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Catalog of Control Systems Security: Recommendations for Standards Developers

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NRC RG 5.71 C.3.1.3, C.4.2, App. B.5.4, App. B.5.5, App. C.11.4<br />

2.6.4 Monitoring Configuration Changes<br />

2.6.4.1 Requirement<br />

The organization implements a process to monitor changes to the control system and conducts<br />

security impact analyses to determine the effects <strong>of</strong> the changes.<br />

2.6.4.2 Supplemental Guidance<br />

Prior to change implementation, and as part <strong>of</strong> the change approval process, the organization analyzes<br />

changes to the control system <strong>for</strong> potential security impacts. After the control system is changed, the<br />

organization should check the security features to ensure that the features are still functioning properly.<br />

<strong>Security</strong> impact analysis may also include an assessment <strong>of</strong> risk to understand the impact <strong>of</strong> the changes<br />

and to determine if additional safeguards and countermeasures are required. <strong>Security</strong> impact analysis is an<br />

important activity in the ongoing monitoring <strong>of</strong> security controls in the control system. The organization<br />

should audit activities associated with configuration changes to the control system. The organization<br />

considers control system safety and security interdependencies.<br />

2.6.4.3 Requirement Enhancements<br />

None<br />

2.6.4.4 References<br />

NIST SP 800-53r3 CM-4<br />

CAG CC-4<br />

API 1164r2 3.6, Annex A, Annex B.3.1.1.1<br />

NERC CIPS CIP 007-3. B.R1, B.R3<br />

NRC RG 5.71 C.4.3, App. C.3.4, B.5.4, App. C.11.7, App. C.11.8<br />

2.6.5 Access Restrictions <strong>for</strong> Configuration Change<br />

2.6.5.1 Requirement<br />

The organization:<br />

1. Defines, documents, and approves individual access privileges and en<strong>for</strong>ces physical and logical<br />

access restrictions associated with configuration changes to the control system<br />

2. Generates, retains, and reviews records reflecting all such changes.<br />

2.6.5.2 Supplemental Guidance<br />

Planned or unplanned changes to the hardware, s<strong>of</strong>tware, and/or firmware components <strong>of</strong> the control<br />

system can potentially have significant effects on the overall security <strong>of</strong> the system. Accordingly, only<br />

qualified and authorized individuals are allowed to obtain access to control system components <strong>for</strong><br />

purposes <strong>of</strong> initiating changes, including upgrades, and modifications. The organization establishes strict<br />

terms and conditions <strong>for</strong> installing any hardware or s<strong>of</strong>tware on control system devices (e.g., modems,<br />

wireless adapters, multi-function printers, games, word processing s<strong>of</strong>tware).<br />

In addition, maintaining records <strong>of</strong> access is essential <strong>for</strong> ensuring that configuration change control is<br />

being implemented as intended and <strong>for</strong> supporting after-the-fact actions should the organization become<br />

aware <strong>of</strong> an unauthorized change to the control system. Access restrictions <strong>for</strong> change also include<br />

s<strong>of</strong>tware libraries. Examples <strong>of</strong> access restrictions include physical and logical access controls, workflow<br />

automation, media libraries, abstract layers (e.g., changes are implemented into a third-party interface<br />

rather than directly into the control system component), and change windows (e.g., changes occur only<br />

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