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  1. Home
  2. Cross-Media Electronic Reporting Rule
  3. CROMERR 101 Training
  4. Lesson 5: CROMERR-Compliant Electronic Reporting

Lesson 5: Priority vs. Non-Priority Reports

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Under § 3.2000(b)(5)(vii), CROMERR requires that more specific conditions be met where the electronically signed documents have been designated as Priority Reports As defined in § 3.3 of CROMERR, the reports listed in Appendix 1 to part 3..

Priority Reports are those that EPA has identified as likely to be material to potential enforcement litigation. Given this likelihood, it is important to provide not only for the provability of signature device ownership in principle, but for the practical need to make this proof with the resources typically available to enforcement staff and within the constraints of the judicial process in criminal and civil proceedings. A list of these reports can be found under Appendix 1 to Part 3 of CROMERR.

Access the official version of the final rule "Cross-Media Electronic Reporting" – The official version of this rule (70 FR 59848) was published in the Federal Register on 10/13/2005. Click on the previous hyperlink to access the rule, including Appendix 1 to Part 3.

The CROMERR requirements for determining the identity of someone submitting an electronic report are different for Priority and Non-Priority reports. Select each of the links below for information on these requirements.

  • Priority Reports
  • Non-Priority Reports

Priority Reports

For Priority Reports, the system must determine identity before the e-signature is received by means of either:

  • Wet-ink-on-paper e-signature agreements (i.e., subscriber agreements) either submitted to the state or maintained by a responsible company official. While some systems with CROMERR approval require that they be notarized, notarization is not a CROMERR requirement; OR
  • Electronic identity-proofing by a disinterested party (such as a public key infrastructure Enables users of a basically unsecure public network, such as the Internet, to securely and privately exchange data and money through the use of a public and a private cryptographic key pair that is obtained and shared through a trusted authority. The public key infrastructure provides for a digital certificate that can identify an individual or an organization and directory services that can store and, when necessary, revoke the certificates. [PKI Enables users of a basically unsecure public network, such as the Internet, to securely and privately exchange data and money through the use of a public and a private cryptographic key pair that is obtained and shared through a trusted authority. The public key infrastructure provides for a digital certificate that can identify an individual or an organization and directory services that can store and, when necessary, revoke the certificates.] certificate authority or an agency official) using objectively verifiable information, including at least one government-issued identifier such as a driver's license number or passport; OR
  • Identity-proofing using an approach no less stringent than electronic identity-proofing as specified above.

Note: Disinterested party refers to an individual who is not connected with the person in whose name the electronic signature device As defined in § 3.3 of CROMERR, a code or other mechanism that is used to create electronic signatures. Where the device is used to create an individual's electronic signature, then the code or mechanism must be unique to that individual at the time the signature is created and he or she must be uniquely entitled to use it. The device is compromised if the code or mechanism is available for use by any other person. is issued. A disinterested individual As defined in § 3.3 of CROMERR, an individual who is not connected with the person in whose name the electronic signature device is issued. A disinterested individual is not any of the following: The person's employer or employer's corporate parent, subsidiary, or affiliate; the person's contracting agent; member of the person's household; or relative with whom the person has a personal relationship. is not any of the following:

  • The person's employer or employer's corporate parent, subsidiary, or affiliate;
  • The person's contracting agent;
  • A member of the person's household; or
  • A relative with whom the person has a personal relationship.

Non-Priority Reports

For Non-Priority Reports, the system must determine identity by collecting and maintaining information sufficient to prove the identity of individuals that sign and submit electronic documents.

Note that CROMERR does not specify when or how this goal is to be achieved.

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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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