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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: Signature Process

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Checklist items 5 through 7 are grouped under the Signature Process and represent CROMERR requirements that this process must satisfy.

Select each item under the Signature Process to learn more.

  1. Binding of Signatures to Document Content
  2. Opportunity to Review Document Content
  3. Opportunity to Review Certification Statements and Warnings

5. Binding of Signatures to Document Content

CROMERR requires that all electronic signatures be bound to the document content. This means that the system must provide a way to ensure that the document content is, in effect, locked, so that it can not be subject to undetectable changes once the signature is executed.

Reference:

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

6. Opportunity to Review Document Content

CROMERR also requires that the signature process provide the signers with the opportunity to review the content of the document they are signing.

Reference:

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

7. Opportunity to Review Certification Statements and Warnings

Along with the opportunity to review document content, CROMERR also requires that signers have the opportunity to review certification statements—including any applicable warnings of criminal penalties for false certifications—before asking them to execute their electronic signatures.

Reference:

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

Review the Regulation Language: § 3.2000(b)(5)(ii)

(b) 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. 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 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. 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: (ii) The electronic document cannot be altered without detection at any time after being signed

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

(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... (iii) Each signatory had the opportunity to review in a human-readable format the content of the electronic document that he or she was certifying to, attesting to or agreeing to by signing

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

(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... (iv) Each signatory had the opportunity, at the time of signing, to review the content or meaning of the required certification statement, including any applicable provisions that false certification carries criminal penalties

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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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