Cyber Security Supply Chain Risk Management
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- Horace Townsend
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1 Cyber Security Supply Chain Risk Management JoAnn Murphy, SDT Vice Chair, PJM Interconnection May 31, 2017 FERC Order No. 829 [the Commission directs] that NERC, pursuant to section 215(d)(5) of the FPA, develop a forward looking, objective driven new or modified Reliability Standard to require each affected entity to develop and implement a plan that includes security controls for supply chain management for industrial control system hardware, software, and services associated with bulk electric system operations. Order No. 829, July 2016 Four objectives as they relate to cyber security of BES Cyber Systems: Software integrity and authenticity Vendor remote access including machine to machine Including security considerations during information system planning Vendor risk management and procurement controls Note: Plans use a risk based approach to allow flexibility to responsible entities as to how to meet those objective. (see Order No. 829 P.13) 2 1
2 Summary of Proposed Changes FERC Order 829 Objective Version 1 of CIP R1 Implement the supply chain cyber security risk management plan for BES Cyber Systems (including Electronic Access Control and Monitoring Systems, Personnel Access Control Systems, and Protected Cyber Assets) R2 Review plan(s) every 15 months Version 2 of CIP R1 Develop the supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems, including specific procurement processes R2 implement plan(s) from R1 now R3 but remained essentially the same Review plan(s) every 15 months plus modifications to other existing CIP Standards No change proposed changes to CIP 003 to cover low impact BES Cyber Systems have been removed No change 1 R3 (software authenticity) R3 removed and moved to >> CIP ( software integrity and authenticity ) Table R1 Part 1.6 added R4 (vendor remote access) R4 removed and moved to >> CIP ( visibility and disabling ) Table R2 Part 2.4/2.5 added 2 3 R5 (Low impact BES Cyber Systems) Removed No change CIP (draft 2) R1-R3 Summary* R1: Develop a supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems. R1.1: Process(es) used in planning for the procurement of BES Cyber Systems R1.2: Process(es) used in procuring BES Cyber Systems that address the following: o Notification by the vendor of vendor identified incidents; o Coordination of responses to vendor identified incidents; o Notification by vendors when access should no longer be granted; o Disclosure by vendors of known vulnerabilities; o Verification of software integrity and authenticity of software/patches; and o Coordination of controls for IRA and system to system remote access. *Refer to CIP (Draft 2) for specific language for each Requirement 4 2
3 CIP (draft 2) R1-R3 Summary* R2: Implement the plan(s) from R1. R2 specifically notes: o Renegotiation or abrogation of existing contracts not required, o Actual contract terms and conditions are out of scope, and o Vendor performance and adherence to a contract are out of scope. R3. Obtain CIP Senior Manager (or delegate) approval of its plan(s) in R1 at least once every 15 calendar months. Previously CIP (draft 1) R2 *Refer to CIP (Draft 2) for specific language for each Requirement 5 CIP (draft) Summary Previously CIP (draft 1) R3: Requires entities to implement a process for verifying the integrity and authenticity of software and firmware and any upgrades to software and firmware before being placed in operation on high and medium impact BES Cyber. Moved this operational requirement into existing CIP standard Proposed change to CIP (Table R1 Part 1.6 added) Added when the method to do so is available to the Entity from the software source to account for situations in which a vendor is unwilling or unable provide needed functionality. 6 3
4 CIP (draft) Summary Previously CIP (draft 1) R4: Requires entities to implement a process for controlling vendor remote access to high and medium impact BES Cyber Systems. Moved this operational requirement into existing CIP standard Proposed change to CIP (Table R2 Part 2.4/2.5 added) Focus on visibility and the ability to disable remote access 2.4 Have one or more methods for determining active vendor remote access sessions (including IRA and system to system) 2.5 Have one or more methods to disable active vendor remote access (including IRA and system to system) 7 Summary R5 Change Previously CIP (draft 1) R5: Require entities to have documented cyber security policies that address software integrity and vendor remote access as they apply to low impact BES Cyber Systems Removed R5 No new planning or procurement plans or policies for Low Impact BES Cyber Systems No new operational requirements on Low Impact BES Cyber Systems. 8 4
5 Implementation Plan and Guidance Implementation Plan: Changed from 12 to 18 months SDT developed Implementation Guidance to provide examples of approaches for complying with CIP The draft includes the following examples: Risk based approach to developing Cyber Security Supply Chain Risk Management plans (R1) o Processes for planning BES Cyber Systems that identify and assess cyber security risks from vendor products or services (R1.1) o Request for proposal or negotiation provisions to address topics (R1.2) Processes for periodically reviewing and approving plans (R3) Implementation Guidance has been submitted for endorsement per NERC s Compliance Guidance Policy 9 Standards Development Process Oct 2016 Mar 2017 Tech Conference 1 st Formal Balloting May nd Formal Comment and Balloting August 2017 NERC Board Adoption September 2017 Deadline for filing 1 st formal comment period January 20 March 6, nd formal comment period May 2 June 15,
6 Contact Information Refer to the Project page for more information to join the list Corey Sellers, Southern Company, SDT Chair at JoAnn Murphy, PJM Interconnection, SDT Vice Chair at 11 6
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