Innovate! has been supporting implementation of the Cross Media Electronic Reporting Rule (CROMERR) for the past five years. CROMERR provides the legal framework for electronic reporting (ER) under all of the Environmental Protection Agency’s (EPA) environmental regulations. In support of the CROMERR business processes, we have worked with the CROMERR Technical Review Committee (TRC) and IESD staff to create meeting agendas, minutes, and other supporting materials. We have also managed the processing of physical records and online storage, as well as training and outreach efforts. As a part of this effort, Innovate! has supported the improvement of CROMERR business processes so they are efficient, available, and actionable for all parties involved. Innovate! consultants have assessed the business requirements, evaluated existing resources, and then re-engineered the way documentation was being collected, stored, and distributed with extensive use of existing resources such as the EPA Portal.

More recently, Innovate! has supported the migration of CROMERR business processes to the CROMERR Program and Stakeholder Management (PSM) system. PSM is a custom implementation of a Salesforce.com platform that integrates database records, online file storage, multiple distinct spreadsheets, and email logs, to support the reduction of TRC and OEI levels of effort in managing the application approval process. Innovate!’s task lead is a certified Salesforce.com administrator with intimate knowledge PSM; under his direction, Innovate has provided development, administrator, security, and training and outreach support for PSM implementation. To provide for quick and efficient system development, we have leveraged existing prototypes and requirements, creating custom Salesforce.com components – such as junction objects, email handlers, and visual force pages – as needed. To preserve data integrity, we have coordinated data integration and quality assurance efforts supported by appropriate technical documentation. We have also drafted components of the PSM system security plan and worked to code and configure the system to uphold required security functions. In addition, to promote PSM user adoption, we have supported training curriculum development and delivery, and user outreach. As needed, we work directly with PSM users to educate them on the value of the system and provide help desk-like services such as technical support and troubleshooting.

Innovate! has also supported the assessment of EPA and state electronic reporting systems for compliance with CROMERR requirements, and has provided analyses of associated issues. For this effort, Innovate! has drawn on the expertise of a current employee who chaired the EPA-wide workgroup responsible for CROMERR regulation and policy over the course of an 8-year period while employed at the EPA. This individual developed the overall CROMERR rulemaking approach and strategy and wrote the proposed and final regulation as published in the Federal Register. His work also included CROMERR implementation: the development of the CROMERR system “Checklist”, the design and presentation of CROMERR training for EPA regional and state staff, and the assessment of more than 50 EPA and state electronic reporting systems under CROMERR. This expertise has proven to be an invaluable resource across all of Innovate’s CROMERR activities.

From a technical perspective, Innovate! developed, tested and delivered the EPA-CDX CROMERR System.

  • Provides an authentication, integrity and non-repudiation framework for EPA applications. The system provides registration, authentication/authorization, 20-5-1 question/answer validation, document signing and Copy of Record (COR) archiving services.
  • Enables the users to perform all the steps for the signing of web forms and documents.
  • Provides a component (CROMERR Widget) to complete the document and web form signing process.
  • Provides archiving for the COR documents as well as CROMERR events.
  • Reusable/generic User Interface (UI) and can be accessed by helpdesk, end users and administrators.

Innovate! also provided the State of Indiana with our generic CROMERR Application that allows end users to electronically sign web forms and documents. The CROMERR Application has been designed to meet the requirements of the CROMERR Rule including electronic signature, Copy of Record (COR), authentication, 20-5-1 and various non-repudiation functions. An eSignature Widget is at the core of the CROMERR Application – it allowed Indiana developers to quickly add CROMERR compliant electronic signatures into the EMITS web application. Moreover, the CROMERR Application User Provider framework allowed the Indiana EMITS team to quickly integrate it with their existing user repository over Web Services. The scope of the work included delivery of the CROMERR software, installation assistance, documentation and technical integration support. Indiana estimates by re-using the CDX CROMERR application, they saved over $20,000 in contractor work effort and 6 weeks of internal staff time. In the future we envision many states and tribes integrating this generic CROMERR application into their internal systems.

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