mercury product data exchange project - the exchange network

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Check Title on EN Site Andy Bray Northeast Waste Management Officials’ Association (NEWMOA) April 20 th ?, 2010 Mercury Product Data Exchange Project Andy Bray Project Manager Northeast Waste Management Officials’ Association (NEWMOA) Exchange Network National Meeting April 27, 2011

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Check Title on EN Site

Andy Bray

Northeast Waste

Management Officials’

Association (NEWMOA)

April 20th?, 2010

Mercury Product Data

Exchange Project

Andy Bray

Project Manager Northeast Waste

Management Officials’

Association (NEWMOA)

Exchange Network

National Meeting

April 27, 2011

Overview

• Starting with the end in mind - what does

success look like?

• What is the Interstate Mercury Education

and Reduction Clearinghouse (IMERC)?

• Background on mercury-added product

notification reporting requirements

• Outline of Exchange Network-funded

project to:

o Move notification to e-filing

o Make data available through Node 2

What Does Success Look Like?

• Public user interface modernized,

increasing utility of data

• Online reporting launched end of June,

early July 2011

• >95% electronic reporting for 2010

• New data flow established and available to

states/EPA

• Reporting entities, States, and IMERC Staff

save time/resources3

What is IMERC?

• Constituted under the Northeast Waste

Management Officials' Association

(NEWMOA)

• Formed in 2001

• Provides assistance to states with

mercury education & reduction laws

• Acts as a single point of contact for

regulated community and public

4

Current IMERC Member States

5

What are the Product Notification Reporting Requirements?

• What is required?

– mercury content of products

– total mercury used in a single year

• Who does it apply to?

– manufactures, distributors, or importers of

products with intentionally added mercury

• Why is it important?

– informs policy makers, consumers, recyclers,

institutional purchasers, supply chain, etc.

– informs decisions about further action including

phase-outs and product bans 6

Novel Elements of Requirements and the Review Process

• Reporting on products, not

emissions/releases or monitoring/testing

• A single submission & approval through

IMERC provides a streamlined process for

companies to comply with multiple

states’ requirements

• Shared burden of filing review process

means states’ workload significantly

reduced 7

Novel Elements (continued)

• Associations can file for membership

• Reporting on a single neurotoxin over

a broad range of products

• The universe of products covered by

these requirements is enormous

• Toxics in products reporting may be

novel now, but not for much longer!

8

Exchange Network Funded Project

Grant to MassDEP, NEWMOA/IMERC as

Subawardee

• Develop e-filing system

• Establish a Network Node

• Create a Mercury Products Data Flow

• Make the data available through the EN

Browser

• Expand/modernize online data

publishing features 9

Goals of the Project

• Eliminate inefficiencies and potential

errors from paper submission

• Streamline work flow of states’ reviews

• Vastly decrease data publishing lag time

• Improve business rules and processes

• Allow real-time transfer of data set to

EPA, states, or others

o e.g., EPA’s Database on Mercury-Containing

Products and Alternatives:

www.epa.gov/mercury/database.htm 10

11

GovOnline System Components

• User Account Management: user

account establishment, forgotten

password, and user login

• e-Filing: create a new application,

edit existing application, and renewal

(triennial or updated filing)

• Review: administrative review

(NEWMOA), technical review (IMERC),

and approval (NEWMOA/IMERC)12

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Select Type of

Notification

Enter Reporting

Company Info

Manufacturer?

Enter Info for One

Manufacturer

Yes

No

Enter Prod Info

Select Correct

Notification Form

Product Category and

Sub-category

Component Description

and Location

Report Mercury in Each

Component

Report Units in MG or

PPM

Report Range or Exact

Amount

Submit Report

Create / Revise

Reports

E-Filing Business Process Work Flow

Log in

View/Print Report

in PDF Label certification Optional on

dynamic form

Log Into GovOnline

Set Permanent

Password

User Account Establishment

Enter Email Address

E-Filing

System Emails out

Temp Password

Self-Registration

Existing User?

Configure Security

Question(s)

Submit

System Emails out

Credential

(User ID & Temp

Password)

Log Into GovOnline

Configure Security

Question(s)

Set Permanent

Password

No Yes

System Emails out

Temp Password

Log Into GovOnline

Set Permanent

Password

Forgot Password

User has Email

Address?

Yes

NoNEWMOA

Contacts

User

System Emails User

a Security change

confirmation

System Emails User

a Security change

confirmation

No response in

30 days: System

sends 2nd

email

No response in

60 days: Phone

contact

Configure Security

Question(s) if not

done already

Start

Start

End

End

Number of Components

in One Unit of Larger

Product

Purpose of Mercury in

Product of Component

Reporting for Multiple

Manufactures?

Enter Info for Multiple

Manufacturer

YesNo

Association?

User CertifyUpload Manufacturers’

Certification Form

No Yes

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Administrative Review

by NEWMOA

Technical Review by

IMERC

Decision by IMERC

Submit /

Certify Report

Administrative

Comments

Technical

Comments

Reporting Company

Form Deficient?

Make

Corrections

YesSend comment

email to NEWMOA

and applicant

No

Issue Completion /

Approval Letter

System eNotifiies

NEWMOA

NEWMOA / IMERC

Approval

Comments

Review Business Process Work Flow

Decision

Require revision

Ask for clarification

Pass

Administrative

Review Assign package to

IMERC member

Send out 3rd

comment letter in

paper

Need

exemptionSend out email

Manually activate the

notification again

Track exemption state,

reporter, exempt status

System sends 2nd

Comment email to

NEWMOA and

applicant

Apply for

Exemption

Clarify by

email

Response in 30

days?

Response in 60

days?

Yes

No

Make Corrections

and Submit/Certify

Report

No

Yes

Start

End

Demonstration

15

Early Successes of Project

• Data migrated from legacy system

• e-Filing Beta System to State and

reporting entity Beta Testers, 4/29

• Challenges of integrating new public

browse/search with NEWMOA/IMERC

website overcome

• On schedule for e-Filing launch early

July

16

Next Steps

• Beta testing underway, to be

completed mid-May

• System launch anticipated by early July

• Node and flow established Summer

2011

• Project completed, 9/30/2011

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More Information

For more information on IMERC, visit:

www.newmoa.org/prevention/mercury/imerc

Contact: Andy Bray

(617) 367-8558 ext. 306

[email protected]

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