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Cross-Media Electronic Reporting Rule
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Lesson 5: Overview of CROMERR Requirements for Electronic Reporting

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The purpose of the CROMERR requirements is to ensure that authorized programs that receive electronic documents in lieu of paper 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 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)
  • 3.2000(b)
  • 3.2000(c)

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 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.

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  • CROMERR Home
  • Learn about the Cross-Media Electronic Reporting Rule (CROMERR)
  • Overview for State, Tribal, and Local Governments
  • Overview for EPA Programs and Regions
  • CROMERR 101 Training
    • Lesson 1: Overview of the Final Rule
    • Lesson 2: Quick Tour of the Final Rule
    • Lesson 3: Application Requirements
    • Lesson 4: The EPA Review and Approval Process under Part 3
    • Lesson 5: CROMERR-Compliant Electronic Reporting
      • Lesson 5: Overview of CROMERR Requirements for Electronic Reporting
      • Lesson 5: Requirements for Authorized Program e-Reporting
      • Lesson 5: Standards for an Acceptable Electronic Document Receiving System
      • Lesson 5: Defining "Valid Electronic Signatures"
      • Lesson 5: System Requirements for Receiving e-Signatures
      • Lesson 5: Priority vs. Non-Priority Reports
      • Lesson 5: Title: Enforceability Provisions
      • Lesson 5: Title: End of Lesson
    • Lesson 6: Using the Checklist to Work through System Requirements
    • Lesson 7: From Requirements to Solutions
    • Lesson 8: Four Critical Roadmap Items
  • Program Announcements & Initiatives
  • Status of CROMERR Applications from States
  • CROMERR Federal Register Notices
  • Application Tools & Templates
  • Sample Applications & Checklists
  • Glossary
  • Frequently Asked Questions
  • Help Desk
Contact Us to ask a question, provide feedback, or report a problem.
Last updated on June 7, 2022
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