Recently we posted an article on the topic of mandatory electronic reporting for EPA regulatory compliance, since the EPA has made its intentions to make the shift to digital very clear.
It boils down to this: electronic reporting offers a wide range of benefits - including better QAQC, it should take less time to complete and submit, and theoretically its more convenient.
However, for some electronic reporting presents a complete turnaround in how reporting works, which may prove to be a hardship for those professionals who have already mastered paper reporting.
In addition, the first few years in which electronic reporting is the only way to report will probably be difficult for nearly everyone, resulting in a lot of inaccurate reports, frustration, and late submissions.
So we took the topic to you and listened to what you had to say. Here are some of the best reactions we received to the idea of switching to mandatory environmental compliance reporting (names have been removed to protect commenters’ privacy):
“I have done electronic reporting through CDX under three different programs (TRI, TSCA CDR, and GHG) for several companies. The biggest problem we have run into is that the CDX logins are person specific not company specific. Whenever a person leaves, the new person has to recreate logins, sign ESA's, and get setup in the programs - sometimes much easier said than done!
Additionally, each program uses different terminology. The person responsible for certifying the report can be called the "certifying official", the "authorized official", or the "designated representative". The programs allow for another person to submit the data who can be called the "agent", "submitter", or some other term. This gets very confusing!
Most of the certifying officials that I know are very busy running their business - they do not want to be bothered with dealing with the electronic programs. They want their environmental people (either in house or consultants) to prepare the report, tell them what's in it, answer questions, and then submit the report. They do understand their responsibilities but they would much rather sign a certification statement and then let someone else deal with the electronics.
And don't get me started on registration under OTAQREG for GHG reporting under Subparts LL and MM - what a nightmare!”
“This is a great thing. It will cause disruption at first but five years from now, it will be as basic as email. Not to mention California and other states already do this and though it is challenging, it is a good thing.”
“If EPA wants to go to mandatory electronic reporting then their systems had better be examined to ensure they work prior to release. I just finished a TRI submission to CDX and had some of the addresses get "bounced" because of claimed zip code and address errors. We got that information from the businesses themselves so where is EPA getting their check data base they use to flag errors?”
“It would be interesting to see how security of information is handled; reporting chemical also may invite ‘unwelcome guests’ to the web site(s). I'm not real familiar with the current site due to its complexity, perhaps this is already covered(?)”
“I prefer the electronic reporting. The CAMD D client tool is relatively easy to use and provides good feedback. There are bugs and they do fix them. Webfire is another story. Webfire is very difficult to use and the data is hard to access.”
“The existing web site is very complex and in-depth, interesting to see how effective the information management system is, how effective the information has been in the past, how old information is transferred electronically”
“Will this really expedite EPA's review period demand?”
“Most labs use some form of LIMS. Keeping the data in the digital realm is a good thing. California has a requirement that groundwater data be submitted electronically (in an EDF, not PDF, format.) Because the data are tagged with date/time and location, all data from all reporters in an area can be pulled up to track plumes or for other causes.
However, eyeballs on the data are still important. Just in the last month I found a dilution factor error in a lab report (in a direction that is bad for us.)”
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