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 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) - 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.