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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: Copy of Record (COR)

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Checklist items 18 through 20 are grouped under the fifth and final process, the 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. 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.

  1. Creation of COR
  2. Timely Availability of COR, as needed
  3. Maintenance of COR

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 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. 

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 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. 

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 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. 

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

(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 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

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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