certification form has been submitted. It includes general information on the form
and the system's determination. It also provides a "View Report" button to access a read only
version of the submitted compliance certification form.
Figure 8-25 Certification Confirmation
MyCDX
Inbox My Profile
Violation Disclosure
Compliance Certification | Disclosure Search
Sharing 1 1 Manage Facilities
You are here: MyCDX» Certified
Compliance Certification
Disclosure Name AP Example
Policy Audit Policy
Statute/Section CERCLA / 122L
Compliance Report ID 1086
CROMERR Activity ID _cb418c5e-33dO-451a-a5t>4-4da8731dc682
Signature Date 11/5/2015
Thank you for certifying compliance. Based on the information that you submitted, the eDisclosure system is issuing an
Acknowledgement Letter for the disclosed violation(s) and sending it to the e-mail address(es) that you registered in the
eDisclosure system. If you do not receive such an e-mail within 1 hours, please contact the eDisclosure Help Desk. If you wish to
view this Acknowledgement Letter in the eDisclosure system, please click here.
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8.3. Small Business Compliance Policy-EPCRA Compliance Certification Form
If you are disclosing an EPCRAviolation pursuant to the Small Business Compliance Policy,
follow the steps in this section to complete the Compliance Certification form. The form also
includes help text that provides additional information on how to complete the fields. Click on
the "?" symbol to view the help text. There are three (3) different variations on the form
depending on the section of EPCRA being disclosed. The following describes the information
required for an EPCRA section 313 disclosure. Any difference will be highlighted within the
descriptions.
Note: An auto-complete folder icon will display if you have entered information from previous
forms. When you click on the IR next to each field, a list of previously-entered data will display.
You can select from the list by checking on the corresponding radio button and clicking on the
"Select" button.
The General Information section of the Small Business Compliance Policy-EPCRA Compliance
Certification form (Figure 8-26) captures general information related to the NAICS code and last
environmental compliance certification.
a. Primary NAICS code for this facility: If you are a multi-establishment facility,
use the NAICS code of the establishment that provides the most revenue for the
entire site. If you are unfamiliar with NAICS codes and their assignment to a
facility or if you want to insure your facility is classified correctly please refer to
http://www.naics.com/search/.
In order to start a search, click on the "Select" button. The "Name" and "NAICS
Code" fields will display. You can search for a specific code by entering
information in one or both fields. Click on the "Find" button to display matching
search results. From the search results, select the corresponding radio button and
hit the "Select" button. Your selection will populate in the "Primary NAICS code
of this facility" field.
Note: Search results will be restricted to 100 matching NAICS Codes. If more
than 100 matching results are found, you will need to provide more stringent
search criteria or search via the NAICS website.
b. Date of last environmental compliance: Click on the dropdowns to make a
selection. The dropdowns include "None" and "Unknown" options for cases
where you cannot provide specific information.
c. Last environmental compliance inspection was performed by: Enter data in the
text field.
d. Regulatory area covered by inspection: Enter data in the text field.
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Figure 8-26 General Information
EPCRA/31 3 Compliance Report for 5000 PLEASE SAVE ME Facility [EPCRA SBCP]
You cannot certify this submission until all fields are complete.
. General Information
1. Primary NAICS code of this facility
2. Date of last environmental compliance inspection by local, state or federal Agency:
| Select year T / Select month T / If known, select day T
3. Last environmental compliance inspection was
performed by:
4. Regulatory area covered by inspection:
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8.3.2. Specific Non-Compliance Information:
The Specific Non-Compliance Information section of the Small Business Compliance Policy-
EPCRA Compliance Certification form (Figure 8-27) allows the certifier to describe one or more
violations. The information needs to be provided as many times as applicable. Click on the "Add
Violation" button to enter information for each violation.
Figure 8-27 II. Specific Noncompliance Information
II. Specific Noncompliance Information
Describe the violation(s). (This information needs to be provided as many times as applicable. For example, each year of
a multiple reporting year disclosure will have to be filled out separately.)
Add Violation
Once you click on the Add Violation, a grouping of seven questions will display as shown in
Figure 8-28 Add Violation Fields. You will need to complete the fields as follows:
a. Remove: The section includes a Remove button that allows you to remove the
violation when needed. The information will be deleted from the form when
clicking on this button.
b. Number of full time employees at this site: Take the number of hours worked by
all full-time, part-time, and contract employees, and anyone else who contributes
to the functions of this facility. Enter the data in the text field.
c. Physical location of the violation at the facility: Enter corresponding data in the
text field.
d. Violation Type: Select one of the following options from the dropdown:
o Data Quality (Form A)
o Data Quality (Form R)
o Non-reporting (Form A)
o Non-reporting (Form B)
o Supplier Notification
o Other
e. Chemical Information: For each chemical that you are disclosing, specify the
chemical name, its CAS (Chemical Abstract Society) number, and how much of
that chemical was manufactured, processed or otherwise used (EPCRA §313) at
the facility, in pounds, for the year in question. Refer to sections 8.3.2.1 and
8.3.2.2.
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f. Questions 6 and 7: To complete these fields you must click on the text boxes and
enter data. You also have the option to add attachments as needed for each of
these questions.
Note: An auto-complete folder icon will display if you have entered information for previous
forms. When you click on the icon a list of previously entered data will display. You can
select from the list by checking on the corresponding radio button and clicking on the
"Select" button.
Figure 8-28 Add Violation Fields
1. Reporting Year
2. Number of full time employees at this site during
reporting year:
3. Physical location of the violation at the facility:
4. Violation type?
,.
5. Chemical Information, for each chemical you are disclosing for, specify the chemical name, its CAS
(Chemical Abstract Society) number, and how much of that chemical was manufactured, processed or
otherwise used (EPCRA §31 3) at the facility, in pounds, for the year in question. @
6. Provide the date and description of how the violation was corrected and how any harm was
remediated. Attach documents supporting your actions. For example, include written confirmation from
authorities that submittals (Tier II reports, Form R's) were received.
Add Attachment
7. Describe what steps were taken to prevent recurrence of the violation, and provide the date that
those measures were implemented. If the measures have not yet been implemented, provide the
implementation schedule setting forth the dates of the anticipated actions.
Add Attachment
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8.3.2.1. Add Chemical
In order to add a chemical to your violation, click on the "Add Chemical" button and a group of
fields display. Note that the section includes a "Remove" button at the top for you to delete an
added chemical when needed. If you select the Chemical radio button, you will see Section 1 as
shown in Figure 8-29.
Figure 8-29 Add Chemical
Chemical Information
Is this a chemical or mixture?
• Chemical Mixture
SECTION 1. CHEMICAL
Use this button to search/find your chemical by CAS number.
1.1 CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical
category.)
7726-95-6
1.2 Toxic Chemical or Chemical Category Name [Important: Enter only one name exactly as it appears on the Section 313 list.)
IBROMINE |
1.3 Trade or Generic Chemical Name (Important: Complete only if Part I, Section 2.1 of the Form R is checked "Yes". Generic Name must
be structurally descriptive.)
Click on the "Search" button to search for a chemical by CAS number. Additional fields display
to help you search for the chemical name as shown in Figure 8-30. You can search for a
chemical name by entering the name and/or the CAS Number. Click on the "Find" button when
ready. A list of results displays. Click on the corresponding radio button and hit the "Select"
button. Your selection will populate in fields 1.1 and 1.2 of "Section 1. Chemical".
Figure 8-30 Section 1. Chemical
Use this button to search/find your chemical by CAS number.
Chemical Name bromide and/or CAS Number
METHYLENE BROMIDE (74-95-3)
VINYL BROMIDE (593-60-2)
Complete question "1.3 Trade or Generic Chemical Name" only if Part I, Section 2.1 of the
Form R is checked "Yes".
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Under Section 3. Activities and Uses of the Toxic Chemical, indicate if the manufacture of the
toxic chemical is a produce or import by clicking on the corresponding checkbox. Also select a
checkbox in the rest of the questions in Section 3.
Under Section 4. Maximum Amount of the Toxic Chemical, enter a numeric value in the
"Amount" field.
83.2.2. AddJVIixture
In order to add a chemical to your violation, click on the "Add Chemical" button and a group of
fields display. Note that the section includes a "Remove" button at the top for you to delete an
added chemical when needed. If you select the Mixture radio button, you will see Section 2.
Mixture Component Identity, where you will need to provide the chemical name provided by the
supplier as shown in Figure 8-31.
Under Section 3. Activities and Uses of the Toxic Chemical: Indicate if the manufacture of the
toxic chemical is to produce or import by clicking on the corresponding checkbox. Also select a
checkbox in the rest of the questions in Section 3.
Under Section 4. Maximum Amount of the Toxic Chemical: enter a numeric value in the
"Amount" field.
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Figure 8-31 Mixture Sections
Chemical Information
Is this a chemical or mixture?
Chemical • Mixture
SECTION 2. MIXTURE COMPONENT IDENTITY
Trade Or Generic Chemical Name Provided by Supplier [Important: Maximum of 70 characters, ircbdirq numbers, btte
spaces, and pjnctjat'ori,)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
Ilmpcr'an:: Check all that apply.)
Manufacture the toxic chemical: Produce Import
Process the toxic chemical: O As a reactant
As a formulation component
i- As an article component
Repackaging
1 As an impurity
Otherwise use the toxic chemical: A; a cheriic?! processing Jid
As a manufacturing aid
Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE AT ANY TIME
DURING THE CALENDAR YEAR
Amount
8.3.3. Small Business Compliance Policy
Conditions:
This section is for the user to indicate if all Small Business Compliance Policy conditions have
been met (Figure 8-32). This section lists a total of four conditions. Please read the instructions
for each question carefully and complete all conditions before submitting.
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Figure 8-32 Small Business Compliance Policy Conditions
III. Small Business Compliance Policy Conditions
Criteria 1: Discovery is Voluntary * @
The violation was voluntarily discovered (1st 4 boxes must be checked to qualify). *
u The violation was discovered prior to notice of an EPA or State inspection.
The violation was not found through a legally required monitoring procedure that is required by statute,
regulation, permit, judicial or administrative order, or consent agreement.
u The violation was not found through a legally required sampling procedure that is required by statute,
regulation, permit, judicial or administrative order, or consent agreement.
The violation was not found through a legally required auditing procedure that is required by statute,
regulation, permit, judicial or administrative order, or consent agreement.
u This facility does not meet Criteria 1.
8.3.4. Saving and Submitting
Save for Later button: This button is located at the bottom of the Compliance Certification
form (Figure 8-33). The "Save for Later" button allows you to save the form if you are not able
to complete it in one session. You can access the form from the "Go To Compliance
Certification Page" hyperlink in Section 3 of the Violation Disclosure form. You can save it as
many times as needed before you are ready for submittal.
Figure 8-33 Save and Submit buttons
Save for Later II Review & Submit
Review & Submit button: This button is located at the bottom of the Compliance Certification
Page next to the "Save for Later" button. Click on the "Review & Submit" button when you are
ready to certify compliance. Remember that all required fields must be populated before
submitting. A warning message as shown in Figure 8-34 will display on top of the form if you
try to submit without completing the form correctly.
Figure 8-34 Compliance Certification Warning Message
You cannot certify this submission until all fields are complete.
Please address the following error(s).
• Primary NAICS code must be provided.
• Date of last environmental compliance inspection is required.
• Last environmental compliance inspection was performed by is required.
» Regulatory area covered by inspection is required.
Once you fill out all fields and click on the "Review and Submit" button, you will be routed to a
read-only version of the form (Figure 8-35). This allows you to review before submitting.
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Figure 8-35 Read Only Compliance Certification Form
You are here: MvCDX» Review: EPCRA/313 Compliance Report for APPLIED SCIENCE AND TECHNOLOGY (SPRINGFIELD, VA
22153) Facility [EPCRASBCP]
EPCRA/31 3 Compliance Report for APPLIED SCIENCE AND TECHNOLOGY (SPRINGFIELD. VA 22153) Facility [EPCRA
SBCP]
I. General Information
1. Primary NAICS code of this facility
Brewers' and distillers' flakes and grits, corn, manufacturing
2. Date of last environmental compliance inspection by local, state or federal Agency:
Year: 2014; Month: January; Day: 2
3. Last environmental compliance inspection was John Jones
performed by:
4. Regulatory area covered by inspection: Area 1
The bottom of the page has a Certification section (Figure 8-36). It has an "Edit" button that
allows you to go back and make changes as needed before submitting.
Read the section carefully, and when you are ready to certify compliance click on the checkbox.
The "Certify" button becomes active for you to click on it.
Figure 8-36 Certification Section
IV. Certification
Name of individual submitting this
self-disclosure:
Ms. Paulette Elvir
Current date:
9/11/2015
By checking this box, I, the person whose name is displayed above, am authorized to make this
certification and certify under penalty of the law that this document was prepared under my direction and
to the best of my knowledge and belief, the information submitted is true, accurate and complete.
Furthermore, I understand that eligibility for, and any reduction of penalties under, the EPA Audit Policy is
conditioned on the truth, accuracy and completeness of this disclosure.
An electronic signature widget displays on the screen (Figure 8-37). Enter the credentials you set
up when registering with CDX. If you forgot your password you will be able to reset by clicking
on the "Forgot Password" hyperlink included in the certification section.
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Enter your credentials and click on the "Sign" button.
eSignature Widget
1. Loo In to CDX
User:
PAULETTE.ELVIR
Password:
:'.'.& EK'ii
Figure 8-37 eSignature Widget
2.Answer Secret Question
Question:
What is your favorite hobby?
Answer.
Hobby 1
3.Sign File
-
Once you sign, a certification confirmation screen displays (Figure 8-38) indicating the
compliance form has been certified. It includes general information on the form and the system's
determination. It also provides a "View Report" button to access a read-only version of the
submitted compliance certification form.
Figure 8-38 Certification Confirmation
MyCDX
Inbox 1 1 My Profile | j Violation Disclosure
Compliance Certification
Disclosure Search
Sharing 1 1 Manage Facilities
You are here: MvCDX» Cettified
Compliance Certification
Disclosure Name
Policy
Statute/Section
Compliance Report ID
CROM ERR Activity ID
Signature Date
CE-158 SBCP
Small Business Compliance Policy
EPCRA / 313
1087
Jlb3aaf8-8065-4443-8547-e010c7dld3c9
11/5/2015
Thank you for certifying compliance. Based on the information that you submitted, the eDisclosure system is issuing a Notice of
Determination (NOD) for the disclosed violation(s) and sending it to the e-mail address(es) that you registered in the eDisclosure
system. If you do not receive such an e-mail within 1 hour, please contact the eDisclosure Help Desk. If you wish to view this
NOD in the eDisclosure system, please click here.
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8.4. Small Business Compliance Policy Non-EPCRA Compliance Certification Form
If you are disclosing a non-EPCRA violation pursuant to the Small Business Compliance Policy,
follow the steps in this section to complete the Compliance Certification form. Please note that
you cannot certify the submission until all fields are complete. The form also includes help text
that provides additional information on how to complete the fields. Click on the "?" symbol to
view the help text.
The General Information section of the Small Business Compliance Policy Non-EPCRA
Compliance Certification Form (Figure 8-39) captures general information related to the NAICS
code and last environmental compliance certification.
a. Primary NAICS code for this facility: If you are a multi-establishment facility,
use the NAICS code of the establishment that provides the most revenue for the
entire site. If you are unfamiliar with NAICS codes and their assignment to a
facility, or if you want to insure your facility is classified correctly please refer to
http://www.naics.com/search/.
In order to start a search, click on the "Select" button. The "Name" and "NAICS
Code" fields will display. You can search for a specific code by entering
information in one or both fields. Click on the "Find" button to display matching
search results. From the search results, select the corresponding radio button and
hit the "Select" button. Your selection will populate in the "Primary NAICS code
of this facility" field.
Note: Search results will be restricted to 100 matching NAICS Codes. If more
than 100 matching results are found, you will need to provide more stringent
search criteria or search via the NAICS website.
b. Date of last environmental compliance: Click on the dropdowns to make a
selection. The dropdowns include "None" and "Unknown" options for cases
where you cannot provide specific information.
c. Last environmental compliance inspection was performed by: Enter data in the
text field.
d. Regulatory area covered by inspection: Enter data in the text field.
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Figure 8-39 General Information
CERCLA/122L Compliance Report [SBCP]
You cannot certify this submission until all fields are complete.
I. General Information
1. Primary NAICS code of this facility
2. Date of last environmental compliance inspection by local, state or federal Agency:
Select year T / Select month T / If known, select day T
3. Last environmental compliance inspection was
performed by:
4. Regulatory area covered by inspection:
8.4.2. Specific Non-Compliance Information
The Specific Noncompliance Information section of the Small Business Compliance Policy
Non-EPCRA Compliance Certification form allows the certifier to describe the violation(s).
You will need to complete the fields as follows:
a. Fields 1-4: These are all text fields. Click on the field to enter data. Fields 2 and 4 include
helpt text that explain that you may include violations in statutory programs that were not
part of your submitted disclosure, provided the information submitted on this Compliance
Certification form also applies to any such newly added legal provisions.
b. Dates in questions 6 and 7: A calendar widget displays when you click on the field. The
calendar can go back months and years. You can either select a date from the calendar or
enter a date following the mm/dd/yyyy format.
c. Chemical Information: You can provide information for each chemical/pollutant being
disclosed. For more information see Section 8.4.2.1.
d. Questions 9 and 10: To complete these fields you must click on the text boxes and enter
data. You also have the option to add attachments as needed for each of these questions
(Figure 8-40).
Note: An auto-complete folder icon will display if you have entered information for previous
repo forms. When you click on the icon a list of previously entered data will display. You
can select from the list by checking on the corresponding radio button and clicking on the
"Select" button.
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Figure 8-40 II. Specific Non-Compliance Information
II. Spor if if rjoinrompliijne *» Informal ion
n«*ficrlbc? Hif violation^). Click cm the- ^^ ne-srt to i?arh flt^-lci to iMjta-complete uvltEi ctota ente-reel In previous
( 4-FtiJkritioMs.
1. Nature atirf . I. •*,. i i|»tioii
f. < ii MI i«n far 1 1 ». • i .. ,1 . MI.M! t.-.|*-i M| vioUitiort:
.3* 13* -i|nl.iT i >i y < ii.>t n >j i tor Ht*» -.t.it.- |>rn
t.-r|.«T Mil v f M vlin . .--.I .It-:
4. I'. -I lllH | II '. ivrt-.l. H 1-- L-j(l,-l .- .l[.| .li. -ll i.|, - .
f "' •
r«_-.r.i., 'ID CI-R Pail 112.
livsical location of ilio violation at tlio facility:
'• IKlll- I M .1 1. - MH| ^'' ' I *' ' -
y, 1 *. .1.- . it nfitTn** or t
l Ah-strAfl
1 1 1 jful Ji> t . antt l>.) l
I M tltMl <-ll. Tf
iMMl lay
|i>>l'PM!l 1^ | f| i 1VI* !< I"T | lll(? I M • IX I I ! I I < I t 1 H *"< I i i 1 I ^1" >1 I < •-• | I B. -V I ^. (l.ciji- ilF-ii|(
I>V tlic- ontltv to ciistiro It siiimilttetl a tlitioly cout[>tcto i>ornut
O. 1 >•-—( I ib
iivu not ytrl lj**«jn li
•-. Ji.-. In!-- -..•! Mti*i furtli
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8.4.2.1. Add Chemical
In order to add a chemical to your violation, click on the "Add Chemical" button and a group of
fields display as shown in Figure 8-41 . You can add multiple chemicals by clicking the "Add
Chemical" button multiple times. Note that the section includes a "Remove" button at the top for
you to delete an added chemical when needed.
Figure 8-41 Add Chemical
Chemical Information |
Use this button to search/find your chemical by CAS number.
a.l) Provide the chemical name (or common name
of the chemical) as provided on the MSDS:
a.2) CAS Number
b) Amount involved Ibs.
Click on the "Select" button to search for a chemical by CAS number. Additional fields display
to help you search for the chemical name as shown in Figure 8-42.
Figure 8-42 Chemical Name Look-up tool
Chemical Information £
Use this button to search/find your chemical by CAS number.
Chemical Name bromide • and/or CAS Number
Acetyl bromide (506-96-7)
Bromide (24959-67-9)
You can search for a chemical name by entering the name and/or the CAS Number. Click on the
"Find" button when ready. A list of results displays. Click on the corresponding radio button and
hit the "Select" button. Your selection displays in fields "a.l)" and "a.2)". Complete question "b)
Amount involved" by entering a numeric value in the field.
8.4.3. Audit Policy Conditions
This section is for the user to indicate if all Audit Policy conditions have been met. This section
lists a total of nine conditions as shown in Figure 8-43. Please read the instructions for each
question carefully and complete all conditions before submitting.
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Figure 8-43 III. Audit Policy Conditions
III. Small Business Compliance Policy Conditions
Criteria 1: Discovery is Voluntary * ''-=
The violation was voluntarily discovered (1st 4 boxes must be checked to qualify). *
u The violation was discovered prior to notice of an EPA or State inspection.
u The violation was not found through a legally required monitoring procedure that is required by statute,
regulation, permit, judicial or administrative order, or consent agreement.
u The violation was not found through a legally required sampling procedure that is required by statute,
regulation, permit, judicial or administrative order, or consent agreement.
u The violation was not found through a legally required auditing procedure that is required by statute,
regulation, permit, judicial or administrative order, or consent agreement.
u This facility does not meet Criteria 1.
8.4.4. Saving and Submitting
Save for Later button: This button is located at the bottom of the Compliance Certification
form as shown in Figure 8-44. The "Save for Later" button allows you to save the form if you are
not able to complete it in one session. You can access the form from the "Go To Compliance
Certification Page" hyperlink in Section 3 of the Violation Disclosure form. You can save it as
many times as needed before you are ready for submittal.
Figure 8-44 Save and Submit buttons
Save for Later HI Review & Submit
Review & Submit button: This button is located at the bottom of the Compliance Certification
Page next to the "Save for Later" button. Click on the "Review & Submit" button when you are
ready to certify compliance. Remember that all required fields must be populated before
submitting. A warning message will display on top of the form if you try to submit it without
completing the form correctly as shown in Figure 8-45.
Figure 8-45 Compliance Certification Warning Message
You cannot certify this submission until all fields are complete.
Please address the following error(s).
• Primary NAICS code must be provided.
• Date of last environmental compliance inspection is required.
• Last environmental compliance inspection was performed by is required.
» Regulatory area covered by inspection is required.
Once you fill out all fields and click on the "Review and Submit" button, you will be routed to a
read-only version of the form (Figure 8-46). This allows you to review it before submitting.
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Figure 8-46 Read Only Compliance Certification Form
CERCLA/122A Compliance Report [SBCP]
I. General Information
i. Primary NAICS code of this facility Densified wood manufacturing
2. Date of last environmental compliance inspection by local, state or federal Agency:
Year: 2012; Month: March; Day: Unknown
3. Last environmental compliance inspection was
performed by:
4. Regulatory area covered by inspection:
The bottom of the page has a Certification section (Figure 8-47). It has an "Edit" button that
allows you to go back and make changes as needed before submitting.
Read the section carefully, and when you are ready to certify compliance click on the checkbox.
The "Certify" button becomes active for you to click on it.
Figure 8-47 Certification Section
IV. Certification
Name of individual submitting this
self-disclosure:
Ms. Paulette Elvir
Current date:
9/11/2015
By checking this box, I, the person whose name is displayed above, am authorized to make this
certification and certify under penalty of the law that this document was prepared under my direction and
to the best of my knowledge and belief, the information submitted is true, accurate and complete.
Furthermore, I understand that eligibility for, and any reduction of penalties under, the EPA Audit Policy is
conditioned on the truth, accuracy and completeness of this disclosure.
An electronic signature widget displays on the screen as shown in Figure 8-48. Enter the
credentials you set up when registering with CDX. If you forgot your password you will be able
to reset by clicking on the "Forgot Password" hyperlink included in the certification section.
Enter your credentials and click on the "Sign" button.
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Figure 8-48 eSignature Widget
eSignature Widget
1. Loo In to CDX
User:
PAULETTE.ELVIR
Password:
2.Answer Secret Question
Question:
What is your favorite hobby?
Answer:
3,Sign File
•
Hobby 1
•
Once you sign, a certification confirmation screen displays indicating the compliance
certification form has been submitted as shown in Figure 8-49. It includes general information on
the form and the system's determination. It also provides a "View Report" button to access a
read-only version of the submitted compliance certification form.
Figure 8-49 Certification Confirmation
MyCDX
Inbox
My Profile
Violation Disclosure 1 1 Compliance Certification
Disclosure Search 1 1 Sharing
Manage Facilities
You are here: MvCDX» Certified
Compliance Certification
Disclosure Name
Policy
Statute/Section
Compliance Report ID
CROMERR Activity ID
Signature Date
CE-158 SBCP
Small Business Compliance Policy
CERCLA / 122L
1083
_2bf637el-9d6e-44b7-ac77-0829c570b35f
11/5/2015
Thank you for certifying compliance. Based on the information that you submitted, the eDisclosure system is issuing an
Acknowledgement Letter for the disclosed violation(s) and sending it to the e-mail address(es) that you registered in the
eDisclosure system. If you do not receive such an e-mail within 1 hours, please contact the eDisclosure Help Desk. If you wish to
view this Acknowledgement Letter in the eDisclosure system, please click here.
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8.5. Compliance Certification Tab
The Compliance Certification page displays two tables. The first table includes disclosures that
have Compliance Certification forms that are complete and ready for certification. The second
table includes disclosures with Compliance Certification forms that are not yet complete (Figure
8-50).
Figure 8-50 Compliance Certification Tab
MyCDX Inbox My Profile Violation Disclosure
Compliance Certification
Disclosure Search Sharing Manage Facilities
You are here: MvCDX» Compliance Reports
The following disclosures have Compliance Certification forms that are complete and ready for certification. You can review
certifications individually by clicking on the Go To Compliance Certification hyperlink. Alternatively, check the boxes for those that
you wish to certify as a batch and click on the Review & Certify button (note, on the next screen you will be given an opportunity
to review all of them prior to certification).
Compliance Certification Forms Ready for Review and Submittal
Expand all CollBese all
Seise: n
Disclosure Crojp Name
Violation
D ;; :• .'en.1 3 = Te
Disdosure
Submission
Date
Status
Available Actions
Audit Policy Disclosure
In Progress • Disclosure(s) &
Compliance Certification.!5)
Pending
Details
Review & Certify
The Compliance Certification forms for the following disclosures are not complete. They must be completed before they are ready
for certification. This must be done individually, by clicking on the Go To Compliance Certification hyperlink for the specific
disclosure desired.
Compliance Certification Forms that Need to be Finished
Expand all Collapse all
Disclosure Croup Name
^ Extension Page
»> Test CE-158
» CE-127Test
»• Test PD 01
>• CE-1Z1 SBCP
> Audit Policy Disclosure
Violation Disclosure
Discovery Dmt« Submission Date
Status
In Progress - Compliance
Certifications) Pending
In Progress - Compliance
Certifications) Pending
Available Actions
• Details
. Details
in Progress - Compliance • Details
Certification(s) Pending
In Progress - Compliance
Certification^) Pervding
In Proaress - Compliance
Certifications) Pending
In Progress - Disclosure^) &
Compliance Certifications) Pending
. Details
• Details
. Details
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8.5.1.
Review and Submittal
Compliance Certification Forms Ready for
Click on the "Expand All" hyperlink to get a detailed view of the disclosures included in the
table. You can also expand a specific disclosure by clicking on the arrow key on the left side of
the disclosure name. Note that the Available Actions column includes two different hyperlinks at
the section level: "Go To Compliance Certification Page" and "Review and Certify Compliance"
as shown in Figure 8-51.
Figure 8-51 Compliance Certification Forms Ready for Review and Submittal
Compliance Certification Forms Ready for Review and Submittal g
Euandall Collins* all
Select Violation Disclosure
A'l Disclosure Croup Name Discovery Submission Status Available A
Date Date
ctions
M T CE 121 SBCP Ir> Pr°8ress - Compliance • DeBit
Certification(s) Pending
T Disclosure Group 1
T BALTIMORE COUNTY RECREATION & PARKS (BALTIMORE, MD 212360000)
v Clean Air Art (CM)
• Go TD
Complia
Ambient Air Quality Standards (Tribal implementation Plan for Due 01/03/16 [59 Days] • Reyiew
National Primary and Secoixiary Ambient Air Quality Standards) -:J'^i?
In Progress-
0 T Audit Poli,, Disclosure £*«*> *
Certification(s) Pending
T Disclosure Groi-p 1
T BALTIMORE COUMTY RECREATION & PARKS (BALTIMORE, MD 212360000)
T Emergency- Planning and Community Right-to-Know Act (EPCRA)
nee
tier, P-3'je
& Certify
nee
• Go To
Compliance
311 Material Safety Data Sheets (MSQS) (Material bafety Data 10/01/15 10/05/15 Due 12/04/15 [29 Days] • Review & Certify
Sheets (MSDS)) Compliance
rife
• Review (V Certify •££•
The "Go To Compliance Certification Page" hyperlink takes you the editable version of the form
and allows you to make additional changes. The "Review and Certify Compliance" link routes to
a read-only version of the form that is ready for certification (Figure 8-52). Both links review
certifications individually.
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Figure 8-52 Review and Certify Compliance
CAA/l 10 Compliance Report [SBCP]
I. General Information
1. Primary NAICS code of this facility
Chrome pigments (e.g., chrome green, chrome orange, chrome yellow) manufacturing
2. Date of last environmental compliance inspection by local, state or federal Agency:
Year: 2013; Month: March; Day: 11
3. Last environmental compliance inspection was tester abc
performed by:
4. Regulatory area covered by inspection: area 123
If you wish to certify multiple forms as a single batch, check the boxes under the "Select All"
column for those you wish to certify and click on the "Review and Certify" button as displayed
in Figure 8-53.
Figure 8-53 Certifying Multiple Compliance Certification Forms
^^^^— Compliance Certification Forms Ready for Review and Submit! aJ
Expand all Collapse alt
Set
A
a« Violatjon
1 Disclosure Group Name DISCOVER
Date
U T CE-121 SBCP
T Disclosure Group 1
T BALTIMORE COUKTY RECREATION & PARKS (BALTIMORE, MD 2123&DOGO)
t '
|
V Clean Air Act (CAA)
IH 110 Implementation Plan for National Primary and Secondary m/m/i
Ambient Air Quality Standards (Tribal Irr-plerrertation Plan for «V<"/1
National Primary and Secondary Ambient Air Quality Standards)
J v Audit Policy Disclosure
Disclosure
Submission Status Available Ac
Date
In Progress - Compliance " Detail
Certification! s) Pending
• Go To
Comdiar
in/ncnc rnmpli*rv^ OrrifiraHon Certifies
tions
E6
ion Paqe
Due 01/03/16 [59 Days] • Review & Certify
Compliance
In Progress -
Disclosure^) & • Details
Compliance
Certification(s) Pending
T Disclosure Group 1
1
T BALTIMORE COUrfTY RECREATION & PARKS (BALTIMORE, MD 212360000)
V Eirergertv Planning and Community Right-to-Kncw; Act (EPCRA)
t !* 311 Material Safety Data Sheets (MSDS) (Material Safety Data 10/01/1
Sheets (MSDS))
« Go To
.' _.-,•..;.-.
,„•„,-,„- rnmpliarw-o rortifiration Ceitifica
£§
k: •" :•
iu/<»M3 Due iyM/15 [29 Days] . Review a Cgrtitv
II Review & Certify IKJI
1
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The following screen allows you to review the selected form prior to certification. You can use
the scroll bar to review the forms or you can also click on the links on the top of the screen to
scroll to a specific form (Figure 8-54). Note that there is a pencil icon next to each Compliance
Certification link. Clicking on the icon will take you to the editable version of the form in case
you wish to make additional changes before certifying.
Figure 8-54 Review Screen for Batch Certification
N
X
MyCDX Inbox
You are here
My Profile Violation Disclosure | | Disclosure Search
MyCDX» Compliance Report Certification
Sharing
Manage Facilities
Compliance Report Certification
The following compliance reports will be certified.
. » EPCRA/311 Compliance Report for BALTIMORE COUNTY RECREATION & PARKS (BALTIMORE, MD 212360000) Facility
[EPCRA Audit Policy] f
• • CAA/110 Compliance Report [SBCP] f
EPCRA/31 1 Compliance Report for BALTIMORE COUNTY RECREATION & PARKS (BALTIMORE, MD
Facility [EPCRA Audit Policy] f
212360000)
1. General Information
1. Primary NAICS code of this facility
Boxes, wood, plain or fabric covered, nailed or lock corner, manufacturing
2. Date of last environmental compliance inspection by local, state or federal Agency:
Year: 2015; Month: April;
Day: 11
3. Last environmental compliance inspection was tester abc
performed by:
4. Regulatory area covered by inspection: area 123
II. Specific Noncompliance Information
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Click on the "Certify" button at the bottom of the screen when you are ready to certify all
selected forms.
Figure 8-55 Section IV. Certification
IV. Certification
Name of individual submitting this self-disclosure: |V|rs. Paillette Elvir
Current date: 11/5/2015
0 By checking this box, I, the person whose name is displayed above, certify under penalty of the law that
this document was prepared under my direction and to the best of my knowledge and belief, the
information submitted is true, accurate and complete. Furthermore, I understand that eligibility for, and
any reduction of penalties under, the EPA Small Business Compliance Policy is conditioned on the truth,
accuracy and completeness of this disclosure.
I Forgot your password?
An electronic signature widget displays on the screen as shown in Figure 8-56. Enter the
credentials you set up when registering with CDX. If you forgot your password you will be able
to reset by clicking on the "Forgot Password" hyperlink included in the certification section.
Enter your credentials and click on the "Sign" button.
eSignature Widget
1.Log in to CDX
User:
PAULETTE. ELVIR
Password:
•••••••••••
Welcome Paulerte EK'"
Figure 8-56 eSignature Widget
2.Answer Secret Question
Question:
What is your favorite hobby?
Answer:
Hobby 1
3.Sign File
Answer
Once you sign, a certification confirmation screen displays indicating that the compliance
certification form has been submitted as shown in Figure 8-57. It includes information on the
system's determination for each of the forms included in the batch certification. It also provides
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hyperlink to access a read-only version of the submitted compliance certification forms. You will
receive a confirmation email with the system determination for all certified forms.
Figure 8-57 Certification Confirmation
MyCDX Inbox My Profile Violation Disclosure I I Disclosure Search Sharing Manage Facilities
You are here: MvCDX» Compliance Report(s) Certified
Certified
The following compliance reports were certified.
. EPCRA/311 Compliance Report for BALTIMORE COUNTY RECREATION & PARKS (BALTIMORE, MD 212360000) Facility [EPCRA
Audit Policy] - NoticeOfDetermination ^^^^™
• CAA/11Q Compliance Report [5BCP] - AcknowledgementLettei
Acknowledgment letters issued: 1
Electronic Notice of Determinations issued: 1
8.5.2. Compliance Certification Forms that Need
to be Finished
The second table in the Compliance Certification tab provides another alternative way to access
compliance certification forms other than the Violation Disclosure landing page. Click on the
"Expand All" hyperlink at the top of the table to get a detailed view of the disclosures in the
table. You can also expand a specific disclosure by clicking on the arrow key on the left side of
the disclosure name.
Click on the "Go To Compliance Certification Page" hyperlink to open a compliance
certification form as shows in Figure 8-58.
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Figure 8-58 Compliance Certification Forms that Need to be Finished
Compliance Certification F
Expand;
Disclosure Croup Name
T Extension Page
T Disclosure Group 1
T RESERS FINE FOODS (BEAVERTON, OR 97005)
V Clean Air Act (CAA)
110 Implementation Plan for National Primary and Secondary Ambient
Air Quality Standards (Tribal Implementation Plan for National
Primary and Secondary Ambient Air Quality Standards)
T Disclosure Group 3
T RESERS FINE FOODS (BEAVERTON, OR 97005)
T Resource Conservation and: Recovery Act (RCRA)
3002 Standards Applicable to Generators of Hazardous Waste (Gen
Hazardous Waste Management - Subtitle C - SQG)
orms that
II Collaps* all
Violation
Discovery
Date
10/08/15
Need to t»
Disclosure
Submission
Date
' '
10/29/15
» Finished
Status
£Sfl&?S±r
Compliance Certification
Due 12/28/15 [53 Days]
Compliance Certification
^^B
Available Actions
• Details
• Go To Compliance
Certifr --•*-' •! ?'---^
• Go To Compliance
Certification Paqe
1
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The "Go to Compliance Certification Page" link will open up the compliance certification form
as displayed below in Figure 8-59. To complete the form, follow the steps specified in section
8.1 through 8.4
Figure 8-59 Compliance Certification Form
MyCDX Inbox My Profile
Violation Disclosure
Compliance Certification'
Disclosure Search
Sharing I Manage Facilities
You are here: MvLDX» New: CAA/110 Compliance Report [Audit Policy]
CAA/110 Compliance Report [Audit Policy]
You cannot certify this submission until all fields are complete.
I. General Information
Click on the (^ next to each field to auto-complete with data entered in previous compliance certifications.
1. Primary NAICS code of this facility 'Mb ~~
2. Date of last environmental compliance inspection by local, state or federal Agency:
ft Select year T / I Select month T / If known, select day T
3. Last environmental compliance inspection was
performed by:
4. Regulatory area covered by inspection:
II. Specific Noncompliance Information
Describe the violation(s). Click on the (^ next to each field to auto-complete with data entered in previous compliance
certifications.
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9. System Determinations
When Compliance Certifications are submitted, the system will make a determination that will
be displayed in the Certification Confirmation screen once you sign the compliance certification
form. Violation disclosures that are not submitted in a timely manner will also trigger a
systematic response sent to the user. The system will send out an email with additional
information indicating the issuance of one of the following letters:
• Ineligibility Due to Untimely Disclosure
• Not Eligible for Category 1 or Category 2
• Ineligibility Due to Timeout of a Compliance Certification Form
• Electronic Notice of Determination (eNOD)
• Acknowledgement Letter
9.1. Ineligibility Due to Untimely Violation Disclosure
If the user fails to disclose a violation within the required 21 days of discovery, the system
updates the status to "Ineligibility Letter Issued (MM/DD/YY)" immediately after the user clicks
on the "Submit Selected Disclosures" button. The Available Actions column will include a
hyperlink to the ineligibility letter. The system will also generate an email notification to the
user.
This determination will include the following text:
PLEASE NOTE: The date of this disclosure is more than 21 days after discovery of the
potential violation(s). Therefore, this disclosure is not eligible to receive an electronic
Notice of Determination (eNOD) or Acknowledgement Letter (AL). EPA will retain a
record of the disclosure and any potential further interaction with EPA concerning this
matter will occur outside the eDisclosure system. In the event of an enforcement action,
EPA will take into account all relevant facts and circumstances surrounding any violations,
including the voluntary nature of your disclosure submitted through this system.
9.2. Not Eligible for Category 1 or Category 2
There are cases where the user submits a fully completed timely disclosure and compliance
certification, but does not meet the required conditions to qualify for Category 1 or Category 2.
The system generates a response immediately after the user signs and submits the Compliance
Certification. The system updates the status to "Ineligibility Letter Issued (MM/DD/YY)". The
Available Actions column will include a hyperlink to the ineligibility letter as shown in Figure
9-1. The system will also generate an email notification to the user that will include the
following text:
PLEASE NOTE: Based on the information that you submitted, this disclosure is not
eligible to receive an electronic Notice of Determination (eNOD) or Acknowledgement
Letter (AL). EPA will retain a record of the disclosure and any potential further
interaction with EPA concerning this matter will occur outside the eDisclosure system. In
the event of an enforcement action, EPA will take into account all relevant facts and
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circumstances surrounding any violations, including the voluntary nature of your
disclosure submitted through this system.
Figure 9-1 Ineligibility Letter
Select
All
D
Disclosure Group Name
Violation
Discovery
Date
T Disclosure Group 1
Disclosure
Submission
Date
Status
v APPLIED SCIENCE AND TECHNOLOGY (SPRINGFIELD, VA 22153)
v Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
Acknow ledgement
103A Notification of Hazardous Reportable 10/20/15 10/27/15 Letter Issued
Quantity Release (Reporting and Access) 10/27/15
T Emergency Planning and Community Right-to-Knovj Act (EPCRA)
311 Material Safety Data Sheets (MSDS)
(Material Safety Data Sheets (MSDS))
10/20/15
10/27/15
[neligibility Letter
Issued on 10/27/15
Available Actions
• Go To Compliance
Certification Page
• View Acknowledgement
Letter
• View Ineligibility Letter ^
9.3. Ineligible Due to Timeout of a Compliance Certification Form
If the user fails to timely certify compliance, the system will deem the violation as not eligible
for Category 1 or Category 2. The system updates the status to "Ineligibility Letter Issued
[dd/mm/yyyy]" once the compliance certification deadline has passed. The Available Actions
column will include a hyperlink to the ineligibility letter. The system generates a response by
email that includes the following text:
PLEASE NOTE: EPA records indicate that the deadline for certifying compliance for the
above-cited disclosure(s) has passed. Therefore, the above-cited disclosure(s) is/are not
eligible to receive an electronic Notice of Determination (eNOD) or Acknowledgement
Letter (AL). EPA will retain a record of such disclosure(s) and any potential further
interaction with EPA concerning such matter(s) will occur outside the eDisclosure
system. In the event of an enforcement action, EPA will take into account all relevant facts
and circumstances surrounding any violations, including the voluntary nature of your
disclosure(s) submitted through this system.
9.4. Electronic Notice of Determination (eNOD)
When the user certifies compliance in a timely manner and meets conditions that qualify the
violation disclosure as Category 1, the system will generate an eNOD. Category 1 applies to
EPCRA violations that meet all Audit Policy conditions and EPCRA violations that meet all
Small Business Compliance Policy conditions. It does not include CERCLA 103/EPCRA 304
chemical release reporting violations and EPCRA violations with significant economic benefit
(as defined by EPA).
Disclosers receiving an eNOD will see a confirmation message with the following text:
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Thank you for certifying compliance. Based on the information that you submitted, the
eDisclosure system is issuing a Notice of Determination (NOD) for the disclosed violation(s)
and sending it to the e-mail address (es) that you registered in the eDisclosure system. If
you do not receive such an e-mail within one hour, please contact the eDisclosure Help
Desk. If you wish to view this NOD in the eDisclosure system, please click here.
The system also generates an official Notice of Determination letter, confirming that the
violations are resolved with no assessment of civil penalties, conditioned on the accuracy and
completeness of the submitter's eDisclosure. The Available Actions column will include a
hyperlink to the Notice of Determination letter and the Status column will reflect an updated
status of Notice of Determination Issued (MM/DD/YY) as shown in Figure 9-2.
Figure 9-2 Notice of Determination
Select
All
U
Disclosure Croup Name
T Disclosure Group 1
Violation Disclosu
Discovery Submissi
Date Date
T VINTAGE 2 (CHESTER, VA 23836)
T Emergency Planning and Community Right-to-Know Act (EPCRA)
313 Toxic Chemical Release Reporting (TRI) 09/10/15 09/30/
(Toxics Chemical Release Inventory (TRI))
T Disclosure Group 2
re
jn Status
Notice of
15 Determination
Issued 09/30/15
v AMERICAN ENERGY RESTAURANT EQUIPMENT (SPRINGFIELD, VA 22153)
T Emergency Planning and Community Right-to- Know Act (EPCRA)
Notice of
313 Toxic Chemical Release Reporting (TRI) 09/15/15 09/30/15 Determination
(Toxics Chemical Release Inventory (TRI)) Issued 10/01/15
Available Actions
• Go To Compliance
Certification Page
• View Notice of
Determination Letter ^™
• Go To Compliance
Certification Page
• View Notice of .
Determination Letter
9.5. Acknowledgement Letter
When the user certifies compliance in a timely manner and meets conditions that qualify the
violation disclosure as Category 2, the system will generate an Acknowledgement Letter.
Category 2 includes all Non-EPCRA violations; EPCRA violations where the discloser can only
certify compliance with Audit Policy Conditions 2-9 (i.e., discovery was not systematic); and
EPCRA/CERCLA violations excluded from Category 1.
Disclosers receiving an Acknowledgement Letter will see a confirmation message with the
following text:
Thank you for certifying compliance. Based on the information that you submitted, the
eDisclosure system is issuing an Acknowledgement Letter for the disclosed violation(s) and
sending it to the e-mail address (es) that you registered in the eDisclosure system. If you do
not receive such an e-mail within one hour, please contact the eDisclosure Help Desk. If
you wish to view this Acknowledgement Letter in the eDisclosure system, please click here.
The system also generates an official Acknowledgment Letter, noting EPA's receipt of the
disclosure and promising that EPA will make a determination as to eligibility for penalty
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mitigation if and when it considers taking enforcement action for environmental violations. The
Available Actions column will include a hyperlink to the Acknowledgement Letter and the
Status column will reflect an updated status of Acknowledgement Letter Issued (MM/DD/YY) as
shown in Figure 9-3.
Figure 9-3 Acknowledgement Letter
Select
All Disclosure Croup Name
a
T Disclosure Group 1
Violation
Discoverv
Date
Disclosure
Submission
Date
Status
T APPLIED SCIENCE AND TECHNOLOGY (SPRINGFIELD, VA 22153)
v Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
103A Notification of Hazardous Reportable 10/20/15 10/27/15
Quantity Release (Reporting and Access)
T Emergency Planning and Community Right-to-Know Act (EPCRA)
311 Material Safety Data Sheets (MSDS) 10/20/15 10/27/15
(Material Safety Data Sheets (MSDS))
Acknowledgement
Letter Issued
10/27/15
Inedibility Letter
Issued on 10/27/15
Available Actions
• Go To Compliance
Certification Page
• View Acknowledgement ^
Letter
• View Ineliqibilitv Letter
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10.
Sharing Violation Disclosures
The Sharing tab allows the user to share a violation disclosure with other individuals in cases
where additional input is needed. It also provides the flexibility for a user to start a violation
disclosure and share access when another person will be certifying.
The tab has an Open Disclosures table that displays all open violations for a specific user. The
table follows the same format as the other tables in the system. It displays violations in bundles
and includes arrows so you can expand to see more information on a particular disclosure. It also
includes general information like the Disclosure Initiation Date and the current status as shown
in Figure 10-1.
Figure 10-1 Sharing Tab
MyCDX | Inbox | My Profile 1 1 Violation Disclosure 1 1 Compliance Certification | Disclosure Search | QJ 8JI Manage Facilities
You are here: MvCDX» Sharing
The Open Disclosures and Closed
share with other users. This includes \
Click on the List hyperlink in the Shaft
one or more e-mail addresses. To sha
You may revoke a shared user s acces
remove all shared access by clicking o
^^^^^^^^^^M
Disclosures tables below show all the violation disclosures that are available for you to
'our disclosures and any disclosures that others have shared with you.
re all Disclosures, click on the Share All button in the appropriate table(s) below.
s by clicking on the List hyperlink in the Share With column and removing a user or you may
n the Revoke All button in the Open Disclosures or Closed Disclosures table(s).
^^ Cijlmf M
, „ Disci
tsITK Instiati
Test Mo Facility 11/0
Extension Page 1O/2
Test CE-15S 10/2
CE-136 1O/2
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4/15 In Proaress - Compliance Certifications) Pending Details List
9/15 In Progress - Compliance Certification(s) Pending Details List
7/15 In Progress - Compliance Certification(s) Pending Details List -li-
e/IB In Progress - Disclosure^) & Compliance Certification(s) Pending Details List
CE-127 Test 1O/26/15 In Progress - Compliance Certifications) Pending Details List
CE-1O3 1O/26/15 In Progress - Disclosure{s) & Compliance Certification(s) Pending Details List -i"-
Test ABC 1O/14/15 In Progress - Disclosure(s) & Compliance Certification(s) Pending Details List
Test PD 01 10/14/15 In Progress - Compliance Certification(s) Pending Details List
CE-121 SBCP 10/05/15 In Progress - Compliance Certifications) Pending Details List
Audit Policy Disclosure 10/05/15 In Progress - Disclosure(s) & Compliance Certifications) Pending Details List
BBB,* EM*
The table below shows all of the closed disclosures.
II Closed Disclosures 1
IX^dll C.IU^.11
Disclosure Name j Disclosure Initiation Date | Status | Available Actions | Share With 1 Shared
No Disclosures Found
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The sharing will take place by providing the email addresses of the people with whom the user
wants to share a violation disclosure. Click on the "List" hyperlink in the "Share With" column.
A pop-up message displays where you can enter one or more email addresses (Figure 10-2).
Enter an email address in the field and click on the "Add" button. Repeat if you wish to add more
email addresses to the list. Once you are ready to share, click on the "Save Changes" button in
the pop-up window, the system will provide an additional message asking you to confirm your
selection. When you confirm, you will have shared the violation disclosure with the selected
individuals. The system will send out an email to both the person sharing the violation disclosure
and the person(s) receiving access. Once the new user(s) have access, they will have the same
privileges as the original discloser.
Figure 10-2 List Pop-up
Manage Emails
Use the field below to add email addresses of the user(s) with
whom you wish to share the disclosure(s). Note: A user must
have a CDX account to view/ your disclosure. They will receive an
email with instructions on how to access.
Email: Email Address
Below are the email addresses able to view and edit the
disclosure(s). Revoke any by clicking the X.
Emails
A paulette.elvir@cgifederal.com
You will also have the option to share all of your open violations by clicking on the "Share All"
button. The "Revoke All" button revokes access previously granted by the sharer. The system
will also send out an email to both the person sharing/revoking the violation disclosure and the
person(s) receiving/losing access.
The second table in the Sharing tab is titled "Closed Violations" and it lists disclosures that have
reached a resolution. You have the option to share these disclosures by clicking on the "List"
hyperlink in the "Share With" column. You will not be able to edit the record since the
disclosure has been completed.
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