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Cross-Media Electronic Reporting Rule
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Lesson 6: Copy of Record (COR)

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Checklist items 18 through 20 are grouped under the fifth and final process, the COR Process. These items represent CROMERR requirements that the system must satisfy in creating and maintaining CORs. The items address:

  • What data CORs must capture;
  • How access to CORs must be provided to program and enforcement staff; and
  • How the CORs must be maintained.

Checklist items 18 through 20 are listed below.

18. Creation of COR

§ 3.2000(b)(1) through (2): For each legitimate submittal received, CROMERR requires the system to create a COR. The COR must be a true and correct copy of the submittal, in the sense that it must have exactly the same informational content as the submittal; otherwise, it must document any changes to this content after submittal.

The COR must include all associated signatures, the date and time of receipt, and any other information necessary to interpret the submittal.

Finally, the COR must be viewable in a human-readable format that makes the meaning of each information item clear; although it need not be maintained in this format or in the format in which the submittal was originally received.

Reference:

  • Review the Regulation Language: § 3.2000(b)(1)(2)
  • Definition of Copy of Record 

19. Timely Availability of COR, as needed

§ 3.2000(b)(1) through (2): CROMERR requires the system to provide program and enforcement staff with timely access to the CORs and the associated documentation.

Reference:

  • Review the Regulation Language: § 3.2000(b)(1)(2)
  • Definition of Copy of Record

20. Maintenance of COR

CROMERR requires the system to maintain the CORs for as long as needed by program or enforcement staff. The CORs must be maintained together with any information needed to document their integrity, such as records or logs of associated signature validation processes. Finally, the CORs must be maintained in a way that protects them from alteration or deletion on a system that is electronically and physically secure. 

Reference:

  • Review the Regulation Language: § 3.2000(b)(1)(2)
  • Definition of Copy of Record

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Regulation Language: § 3.2000(b)(1)(2)

(b) An electronic document receiving system that receives electronic documents submitted in lieu of paper documents to satisfy requirements under an authorized program must be able to generate data with respect to any such electronic document, as needed and in a timely manner, including a copy of record for the electronic document, sufficient to prove, in private litigation, civil enforcement proceedings, and criminal proceedings, that... (1) The electronic document was not altered without detection during transmission or at any time after receipt; (2) Any alterations to the electronic document during transmission or after receipt are fully documented

Copy of Record

A true and correct copy of an electronic document received by an electronic document receiving system, which copy can be viewed in a human-readable format that clearly and accurately associates all the information provided in the electronic document with descriptions or labeling of the information. A copy of record includes: 1) All electronic signatures contained in or logically associated with that document; 2) The date and time of receipt; and 3) Any other information used to record the meaning of the document or the circumstances of its receipt.

  • 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 6: Using the Checklist to Work through System Requirements
      • Lesson 6: Registration
      • Lesson 6: Signature Process
      • Lesson 6: Submission Process
      • Lesson 6: Signature Validation
      • Lesson 6: Copy of Record (COR)
      • Lesson 6: The CROMERR Requirements and the Checklist Items
      • Lesson 6: End of Lesson
    • Lesson 7: From Requirements to Solutions
    • Lesson 8: Four Critical Roadmap Items
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Last updated on December 27, 2021