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Cross-Media Electronic Reporting Rule

CROMERR Overview for EPA Programs and Regions


Background

Published on October 13, 2005, the Cross-Media Electronic Reporting Rule (CROMERR) established a framework by which EPA will accept electronic reports from regulated entities. CROMERR may apply to any electronic document submission required by or permitted under any EPA program governed by EPA's regulations in Title 40 of the Code of Federal Regulations (CFR).

On October 13, 2005, EPA also published a Federal Register Notice (70 FR 59748) designating as acceptable all existing EPA systems that were receiving electronic reports as of that date to continue receiving those reports until October 13, 2007. To receive electronic reports after October 13, 2007, the Administrator must re-designate existing systems other than the Central Data Exchange (CDX).

See: CROMERR Federal Register Notices

CROMERR sets standards for electronic report receiving systems operated by state, tribal and local governments under their authorized programs. In the Preamble to the regulation, EPA commits to meeting those standards for its own electronic report receiving systems. The Preamble states:

EPA's goal is that all its systems for receiving electronic reports be consistent with the CROMERR standards for electronic document receiving systems set forth in 40 CFR 3.2000(b).

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Program Impact

EPA Program and Regional systems that receive electronic reports in lieu of paper copies of record must document conformance with CROMERR standards and apply to the EPA CROMERR Technical Review Committee (TRC) for an assessment. System certification by the TRC is based on an assessment of how electronic reporting systems meet the technology-neutral, performance-based criteria in CROMERR.

The performance-based criteria address a number of topics, including:

  • Criteria for establishing a copy of record,
  • Integrity of electronic document,
  • Opportunity to review and repudiate copy of record,
  • Validity of electronic signature, and
  • Determination of the identity of the individual uniquely entitled to use a signature device.

All CROMERR-subject systems must be certified before going into production. A system is considered to be “in production” when regulated entities start registering to report electronically through the system.

In January 2011, the EPA Chief Information Officer (CIO) announced EPA’s Data Exchange Procedure (CIO 2122-P-04.0), confirming the Central Data Exchange (CDX) as the EPA's designated system to support CROMERR implementation. Per the procedure, EPA systems subject to CROMERR must use CDX services. This procedure only applies to a system’s CROMERR-related functionality and key business processes; it does not mean that aspects of a system unrelated to CROMERR standards must use CDX services.

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Procedures for implementing CROMERR for EPA Systems

CDX services greatly reduce the burden of CROMERR compliance for EPA programs or regions. Still, as the system operator, the program or region is responsible for:

  • determining which of their systems are subject to CROMERR, in consultation with the CROMERR TRC;
  • operating the system in conformance with possible custom-aspects outlined in the approved application; and
  • in some cases, submitting and preparing a CROMERR application that demonstrates a system’s conformance with the CROMERR standards.

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Overview of the Application Process

EPA systems that use CDX services will follow either a traditional CROMERR application process or a “Tier 1” application process. Select each section below to learn more.

If you do not know which process applies to your application, please contact the CROMERR Help Desk.

Traditional EPA CROMERR applications may incorporate custom CDX CROMERR functionality and/or several custom business practices.

Review and approval timeframes can vary; programs and regions pursuing custom functionality should be prepared for lengthy review timeframes and suggested changes to the approach to ensure consistency with CROMERR standards.

For further information about CROMERR, see: CROMERR 101: Fundamentals for States, Tribes and Local Governments

  • Step 1. Application preparation and submittal

    A CROMERR application consists of:

    • A CROMERR application cover sheet noting the application contact(s), full system name, system acronym, brief system description, programs covered by the application, listed by name and CFR citation. 
    • A completed CDX CROMERR System Checklist, drawing from the current “baseline” CDX CROMERR checklist. The most current version of this document is available from CDX.
    • A screen shot taken at the moment of signature showing the “certification and warning” statements and a sample Copy of Record (COR) documenting that these same “certification and warning” statements are included in the COR.

    Potentially required information:

    • A copy of the system’s Electronic Signature Agreement (ESA), if customized from the CDX template ESA.
    • Appendices documenting custom functionality or business processes.
    • Appendices documenting planned custom upgrades, should the EPA program or region wish to get approval for these upfront.

    It is not necessary to include copies of core CDX CROMERR checklist appendices with the application. However, the prepared checklist should refer only to those core CDX CROMERR checklist appendices that apply to the system as implemented.

    Once an EPA CROMERR application has been prepared, the program or region submits the application via email to the CROMERR program indicating that it is submitting the application for review by the TRC.

  • Step 2: Confirmation and processing

    Applicants will receive a confirmation of receipt within three business days after the application is received. The TRC may request further information within two weeks if it is required for review. Not having all required information upfront, not using prepared templates and forms, and/or submitting revised documents mid-process may delay the application’s review.

  • Step 3: Review

    Key members of the TRC review applications, and typically, applicants do not need to conduct presentations for the TRC. Only custom functionality and business processes are reviewed.

    If the system includes custom-built CROMERR functionality and/or presents “new and novel” CROMERR issues, the review process may take longer. Otherwise, the TRC will generally respond with comments approximately four weeks after all required application information is received.

  • Step 4: Comments and response

    If the TRC has questions about an application, it will work with the applicant and CDX to resolve these questions. If the TRC has no questions, this step is skipped. However, Steps 3 and 4 may be repeated until key TRC members conducting the review determine the system to be consistent with CROMERR standards.

  • Step 5: Committee vote

    TRC members have up to two weeks to vote on whether or not the application is consistent with CROMERR standards.

  • Step 6: Approval notification

    The applicant will receive an email confirming that the application has achieved approval.

  • Step 7: “Availability of Electronic Reporting” Federal Register notice

    Prior to collecting reports, EPA programs and regions must publish a notice in the Federal Register (FR) announcing the availability of electronic reporting under their program(s) because of the newly approved system(s). Some programs and regions meet this requirement by including text in another Federal Register publication that is related to the system's regulatory reports, such as a rule or a notice about contractors having access to sensitive data.

    Programs and regions should, at a minimum, include the following information in the “availability of electronic reporting” FR notice:

    • The system’s full name as well as its acronym;
    • Statement that the system supports a CDX data flow;
    • Description of how to access the system;
    • Explaination of how users can get help on the system (e.g., contact the CDX help desk) and/or where to find a users’ guide;
    • References describing which programmatic reporting the system covers (e.g., Part 123 National Pollutant Discharge Elimination System);
    • Listing of which regulatory reports are collected by the system – name(s) and 40 CFR citation(s);
    • Details on when regulated entities can start registering in CDX for the data flow and when they can start reporting. Indication whether and when certain reports are available; and
    • Point(s) of contact in the program or region who can provide more information about the system.

    For guidance on preparing a Federal Register Notice, see: Sample Federal Register Notice for EPA programs and regions(2 pp, 33 K)

    See: CROMERR section 3.2(a)(2)

  • Step 8: Modifications to approved CROMERR applications

    EPA programs and regions with approved CROMERR electronic reporting programs are required to notify the TRC, in writing, of any changes to custom CROMERR functionality and business processes. The TRC coordinates directly with CDX to track and approve changes to the core services. Further, EPA programs and regions:

    • may freely switch from one approved CDX service to another within their approved system, and
    • do not need to notify the TRC if they begin to collect a regulatory report listed within an approved CROMERR application if nothing has changed in terms of custom aspects of the system.

    For further information, see:

Tier 1 is an expedited CROMERR approval process for EPA Programs and Regions with systems that rely entirely or almost entirely on CDX services.

Tier 1 customers benefit from significantly reduced application requirements and expedited approval.  The majority of Tier 1 applicants do not need to provide CROMERR technical documentation -- unless there is a potentially unique use case requiring custom CROMERR functionality and/or an assessment related to CROMERR applicability,  programs and regions will often only need to work with CDX on system set up.  A formal approval action by the CROMERR program is usually not required but typically provided as a courtesy. 

  • Step 1: Application preparation and submittal

    CDX determines if a customer’s system qualifies for the Tier 1 process. Tier 1 EPA applicants are not required to submit a CROMERR checklist.

    Required documents:

    • A CROMERR application cover sheet noting the application contact(s), full system name, system acronym, brief system description, programs covered by the application, listed by name and CFR citation. 

    Potentially required information:

    • A copy of the system’s Electronic Signature Agreement (ESA), if customized from the CDX template ESA.
    • A description of program-specific business processes not handled by CDX.

    Once an EPA CROMERR application has been prepared, the program or region submits the application via email to the CROMERR program indicating that it is submitting the application for review by the TRC.

  • Step 2: Confirmation and processing

    Applicants will receive a confirmation of receipt within three business days after receipt of the application. The TRC may request further information within two weeks if it is required for review.

    Not having all required information upfront, not using prepared templates and forms, and/or submitting revised documents mid-process may delay the application’s review.

  • Step 3: Review and comment

    Reviews are not conducted for applications that only required a cover sheet.

    Key members of the TRC review applications that describe custom business processes consistency with CROMERR standards. If the review results in additional questions, the TRC typically works with the applicant and CDX to resolve the questions.

  • Step 4: Committee vote

    The TRC does not typically vote on Tier 1 EPA CROMERR applications.

  • Step 5: Approval notification

    The applicant will receive an email confirming that the application has achieved approval.

  • Step 6: “Availability of Electronic Reporting” Federal Register notice

    Prior to collecting reports, EPA programs and regions must publish a notice in the Federal Register (FR) announcing the availability of electronic reporting under their program(s) as a result of the newly approved system(s). Some programs and regions meet this requirement by including text in another Federal Register publication that is related to the system's regulatory reports, such as a rule or a notice about contractors having access to sensitive data.

    Programs and regions should, at a minimum, include the following information in the “availability of electronic reporting” FR notice:

    • The system’s full name as well as its acronym;
    • Statement that the system supports a CDX data flow;
    • Description of how to access the system;
    • Explaination of how users can get help on the system (e.g., contact the CDX help desk) and/or where to find a users’ guide;
    • References describing which programmatic reporting the system covers (e.g., Part 123 National Pollutant Discharge Elimination System);
    • Listing of which regulatory reports are collected by the system – name(s) and 40 CFR citation(s);
    • Details on when regulated entities can start registering in CDX for the data flow and when they can start reporting. Indication whether and when certain reports are available; and
    • Point(s) of contact in the program or region who can provide more information about the system.

    For guidance on preparing a Federal Register Notice, see: Sample Federal Register Notice for EPA programs and regions(2 pp, 33 K)

    See: CROMERR section 3.2(a)(2)

  • Step 7: Modifications to approved CROMERR applications

    EPA programs and regions with approved CROMERR electronic reporting programs are required to notify the TRC, in writing, of any changes to custom CROMERR functionality and business processes. The TRC coordinates directly with CDX to track and approve changes to the core services. Further, EPA programs and regions:

    • may freely switch from one approved CDX service to another within their approved system, and
    • do not need to notify the TRC if they begin to collect a regulatory report listed within an approved CROMERR application if nothing has changed in terms of custom aspects of the system.

    For further information, see:

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