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I still don’t see where it states anything to the idea that the 2257 info should be completely separate and on its own, apart from any another release, waiver, or agreement.
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My bad... I thought you were talking about a copy of the scene/picture.
As for the separate 2257 doc, you are correct - there is no specific language stating that it needs to be a separate doc however, it is advisable that you do not give more information than is called for in the 28 CFR 75. It is also industry standard. Its not a fatal flaw but it makes record keeping easier and cleaner. And if they do not ask for it, I wouldnt put it in.
Here is two examples of too much info as well... dont get mad Smokey .. you are in the 90% of people in the indsutry that do overkill on this...
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second you need to have a digital or copied image of the models IDs (2 forms, 1 has to be photo and state or federal like a DL or passport), i use an ID form to photo copy the IDs onto and have the model sign it.
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All the law calls for is 1 ID, not 2, but most people make that mistake as well. Also you do not have to have the model sign the ID. Nothing in the language of 28 CFR 75 calls for 2 IDs or an ID signature.
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I then take a photo of the model holding both of there IDs next to there head on either side so yo see the IDs and the depiction of the model.
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This is also completely unnecessary for 18 USC 2257 and 28 CFR 75. There's no requirement for a pic of the model holding up the ID. Just get a really good color scan/digital picture of the 1 ID and you are good to go. The ID needs to have the model's DOB, DL # and her name and you have to be able to see all the facial features.
Putting in unnecessary info into the records may frustrate and annoy the DOJ/FBI inspectors. They want to see what they need to see and move on. The more you give them the harder their job is and the longer it takes. You want them to get what they need and leave.