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Standards and procedures is a tool to help bring standards across the MiEHDWIS web application. This will minimize wasted JAD time, and structure future enhancements to the application.

Legal Framework of MiEHDWIS Submissions

The MiEHDWIS legal framework complies with the standards set by the EPA Cross-Media Electronic Reporting Rule. All submissions contain legal authority language and configurations for enforceable compliance and legal action, if necessary:

·        Copy of record

The copy of record must include the electronic signatures, the date and time of receipt, and any other information that records the meaning of the document. 

·        Integrity

The electronic document must not be altered without detection during transmission or after receipt. Any alterations must be fully documented. 

·        Submission

The electronic document must be submitted knowingly and not by accident. 

·        Review and repudiation

The individual who submitted the document must be able to review the copy of record in a human-readable format and repudiate the document if necessary. 

·        Electronic signature

The electronic signature must be valid at the time of signing, and the document must be unable to be altered without detection after signing. 

·        Identity

The identity of the individual who is entitled to use the signature device must be determined. 

 MiEDHWIS combined w/ MILogin will use 3rd party ID proofing for all users of the system. Certifier Agreements will be required for users who are submitting EPA required eReporting compliance monitoring results per CROMERR.

Permits

- All permits should have a custom approval stamp, no signature box

Certifier Agreement – CWS Specific Activities

Yes, Safe Drinking Water Act (SDWA) Compliance Monitoring falls under the EPA's Cross-Media Electronic Reporting Rule (CROMERR), meaning that data related to SDWA compliance monitoring must be electronically reported through the CROMERR system, which provides a legal framework for submitting environmental compliance data electronically across different EPA regulatory programs. 

Key points about CROMERR and SDWA compliance monitoring:

  • Electronic reporting:

CROMERR allows public water systems (PWSs) to submit their SDWA compliance monitoring data electronically to the EPA. 

  • Regulatory framework:

CROMERR establishes the legal basis for electronic reporting of data across various EPA environmental regulations, including the SDWA. 

  • State involvement:

States that have primacy under the SDWA can also use CROMERR to manage and submit compliance monitoring data from PWSs within their jurisdiction. 

CROMERR applies to electronic documents submitted to the EPA under Title 40 of the CFR.

CROMERR does not apply to:

  • Documents submitted via fax, magnetic or optical media;

  • Data transfers between EPA and state, tribal or local governments when the transfers are part of their authorized programs or part of administrative arrangements with the EPA ;

  • Submissions to state, tribal or local governments not under their EPA-authorized programs; and

  • Grants, cooperative agreements and other forms of financial assistance reporting under Title 40 of the CFR.
    See: Technical Amendment of CROMERR

Inspections

Templates

Standardize Template:

Activity types

EH activity types need to be renamed with more externally facing appropriate names

Document management

CM

FOIA

accessibility - both external and internal

Workflow

Applications

All applications will be signed w/ a PIN and attestation check box regardless if Certifier Agreement is needed.

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