For the second time in as many months, the Environmental Protection Agency (EPA) has extended the deadline for submission of public comments on a proposal establishing a model system for electronic reporting and recordkeeping. The new deadline for EPA’s “cross-media electronic reporting and recordkeeping rule” (CROMERR) is now February 27, 2002. EPA also has announced two public hearings on the proposed rule’s recordkeeping provisions. The first was held in Washington, D.C., on January 17, and the second is scheduled for January 31 in Irving, Texas.
The CROMERR proposal would permit the use of electronic document receiving systems to satisfy certain information submission requirements in EPA’s regulations, such as the Toxic Release Inventory, the National Pollutant Discharge Elimination System, and various Clean Air Act rules. Industry has lodged very vehement objections to the proposal, arguing that it would impose mandatory, rather than voluntary, electronic recordkeeping requirements.
The proposed CROMERR rule is quite lengthy, which has made it difficult for interested parties who wish to file comments. In this latest Federal Register notice, EPA has attempted to narrow the focus of the public comments by offering the following questions:
· What kinds of records do companies currently keep electronically to satisfy EPA regulatory requirements?
· How prevalent is this electronic recordkeeping and what kinds of systems are used?
· How are automatically captured data and other raw data maintained electronically?
· How will the proposed rule affect companies’ electronic recordkeeping practices?
· Do some of the provisions raise more issues than others?
· How do companies currently ensure the integrity and reliability of their electronic records?
· What special issues are raised by proposed criteria for long-term archiving?
· Where archiving involves the conversion of electronic records to paper, how do companies assure data integrity and reliability, and what role do recognized industry standards play?
· Are there new products or technologies that will help companies address the proposed standards for recordkeeping?
Information on EPA’s CROMERR proposal, including a copy of the proposed rule, is available on the Agency’s website at http://www.epa.gov/cdx/cromerrr/propose/index.html .
