Methodology & trust

How every reported kilogram stays reproducible

PackClose connects each total to its source, calculation, owner, and exact workpaper version. That gives finance repeatable math, gives compliance a faster validation response, and gives the next owner a clean handoff.

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

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

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

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

What we deliberately do not do

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

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

How customer data is handled

No consumer-AI processing

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

Controls before any real data

Before any customer document enters the workspace, a binding checklist applies: accepted workspace terms and data authorization, an approved commercial no-training AI path (or none), an isolated workspace, MFA, least-privilege access, encryption, access and audit records, active-content screening before storage, and backup/recovery. Optional services add their own agreement, authorization, and recorded internal-QA scope.

Retention with a purpose

The QA-checked workpaper, substantiation pack, source inventory (with hashes), and full version history are retained under the workspace's configured schedule or the optional engagement's agreed retention period - and everything is exportable to you on demand.

Deletion, honestly stated

When an account or engagement ends, data remains exportable for the stated availability window and is deleted under the applicable retention/deletion procedure. One honest caveat: an active retention obligation or legal hold blocks deletion until it lapses - and that block is itself recorded, not silent.

The review model: recorded decisions, attributed people

Software surfaces problems; it never decides them. Every material decision passes through an attributed person whose role and reasoning are on the record. In the self-serve workspace, that person is on your team; an optional service names its engagement lead without implying a professional reviewer who has not been contracted.

ElementHow it works
Who checks the workSelf-serve records are reviewed and approved by the people you authorize. Scan and close workpapers are additionally checked against our documented internal QA checklist by the engagement lead before delivery. No qualified reviewer is presumed; qualified professional review is not bundled into the workspace or initial scan.
Recorded decisionsWho decided, what they decided, the basis, and the date - captured for every resolution, approval, and correction, in an append-only audit log.
Separation of eventsWhen internal service QA is present, it and your data approval are separate recorded events on the workpaper version - separate actors and timestamps, never merged.
Blocking checksA field with no source document, or with unresolved divergence between sources, cannot be approved. The queue stays visible until an authorized person resolves it with an attributed rationale; nothing is waved through.
Your decisions stay yoursProducer status, exemptions, and what to submit are decisions you make with your reviewer or counsel. We record the decision, its basis, and its date - we never compute it.

Trust & security: the honest current state

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

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

Workspace support covers technical and how-to questions by email, targeted within two business days; it is not a response-time SLA or included consulting. Optional-service delivery commitments are stated in the accepted engagement agreement. We never guarantee a regulatory outcome, agency acceptance, or supplier behavior.

Frequently asked questions

How do you keep dates and status current?

CAA’s calendar is a planning source, not a universal filing ledger. During workspace setup or the start of an optional engagement, PackClose separates producer-to-PRO actions from state-agency filings, then verifies the current registration, report, fee, correction, adjustment, and receipt status for each legal entity and state. Oregon and Colorado are operating programs; California’s regulations are effective while its program-plan process continues. The workpaper preserves the official source and check date behind every account-level status, and never turns a published planning date into an unsupported claim that a filing, invoice, or account-level action occurred. Sources were rechecked 2026-09-04: CAA resource center, Oregon DEQ, and CalRecycle source-reduction guidance.

Do you submit our reports in the portal?

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

Who decides producer status and exemptions?

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

Do you calculate or optimize our fees?

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

Which states do you cover?

The PackClose Workspace maintains evidence and calculations for Oregon, Colorado, and California. Optional Full Data Close services use the same state scope; the fit check confirms the smallest useful hands-on scope before an agreement or invoice.

Can numbers change after sign-off?

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

Is my data used to train AI models?

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

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

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

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