Clarifications on CMDP and SDWIS Prime Questions

Compiled by Brianna Knoppow

States and EPA Regions have a number of questions related to the CMDP. Here we address some of the questions recently submitted at the April, EPA Drinking Water Branch Chiefs’ meeting.

  1. Lab profiles. Which lab profiles are presently integrated in the CMDP system?

EPA does not have access to this information via the CMDP. State users will be able to see all laboratories within their own primacy agency. For primacy agencies not yet with CMDP access, EPA will work with Shared CROMERR Services (SCS) to obtain a list of laboratories that have profiles in the CMDP. This will provide primacy agencies with an idea of which laboratories are submitting, or plan on submitting, data, using the CMDP.

  1. SDWIS Prime. Can a primacy agency use the CMDP with SDWIS State and avoid immediately transitioning to SDWIS Prime?

Yes. Primacy agencies using SDWIS State, but not planning to transition to SDWIS Prime in the near future, can still submit quarterly reports to EPA. EPA will ensure a method for submissions is provided. These primacy agencies will have to use the Data Exchange Engine (DSE) to exchange data between the CMDP and SDWIS State. However, there will be an eventual point in time when EPA will no longer be able to support the DSE for SDWIS State. Additionally, the SDWIS Fed quarterly reporting process with SDWIS Prime will be less labor intensive than with SDWIS State. Furthermore, EPA Regions will manage federal actions in SDWIS Prime, so primacy agencies will have to access SDWIS Prime to view federal actions. There are also many data sharing opportunities between other states and EPA regions that aren’t available unless the primacy agency uses SDWIS Prime. EPA plans to discontinue funding SDWIS State operations and maintenance after March 2019, so primacy agencies will be financially responsible for maintaining SDWIS State. Given the complexity of the system and obsolete technologies used, this may be quite expensive.

  1. SDWIS Prime. Does a state have to use the CMDP when using SDWIS Prime?

No. However, CMDP and SDWIS Prime share the same database. One of the top requirements for the ReST API is the ability to bulk upload sample results to Prime, bypassing the CMDP job management and CROMERR features. With the ReST API, a primacy agency can continue using its existing lab portal and route the data to the SDWIS Prime samples data structures (also used by CMDP) for compliance. While there is no technical barrier to whether or not a state uses CMDP to use Prime, the samples (which are stored in the CMDP data structure) are needed by Prime in order to run compliance determinations.

  1. SDWIS Prime. How will sampling data enter SDWIS Prime while primacy agencies are in the transitioning process?

EPA plans to provide tools that will facilitate copying data (and doing any transformations) from SDWIS State to SDWIS Prime. It will take more work to do this for primacy agencies that do not use SDWIS State since EPA does not know how their data is structured. Mapping their data system to SDWIS Prime is an important early transition activity for primacy agencies not using SDWIS State.

  1. Unregulated contaminants? CMDP is designed to handle federally regulated contaminants. Does the CMDP also handle unregulated contaminants?

CMDP accepts incidentally reported unregulated contaminants that are often from the same family of regulated contaminates. However, the CMDP is not intended to serve as an unregulated contaminant reporting database.

  1. Analytes. Does the CMDP accept primacy agency defined analytes?

No. The CMDP is limited to the analyte list used by SDWIS State and SDWIS Fed.

  1. Quality Control. Do the CMDP samples include quality assurance (QA) information? For example, J-code on a sample result.

No. However, samples data reported via the CMDP may contain one or more qualifiers using the lab Comments field.

  1. Chain of Custody. How does the state administrator follow the chain of custody?

“Chain-of-custody” records may be reported in the CMDP as attachments to a Sample Job.  Chain of Custody information may also be provided using the Comment section in the sample metadata, if the chain-of-custody applies to the entire Sample Job.

However, is up to the lab to provide these data to the primacy agency.  It is important to note that the CMDP is not a document management system.

Additionally, when the lab Certifier electronically signs Jobs before submission to the State, using the SCS electronic signature service, it is certifying that it followed procedures.

  1. CROMERR. How will Regions know which states are CROMERR certified?

To see which states are CROMERR certified, states may visit the CROMERR applications page. The CMDP will be listed under the ‘System’ column. Users may then view the ‘Application Status’ column to verify if a state’s application has been approved. Note that this page also includes the status of CROMERR for media programs other than drinking water.

  1. Funding. How do allocated DWSRF funds get to the BPA?

The state works with its EPA Regional office grants specialist to withhold funds from their Exchange Network, STAG, other EPA grant, or DWSRF set-aside funds. The withheld funds are then reprogrammed by the grants specialist to the BPA contract (this part of the process is internal to EPA).

State managers using DWSRF set-aside funds for this purpose should keep in mind that the state must still provide the capitalization grant’s full 20 percent state match, which is based upon the full allotment (calculated prior to any in-kind service funds held back at the EPA). For example, if a state’s DWSRF allotment is $100 and the state asks the EPA to withhold $3 for the CMDP BPA, the state must still provide a 20 percent state match of $20 ($100 *.2), rather than a 20 percent calculation based upon $97. Other calculations, including Congress-mandated additional subsidy, are also based upon the full capitalization grant amount.

  1. Drinking Water Watch. Will Drinking Water Watch be integrated with SDWIS Prime?

No. Drinking Water Watch is an interfacing application maintained by some primacy agencies. States will continue using their existing drinking water watch web sites but will draw on data housed in SDWIS Prime.