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  1. Home
  2. Cross-Media Electronic Reporting Rule
  3. CROMERR 101 Training
  4. Lesson 6: Using the Checklist to Work through System Requirements

Lesson 6: Submission Process

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Checklist items 8 through 12 are grouped under the Submission Process, and represent the CROMERR requirements that must be satisfied as the report or document is transferred to the system during a formal submission. Items 8 through 11 are required for all submittals, whether or not an electronic signature As defined in § 3.3 of CROMERR, any information in digital form that is included in or logically associated with an for the purpose of expressing the same meaning and intention as would a handwritten signature if affixed to an equivalent paper document with the same reference to the same content. The electronic document bears or has on it an electronic signature where it includes or has logically associated with it such information. is included.

Select each item under the Submission Process to learn more.

  1. Transmission Error Checking and Documentation
  2. Opportunity to Review COR
  3. Procedures to Address Repudiation COR
  4. Procedure to Flag Accidental Submissions
  5. Automatic Acknowledgement of Submission

8. Transmission Error Checking and Documentation

CROMERR requires that the system be able to assure that it received the electronic report through an error-free transmission or that any errors in transmission are documented. This normally involves the use of cryptographic technologies (e.g., secure socket layer, and transport layer security).

Reference:

  • Review the Regulation Language: § 3.2000(b)(1) (2)

9. Opportunity to Review COR

CROMERR requires that the system provide the submitter and any signers with the opportunity to review the Copy of Record As defined in § 3.3 of CROMERR, a true and correct copy of an electronic document received by an , 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. (COR As defined in § 3.3 of CROMERR, 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.) of the submittal after it is formally received. This is distinct from the requirement that signers have the opportunity to review document content and certification statements prior to signing and submitting, which are addressed in items 6 and 7. The requirement here has three elements. First, the system must notify the submitter and any signers that the COR is available for their review. Second, the system must produce a version of the COR in a human-readable format. Third, and finally, the system must provide the signers and submitter with access to the COR in this human-readable format.

Reference:

  • Review the Regulation Language: § 3.2000(b)(4)
  • Definition of Copy of Record

10. Procedures to Address Repudiation COR

CROMERR requires that the submitter and any signers have the opportunity to repudiate the Copy of Record (COR) in part or in total, if they disagree with how the COR represents the submission. The system must also have a way to address any cases of repudiation and to document the history of the submission in those cases.

Reference:

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

11. Procedure to Flag Accidental Submissions

CROMERR requires that the system be able to identify accidental or counterfeit submissions and have a way of addressing user repudiations of submissions as forged or accidental. For those cases, the system must also be able to document the submission's history.

Reference:

  • Review the Regulation Language: § 3.2000(b)(3)

12. Automatic Acknowledgement of Submission

Where the submission includes an electronic signature, CROMERR requires that the system automatically send an acknowledgement to the individual identified as the signer at the time of submittal. The acknowledgement must identify the submittal, the signers, and the date and time the submittal was received.

This automatic acknowledgement must be sent to an out-of-band address—that is, an address that does not share the same access controls like the username, PIN, or password—as the account used to make the electronic submission. This address is typically an email address, but it could be a U.S. Postal address or even a phone number.

One purpose of this requirement is to help system users detect any compromise In relationship to an electronic signature device, refers to when the device's code or mechanism is available for use by any other person. of their signature devices. If a submission includes a signature executed with a device by someone other than its registered owner, the owner will be alerted by the acknowledgement he or she receives at the out-of-band address. Given this purpose, the system must include procedures to follow-up when the acknowledgement cannot be delivered to determine whether the email or U.S. Postal address associated with the account is still valid.

Reference:

  • Review the Regulation Language: § 3.2000(b)(5)(vi)

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Copy of Record

A true and correct copy of an electronic document As defined in § 3.3 of CROMERR, any information in digital form that is conveyed to an agency or third-party, where "information" may include data, text, sounds, codes, computer programs, software, or databases. "Data," in this context, refers to a delimited set of data elements, each of which consists of a content or value together with an understanding of what the content or value means; where the electronic document includes data, this understanding of what the data element content or value means must be explicitly included in the electronic document itself or else be readily available to the electronic document recipient. received by an 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., 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.

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

(b) An electronic document receiving system that receives electronic documents submitted 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.) documents to satisfy requirements under an authorized program As defined in § 3.3 of CROMERR, a federal program that EPA has delegated, authorized, or approved a state, tribe, or local government to administer, or a program that EPA has delegated, authorized, or approved a state, tribe or local government to administer in lieu of a federal program, under other provisions of Title 40 and such delegation, authorization, or approval has not been withdrawn or expired. 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

Regulation Language: § 3.2000(b)(4)

(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... (4) Any individual identified in the electronic document submission as a submitter or signatory had the opportunity to review the copy of record 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 and had the opportunity to repudiate the electronic document based on this review

Regulation Language: § 3.2000(b)(3)

(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... (3) The electronic document was submitted knowingly and not by accident

Regulation Language: § 3.2000(b)(5)(vi)

(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... (5) In the case of an electronic document that must bear electronic signatures of individuals as provided under paragraph (a)(2) of this section, that... (vi) The electronic document receiving system has automatically responded to the receipt of the electronic document with an acknowledgment As defined in § 3.3 of CROMERR, a confirmation of electronic document receipt. that identifies the electronic document received, including the signatory and the date and time of receipt, and is sent to at least one address that does not share the same access controls as the account used to make the electronic submission

Cross-Media Electronic Reporting Rule

  • Learn about the Cross-Media Electronic Reporting Rule (CROMERR)
  • CROMERR 101 Training
    • Lesson 1: Overview of the Final Rule
      • Lesson 1: What Does the Rule Do?
      • Lesson 1: What Does the Rule NOT Do?
      • Lesson 1: Who is Affected?
      • Lesson 1: When Does the Rule NOT Apply?
      • Lesson 1: End of Lesson
    • Lesson 2: Quick Tour of the Final Rule
      • Lesson 2: End of Lesson
    • Lesson 3: Application Requirements
      • Lesson 3: Required Elements of a CROMERR Application
      • Lesson 3: Typical Application Components
      • Lesson 3: Cover Sheet
      • Lesson 3: Attorney General (AG) Certification
      • Lesson 3: System Description(s)
      • Lesson 3: Submitting the Application
      • Lesson 3: End of Lesson
    • Lesson 4: The EPA Review and Approval Process under Part 3
      • Lesson 4: Technical Review Committee (TRC)
      • Lesson 4: End of Lesson
    • 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 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 7: From Requirements to Specific Solutions
      • Lesson 7: From Requirements to Specific Solutions Two Key Decisions
      • Lesson 7: Key Decision 1 - Type of Credential Used
      • Lesson 7: Key Decision 1 - Type of Credential Used (continued)
      • Lesson 7: Key Decision 2 - Defining the Copy of Record (COR)
      • Lesson 7: From Key Decisions to CROMERR-Compliant Solutions
      • Lesson 7: End of Lesson
    • Lesson 8: Four Critical Checklist Items
      • Lesson 8: CROMERR System Checklist Items
      • Lesson 8: Additional Sample Solutions
      • Lesson 8: End of Lesson
  • Overview for CROMERR
  • Program Announcements & Initiatives
  • Approved CROMERR Applications
  • CROMERR Federal Register Notices
  • Application Tools & Templates
  • Sample Applications & Checklists
  • Glossary
  • Frequently Asked Questions
  • Help Desk
Contact Us about Cross-Media Electronic Reporting Rule
Contact Us to ask a question, provide feedback, or report a problem.
Last updated on November 13, 2024
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