Lesson 5: Overview of CROMERR Requirements for Electronic Reporting
The purpose of the CROMERR requirements is to ensure that authorized programs that receive electronic documents in lieu of paper When an electronic report takes the place of a paper report submitted to satisfy the requirements under another part of 40 CFR. In some states, the electronic reporting is done to make data collection and management easier, but the state requires that each report submitted electronically also be submitted as a signed paper copy. In this case, the electronic submission would not be in lieu of paper and CROMERR does not apply to the state. Some electronic reporting systems use a combined approach, where part or all of the data are submitted only electronically, but a wet ink signature on paper is also required. In these cases, the e-report (or at least the portions of it that are not also submitted on paper) is considered to be submitted "in lieu of paper" and CROMERR applies. In addition, there are special CROMERR rules under 40 CFR 3.2000(a) that govern the use of a wet ink signature on paper in conjunction with an e-report. (Additional detail on this combined approach is provided in Lesson 6.) can rely on those documents for purposes of enforcement-related litigation.
Before examining the actual requirements, it is important to understand that their overarching purpose is to ensure that electronic reports can provide the same evidence Results of data analysis concerning associations between the causal agent and the effect, or between sources or steps in the causal chain and the causal agent (a definition specific to stressor identification). of what was submitted and of the submitter's and signer's intent as their paper counterparts, particularly in support of civil or criminal litigation. This will be important, for example, where the Government is prosecuting false or fraudulent reporting based on electronic submissions.
In CROMERR, these requirements are presented in three sections. Review each section to learn more.
3.2000(a) - Overall Requirements for Implementing Electronic Reporting
Section § 3.2000(a) provides an introduction to the requirements for using electronic reports in lieu of paper. It outlines that authorized programs must: (1) use an acceptable e-document receiving system that meets CROMERR standards; and (2) require that any e-document bear a valid e-signature if the signatory is required to sign the paper document, unless EPA has approved a process for handwritten signatures on separate paper submissions.
3.2000(b) - Electronic Document Receiving System As defined in § 3.3 of CROMERR, any set of apparatus, procedures, software, records, or documentation used to receive electronic documents. Requirements
Section § 3.2000(b), the main focus of this lesson, provides the requirements for document receiving systems themselves. Again, it is important to remember that the purpose of the individual provisions of this section is to ensure that a system captures and maintains sufficient evidence to support the use of electronically received documents as evidence in civil or criminal litigation. The system must be able to demonstrate the authenticity of the reports it receives and any signatures these reports contain.
3.2000(c) - Provisions of Enforceability
Section § 3.2000(c) contains the provisions to ensure that authorized programs can be enforced based on the receipt of electronic reports in lieu of paper.