CROMERR, an acronym for the phrase “Cross Media Electronic Reporting Rule,” was adopted by the US Environmental Protection Agency (EPA) in 2005, for the purpose of providing a unified legal framework for electronic reporting under all of EPA's environmental regulations. CROMERR specifies the requirements for states, tribes and local governments that operated delegated programs to accept electronic reporting, including electronic signatures, from regulated facilities under most environmental regulations. Once a system is put in place that satisfies the requirements of CROMERR, regulated facilities can file electronic reports instead of paper reports, reducing the amount of paper created and transferred, and thereby reducing the cost of reporting and compliance monitoring for both the facilities and the agency operating the delegated program.

CROMERR arose from the need to maintain the same level of corporate and individual responsibility and accountability for electronic reports and records that currently exists in the paper environment and ensure the authenticity of electronic documents submitted in lieu of paper reports. It is imperative for electronic submissions to be able to play the same role as their paper counterparts in providing evidence of what was reported and to what an identified individual certified with respect to the report.

The Oklahoma Department of Environmental Quality (ODEQ) and Premirus Corporation developed and implemented the Edoctus Environmental Portal as a organization-independent, complete solution to the receipt of electronic documents. ODEQ submitted a compliance application to the EPA, and has received approval of the portal design by the technical committee. Oklahoma will be in full production with its compliance portal by October, 2008.

The Edoctus Environmental Portal is available from ODEQ and Premirus at no cost to other agencies working on CROMERR compliance initiatives. The portal is implemented as a web portal and group of rules and rule components in the Edoctus™ Document Center. ODEQ and Premirus jointly sponsor an informational site, www.cromerr.net that includes the full contents of ODEQ’s CROMERR application to the EPA.

In many cases, it is likely that many organizations that come under the requirements of CROMERR will propose and implement vertical, application and/or program specific architectures to comply with CROMERR requirements. The use of Edoctus as a platform for CROMERR compliance demonstrates a different approach—a unified approach that encompasses all applications and programs within an entity that is operating delegated programs. Under this approach, the compliance with the requirements of CROMERR becomes a single, unified, and consist effort, independent of the various programs and their supportive software applications. This approach provides a number of advantages, including lower cost, faster implementation, and a single compliance infrastructure to understand, support, and maintain.

The Edoctus implementation provides a single portal approach to document submission. Representatives of regulated entities, usually referred to as signatories, navigate to the portal, sign in, answer questions that validate their identity, and submit digitally signed documents to the system. These documents are then validated, stored, and routed to the appropriate authority within the agency for acceptance or rejection. This portal can also deliver human readable format (HRF) copies of documents and can create and deliver internally signed documents that can then be validated as having been generated by the regulating entity.

The Edoctus Environmental Portal is available from ODEQ and Premirus at no cost to other agencies working on CROMERR compliance initiatives. It was designed to be organization independent, and can be quickly modified to serve any regulatory entity that wishes to use it. The Edoctus Environmental Portal requires licensing for its underlying components, including Edoctus Document Center, Microsoft SQL Server, and Windows Server 2003 or 2008. Because of the cost effective nature of the Edoctus Document Center product itself, total cost of a compliance solution using Edoctus is significantly less than the cost of an independently developed solution, even in organizations with an existing document management product.