&EPA
United States
Environmental Protection
Agency
Office of Information Collection:
CROMERR Fact Sheet
For EPA Program and Regional Offices
Purpose
The Cross-Media Electronic Reporting Regulation (CROMERR) provides the legal framework
for electronic reporting to the Environmental Protection Agency (EPA) and states, tribes, and
local governments that are authorized to administer EPA programs. CROMERR is intended to
reduce the cost and burden of electronic reporting while maintaining the level of corporate and
individual responsibility and accountability that exists in the paper environment.
Background
Published on October 13, 2005, the final rule
established a framework by which it will accept
electronic reports from regulated entities.
CROMERR could apply to any document submissions
required by or permitted under any EPA or authorized
program governed by EPA's regulations in Title 40 of
the Code of Federal Regulations (CFR), if it is
submitted electronically.
Under CROMERR, reports submitted electronically to
EPA must be submitted to the Central Data Exchange
(CDX), or to a system designated by the Administrator
for the receipt of those reports. On October 13, 2005,
EPA also published a Federal Register Notice (70 FR
59748) designating as acceptable all EPA systems that
were receiving electronic reports as of that date to
continue receiving those reports until October 13, 2007. To receive electronic reports after
October 13, 2007, systems other than CDX must be re-designated by the Administrator.
Section 3.2000(b) of CROMERR sets standards for electronic report receiving systems operated
by states, tribes, and local governments under their authorized programs. In the Preamble to the
rule, EPA commits to meeting those standards for its own electronic report receiving systems.
The Preamble states:
EPA's goal is that all its systems for receiving electronic reports be consistent with the
CROMERR standards for electronic document receiving systems set forth in Sec.
3.2000(b) of today's rule. EPA generally hopes to achieve this consistency within a two-
year transition period for existing EPA systems; however, EPA is not bound by the Sec.
3.2000(b) standards of today's rule or the two-year period. This two-year period is
similar to the two-year transition period provided under Sec. 3.1000(a)(3)for systems
operated under EPA-authorized programs. In a number of cases, EPA may work toward
EPA's CROMERR Policy Applies To:
• EPA Programs and Regions with
existing or planned information
collection systems.
Electronic Reporting Affected:
• CROMERR could apply to any
submissions required by or permitted
under any EPA or authorized delegated
program governed by EPA's regulations
in Title 40 of the Code of Federal
Regulations.
CROMERR Does Not Apply To:
• E-reporting that does not replace reports
submitted on paper.
• Documents submitted fax,
magnetic/optical media.
• Submissions not under 40 CFR.
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this goal by migrating existing electronic reporting to CDXor to other, new CROMERR-
consistent systems.
Program Impact
EPA Programs and Regions operating systems, including CDX data flows, that receive
electronic reports (including via email) must document their system's conformance with
CROMERR and apply to the EPA Technical Review Committee (TRC) for certification of
system conformance as soon as possible, but no later than June 1, 2007. All existing non-CDX
systems that receive electronic reports must also get Administrator designation to continue
operating for specified submissions after October 13, 2007. All new systems (both CDX and
non-CDX) must be certified before they begin receiving electronic reports; non-CDX systems
must also be designated by the Administrator to operate for specific submissions. Programs and
Regions that do not have certified conformance of an existing system by September 15, 2007, or
have an approved conformance plan for the system by that date, will need to appeal directly to
the Administrator for re-designation of the system.
Procedures for Implementing CROMERR for EPA Systems
Each Program or Region is responsible for determining, in consultation with the Office of
Information Collection (QIC), which of their systems are subject to CROMERR. The Program
or Region is also responsible for preparing proposals demonstrating that the subject systems will
conform to the CROMERR standards. Proposals for existing systems must demonstrate that
CROMERR conformance will be achieved by October 13, 2007. Proposals for new systems
must demonstrate that CROMERR conformance will be achieved before the systems begin
receiving electronic reports. For existing systems that cannot achieve CROMERR conformance
by October 13, 2007, the Program Office or Region is responsible for preparing a conformance
plan that describes in detail the activities, milestones and resources that will be used to achieve
conformance. Both proposals demonstrating system conformance and conformance plans are
submitted for review and assessment to the EPA Technical Review Committee (TRC).
Convened in December 2005, the TRC reviews EPA system proposals and authorized program
applications submitted under CROMERR. The TRC reflects an Agency-wide perspective, with
representatives from each of the EPA Regions and Program Offices. To ensure timely review,
proposals and conformance plans must be submitted to the TRC no later than June 1, 2007.
Early submissions are strongly encouraged.
By September 15, 2007, each existing system must have certified conformance with CROMERR
or have an approved conformance plan. New systems must certify conformance with
CROMERR before they begin receiving electronic reports. For existing systems with an
expiring CROMERR designation that certify conformance or get conformance plan approval by
September 15, 2007, QIC will prepare & Federal Register notice for the Administrator's
signature re-designating the systems for receipt of electronic reports. The notice will be
published no later than October 13, 2007. The Program or Region is responsible for preparing
any other Federal Register notice needed to use a system to receive electronic reports under
CROMERR.
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The Program or Region is responsible for implementing approved proposals and conformance
plans. Once a system achieves conformance in accordance with the proposal or plan, the
Information Management Officer for the Program or Region certifies system conformance to
QIC. Also, once a system is certified, the Program or Region must address any changes that
could affect the system's conformance status in a new proposal. The proposal must demonstrate
that the changes will preserve the system's conformance with CROMERR, and must be
submitted to and reviewed by the TRC before the changes are implemented.
Criteria used to evaluate electronic reporting systems
System certification will be based on an assessment of how electronic reporting systems meet the
technology-neutral, performance-based criteria in CROMERR. CROMERR's criteria to
evaluate electronic reporting systems are based, in part, on the need to be able to prove in
enforcement proceedings the following: electronic reports are what they purport to be, their
content is unchanged, and any electronic signatures were actually executed by the designated
signatories. The performance-based criteria address a number of topics, including, among other
things:
• Criteria for establishing a copy of
record
• Integrity of electronic document
• Opportunity to review and repudiate
copy of record
More Information
David Schwarz
Senior Program Analyst
Office of Environmental Information
(202) 566-1704
Schwarz.david@epa.gov
Validity of electronic signature
Determination of the identity of the
individual uniquely entitled to use a
signature device
Evi Huffer
Senior Program Analyst
Office of Environmental Information
(202) 566-1697
Huffer.Evi@epa.gov
EPA's CROMERR web site: http://www.epa.gov/exchangenetwork/cromerr
Office of Environmental
Information (2812A)
www.epa.gov/oei
www.epa.gov/oei
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