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Home > Issues > Environmental > Other Environmental Issues > Electronic Reporting and Recordkeeping |
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Electronic Reporting and RecordkeepingEPA has received a significant number of negative comments on the proposed rule on electronic recordkeeping CROMERRR and has not yet finalized it. Additional information from the EPA web site BackgroundIn August 2001, EPA published a proposed rule for electronic recordkeeping and reporting. The rule is called the Cross-media, Electronic Reporting and Recordkeeping Rule (CROMERRR). NPRA filed comments on the proposal, and is working with a coalition which includes the American Petroleum Institute and the American Chemistry Council. The primary concern is that the rule would not be voluntary. Industry maintains that the proposed rule -- patterned after a similar FDA rule -- would require a regulated entity to conform to EPA's requirements if compliance data runs through a computer at any point in its life cycle. Since virtually all companies use some type of electronic recordkeeping, the rule would require a huge expenditure to comply with its provisions. In January 2002, EPA activated its Central Data Exchange (CDX), the agency's system for receiving environmental compliance data electronically. EPA will conduct electronic data pilot programs over the next few years. EPA held a public hearing in Washington, DC, in January 2002 to receive input on the proposed Electronic Reporting and Recordkeeping Rule. The agency received a significant number of comments from industry representatives, who object primarily to the recordkeeping provisions. They also pointed out that EPA had seriously underestimated the extent to which electronic recordkeeping is now being used. One industry representative estimated the proposed rule would cost the regulated community an initial investment of about $48 billion, with annual operating costs of $20 billion. A second public hearing was held in Irving, Texas, in late January 2002. The Small Business Administration (SBA) Office of Advocacy submitted comments on the EPA's CROMERRR stating that the proposal does not adequately consider the impact on small business and should be withdrawn. SBA also said the rule would not be voluntary as intended. EPA has now decided to separate electronic record keeping and electronic reporting of environmental data in an upcoming rulemaking. Additional information on this issue for NPRA members can be found at |