Helpful Hints for CDX Registration and Submission of e-PMN

Helpful Hints
for
CDX Registration and Submission of e-PMN

Prepared by:

October, 2009

Office of Pollution Prevention and Toxics
US Environmental Protection Agency

CDX: Helpful Hints

Oct 2009

Disclaimer: This Helpful Hints document is not a rule and is not legally enforceable. The
document explains some of the electronic reporting requirements in 40 CFR parts 720, 723 and
725 applicable to documents submitted pursuant to those provisions. The document also
discusses recommended practices for such submission. The document neither creates any new
requirements nor replaces existing established laws or regulations. The use of the word "should"
in this document means that something is suggested or recommended, but not required.

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TABLE OF CONTENTS

Who needs to register .............................................................................. 4
1.
2.
3.
4.
5.
6.
7.

Who needs to register with CDX? ...................................................................................... 4
Who is an Authorized Official? .......................................................................................... 4
Who is a Support Registrant? ............................................................................................. 4
For an Authorized Official, how do I see all my Support Registrants? .............................. 4
For a Support Registrant, how do I see all of my Authorized Officials?............................ 4
Do I need to register for every Authorized Official? .......................................................... 4
If I previously registered for eIUR 2006, will I need to re-register for e-PMN? ................ 5

How to Register........................................................................................ 5
8.
9.
10.
11.
12.
13.
14.

When do I need to register for a CDX account? ................................................................. 5
Where do I go to register for a CDX account? ................................................................... 5
How do I register in CDX? How do I register for electronic submissions? ...................... 5
How do I know if my Registration Request has been approved? ....................................... 6
How do I add another role? ................................................................................................. 6
If my Authorized Official leaves, how will I know? .......................................................... 6
Do I need to resubmit an ESA once I have been approved? ............................................... 7

The submission process- the CDX Node within the e-PMN tool ........ 7
15. After Registration and EPA approval, what happens next? ................................................ 7
16. How will I know if there is an error during electronic submission? ................................... 7
17. How can I tell if the electronic submission has gone through successfully? How long will
I have to wait for a reply? ................................................................................................... 7
18. How will I know if there is something waiting for me in CDX?........................................ 7
19. What is the Copy of Record? .............................................................................................. 7

CDX Registration Maintenance ............................................................. 8
20. How do I make changes to a registration? .......................................................................... 8
21. How do I remove my account from CDX? ......................................................................... 8

Submitter Use of the Tool/Submitter Responsibility ........................... 9
22.
23.
24.
25.
26.

Can I share my User ID and password with others in my company? ................................. 9
Can I submit documents from more than one computer? ................................................... 9
Can more than one person use the same computer to submit via CDX? ............................ 9
Should I leave the Copy of Record in CDX? ...................................................................... 9
Can others review information on the submission before I send it electronically? ............ 9

General ................................................................................................... 10
27. Can I submit TSCA Confidential Business Information? Will it be protected? .............. 10
28. How do I get help if I need it? .......................................................................................... 10

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Who needs to register
1. Who needs to register with CDX?
There are two types of registered persons who will be able to submit documents
electronically via CDX: those who are authorized to legally sign the PMN form or other notices
(the Authorized Official); and those who are designated and approved by the Authorized Official
to submit support documents. Persons who prepare draft versions of Section 5 Notices and
Notice supporting documents need not register.
2. Who is an Authorized Official?
An Authorized Official is a person in a company legally responsible for the data in the notice
submission. Generally, this would be the person who signs the certification page on the paper
version of the PMN form. Under CROMERR, the person who submits a document via CDX is
equivalent to the person whose wet ink signature is on the PMN form.
3. Who is a Support Registrant?
A Support Registrant is a person designated by an Authorized Official to submit supporting
documents in his/her behalf. The Support Registrant can be another person from the Authorized
Official’s company or they can be an agent or consultant from outside the company.
4. For an Authorized Official, how do I see all my Support Registrants?
There is a link on the MyCDX website in CDX Registration for Authorized Officials to view
all the Support Registrants linked to their UserID. The view lists the Support Registrant personal
information and their registration status. MyCDX is the default site in CDX Registration after a
submitter has registered as either a Support Registrant or an Authorized Official.
5. For a Support Registrant, how do I see all of my Authorized Officials?
There is a view called List Roles in CDX Registration. In this view, the registrant can see
his/her roles, the status of his/her roles, and the Program IDs for the Authorized Officials. By
clicking on the Program ID, a pop-up window will display the Authorized Officials information.
This view can be found by selecting the link “Edit Current Account Profiles” in the MyCDX
website. MyCDX is the default site in CDX Registration after a submitter has registered as
either a Support Registrant or an Authorized Official.
6. Do I need to register for every Authorized Official?
Yes. A Support Registrant will have to register and be approved for every Authorized
Official that he/she will be sending documents on their behalf. A separate Verification form
(“Authorization and Verification for Section 5 Notice Support Submitter by Company
Authorizing Official”) is needed for each Authorized Official/Support Registrant relationship.
The Support Registrant only needs one signed and notarized Electronic Signature Agreement
form on file at EPA though he/she may be working for many Authorized Officials.

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7. If I previously registered for eIUR 2006, will I need to re-register for e-PMN?
Yes, you will have to completely re-register for e-TSCA in CDX. This includes sending the
signed and notarized new Electronic Signature Agreement form and a signed Verification form
to EPA.

How to Register
8. When do I need to register for a CDX account?
If you are planning to submit a document created by the e-PMN software to EPA using CDX,
you will need to register in advance of submitting a document. It will take several days
(typically 5-10 business days) for the registration process to be completed once EPA has
received the signed and notarized documentation. Once EPA has approved the account and the
20-5-1 security questions have been answered, your CDX account will become active and you
will be able to submit documents via CDX.
9. Where do I go to register for a CDX account?
The address for registering with CDX is http://cdx.epa.gov/epa_home.asp. There are two
additional places where you can find a link to the CDX website: in the e-PMN software home
page and through the EPA’s New Chemicals Program website.
10. How do I register in CDX? How do I register for electronic submissions?
Registration is a multi-part process: (1) basic registration information; (2) Electronic
Signature Agreement and Verification Forms; (3) e-mail announcing account activation; and
then (4) completion of the 20-5-1 Security Questionnaire.
Step 1) For the basic registration information, you will be prompted for the following:
Full name;
User ID (“User Name”/Login Name);
Password;
Formal company name where you are employed
(E.g. not merely “Test”, but “Test Chemicals Inc.”);
Company address (two lines are provided);
Your corporate phone number;
Your corporate e-mail address
Please note that the information provided in CDX Registration must agree with the
contact information in the submission documents.
Step 2) The three forms are the e-TSCA Electronic Signature Agreement (ESA) and the
Verification forms (one for Authorized Official and one for a Support Registrant). The ESA
contains information entered in CDX registration along with terms of the agreement, the
submitter’s signature and the signature of a notary public. This form is the main registration
form for CDX. The Verification form contains the signed statement that the data is accurate and
truthful. Once these forms have been printed and signed, mail them back to the following

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address:
By U.S. Postal Service: PMN CDX Registration Coordinator (7407M), U.S. Environmental
Protection Agency, Office of Pollution Prevention and Toxics, Ariel Rios Building, 1200
Pennsylvania Ave, NW, Washington, DC 20460.
By Hand Delivery or Courier: PMN CDX Registration Coordinator, U.S. EPA- OPPT/CBIC,
EPA East Building, Room 6428, 1201 Constitution Ave, NW, Washington, DC 20004-3302,
202-564-8930; 202-564-8940.
Step 3) EPA will approve your registration account when it receives these forms and verifies the
information on them with the information in the CDX registration data base. EPA will then send
an e-mail to the user’s corporate e-mail address to notify them of this and to instruct them to log
back into the registration data base and complete the 20-5-1 Questionnaire.
Step 4) The “20-5-1 Questionnaire” is a special security feature that helps to ensure your identity
in CDX. Many other commercial and government web sites are also using this feature. You will
be given a list of 20 personal knowledge questions (“Favorite Color”, “Name of Pet”, “Mother’s
Name”, etc). You will be able to select and answer five of these questions from this list. Once
the questions have been completed, your account is activated and you may submit documents to
the EPA via CDX. Whenever you log into CDX or use CDX to transmit submissions
electronically to EPA, you will be prompted with one randomly selected question of the five you
answered during registration.
11. How do I know if my Registration Request has been approved?
After EPA has approved and activated the registrant’s request, CDX will send the registrant a
generic e-mail which states that an account has been approved. To verify which account was
approved, the registrant will need to go to the CDX Registration view called List Roles. In this
view, the registrant can see his/her roles, the status of his/her roles, and the Program ID for the
Authorized Official associated with that account. The status will either be Awaiting Approval,
Active, or Deactivated. When the status is “Active”, the registrant may submit under that role.
12. How do I add another role?
There is a view called List Roles. In this view, the registrant can see his/her roles, the status
of his/her roles, and the Program IDs for the Authorized Officials. Under the roles is a link to
“Add New TSCA Role/Program ID”. After selecting this link, a webpage will appear where the
role of Authorized Official or Support Registrant may be selected.
13. If my Authorized Official leaves, how will I know?
There is a view called List Roles. In this view, the registrant can see his/her roles, the status
of his/her roles, and the Program IDs for the Authorized Officials. The status will either be
Awaiting Approval, Active, or Deactivated. If an Authorized Official has been deactivated, the
Support Registrants associated with this Authorized Official will have their role for this Official
deactivated.

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14. Do I need to resubmit an ESA once I have been approved?
An Electronic Signature Agreement (ESA) only needs to be submitted and approved by EPA
once. If a person adds another role (e.g., becomes a Support Registrant for a different
Authorized Official), he will be asked to print, sign and send in a Verification form only.

The submission process- the CDX Node within the e-PMN tool
15. After Registration and EPA approval, what happens next?
After registration and approval, the submitter will receive an e-mail stating that their account
is now active. The submitter will return to the CDX Registration website and complete the 20-51 questions. After answering the questions, the submitter will be taken to the “MyCDX” website
where he/she can download the e-PMN software. Once the software has been downloaded and
installed, the submitter can begin to create draft documents. Once the documents are ready for
submitting to EPA, the submitter selects to finalize the file and submit via CDX. A node (portal)
to CDX is opened. The submitter enters their User ID and password. The submitter selects the
“Submit” button and answers the 20-5-1 security questionnaire. An encryption key is generated
and placed onto the hard drive (this only happens the first time a submitter uses that particular
computer to submit via CDX). The file is encrypted and sent to EPA for processing. An e-mail
is sent to the submitter stating that the transmission was successful. A Copy of Record is
transmitted back to the submitter containing a read-only version of the submission which can
only be opened by the original encryption key.
16. How will I know if there is an error during electronic submission?
If there is any type of error in transmission through CDX you will get a short message right
away. You should contact the CDX Help Desk for further instructions before attempting
transmission again. Transmitting the same package a second or third time would cause
confusion with EPA processing. The CDX Help Desk might be able to solve the problem and
have the transmission go through successfully without you having to retransmit it. They may
also detect a problem and fix it, but will need you to transmit your package again. Either way,
you should wait for instructions from the CDX Help Desk before attempting transmission again.
17. How can I tell if the electronic submission has gone through successfully? How long
will I have to wait for a reply?
A few minutes after selecting the “Submit” button, select the “Check Transaction Status”
button. The submission status will either stay as “Pending” or it may change to “Successful” or
“Failure”. If “Successful”, you will receive an e-mail with the CDX Transaction ID number. If
your status is Failure, please call the CDX Help desk.
18. How will I know if there is something waiting for me in CDX?
For all transmissions from EPA to you via CDX, EPA sends you a generic e-mail to your
corporate e-mail address notifying you that something is ready for downloading from CDX
through the e-PMN software. This e-mail does not contain any TSCA-CBI.
19. What is the Copy of Record?
Transmitting submissions through CDX also provides you with an electronic Copy of Record
of your submission. After EPA receives and decrypts and unzips your submission, it
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automatically zips it and encrypts it again using a special encryption key it received from CDX
when you first verified your account in CDX. EPA then sends this package back to CDX
backend node where your can access it through your e-PMN software for downloading. You
will not have to have your e-PMN software open on your work station to know that something is
available for download. EPA sends an e-mail notification to the submitter that the Copy of
Record is available.
Once you receive this e-mail notification and open the CDX node from the e-PMN software
(and after verifying your UserID, Password and the 20-5-1 Questionnaire), the e-PMN software
automatically uses the corresponding decryption key to download the submission. This is the
Copy of Record. It is not merely a mirror copy of your originally zipped and encrypted
submission - it is what EPA has received, re-encrypted and sent back to you for your records.
The Copy of Record is equivalent to a photo-copy of your paper submission from EPA verifying
what you sent. The file is a read-only file and cannot be altered.

CDX Registration Maintenance
20. How do I make changes to a registration?
After you log into your CDX account with your username and password, your account home
page (MyCDX) has links to change the following: your personal profile information; company
information; and to register for another CDX program or role (Authorized Official or Support
Registrant).
Any personal profile information (UserID, Password, your password secret question) you
provide in CDX registration can be changed and updated. Personal corporate mailing address
and phone number can also be changed and updated. However, changing the official corporate
name is a different issue. Please contact CDX Help desk, if the name or identity of the
corporation has changed (e.g., change in name, bought as a subsidiary, sold or split off from the
original parent company, etc).
You may also register for a new program by selecting “Edit Current Account Profiles” in the
MyCDX webpage and selecting “Add New Program”. If you want to add another role to an
exiting Program, select “List Roles” from this site. An example of adding another role would be
a Support Registrant registering for another Authorized Official.
21. How do I remove my account from CDX?
Please contact EPA by letter on company letterhead to the address specified below and in the
CDX Electronic Signature Agreement form to remove a name from the CDX account:
By U.S. Postal Service: PMN CDX Registration Coordinator (7407M), U.S. Environmental
Protection Agency, Office of Pollution Prevention and Toxics, Ariel Rios Building, 1200
Pennsylvania Ave, NW, Washington, DC 20460.
By Hand Delivery or Courier: PMN CDX Registration Coordinator, U.S. EPA- OPPT/CBIC,
EPA East Building, Room 6428, 1201 Constitution Ave, NW, Washington, DC 20004-3302,
202-564-8930; 202-564-8940.

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Submitter Use of the Tool/Submitter Responsibility
22. Can I share my User ID and password with others in my company?
NO, you may not share your User ID, password or 20-5-1 questionnaire with others. This
violates the terms of agreement on the Electronic Signature Agreement. Complying with the
terms of the agreement protects everyone’s information. Violating these terms puts your
information at risk. If more than one person at your company needs to submit information, then
each one needs to go through the registration process.
23. Can I submit documents from more than one computer?
A private key located on the local machine is created upon the first submission to EPA via
CDX. In order to submit via CDX from more than one computer, you must copy your private
key (called .userID-cromerr-keystore.jks) located in the C:\Documents and Settings\username\
folder from the first computer and paste it into the second computer (same location). This way
you will have the same key on both machines and you will be able to open/download documents
within CDX which have been encrypted using this key. Otherwise, you will create a new private
key for the second computer which cannot be used to open documents sent using the encryption
key from the first computer.
24. Can more than one person use the same computer to submit via CDX?
Yes. When a person logs into their CDX account for the first time, an encryption key
(named based on your User ID) is stored for that person on the computer. When a second person
logs into their own CDX account on the same computer, a separate encryption key (named based
on the second person’s User ID) is generated for the second person and is stored on that
computer as well.
25. Should I leave the Copy of Record in CDX?
No. The Copy of Record in CDX is encrypted and only available to the original submitter
who must use his/her original encryption key to decrypt and download the document. If the key
is lost or becomes corrupted, the document in CDX will become unavailable to the company.
26. Can others review information on the submission before I send it electronically?
Some companies may have more than one person collaborating on a document. There are a
number of ways your company can review the information in a document:
You can install the e-PMN software on a shared directory within your company’s
computer system which allows other to open and modify the document directly
within the software;
Your can save the document as a PDF and e-mail it around for review and
comment;
You can print the document and pass a paper copy of the PDF around your
company for review before you submit electronically.

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General
27. Can I submit TSCA Confidential Business Information? Will it be protected?
Yes, the e-PMN Software and EPA’s data bases are designed for you to safely transmit
TSCA Confidential Business Information (TSCA-CBI) via CDX. As you complete the form and
provide attachments, the tool automatically zips everything into one file. The tool then
automatically encrypts this file and (after verifying your UserID, Password and the 20-5-1
Questionnaire) sends it through CDX to EPA. CDX is unable to open up your submission. EPA
receives a matching decryption key with your submission. Only EPA has the matching
decryption key; therefore, your TSCA-CBI is fully protected. EPA then decrypts and unzips
your submission for further processing.
28. How do I get help if I need it?
The EPA will have a centralized call center number for any issues associated with the
software or CDX. Please contact CDX by e-mail at help [email protected] or by calling the
CDX Technical Support Staff through the toll free telephone support on 888-890-1995 between
8:00 am to 6:00 pm (EST) Monday through Friday.

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