If you’re a CIP-013 groupie, you may have noticed that I focus on CIP-013 R1.1 a lot in this blog, and not so much on the other CIP-013 requirements. In fact, I’ve only discussed R3 once, and I’ve never discussed R2, since all it says is “Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1.” Not much to discuss there!
And in R1, I focus on R1.1, instead of R1.2. Is this because I don’t like big words like “authenticity” and “Interactive Remote Access” – both of which are found in R1.2? No. While it’s true that I don’t approve of excessive polysyllabilality, I myself have been known to use long words at times. The reason I focus on R1.1 is that this is without doubt the heart of CIP-013. In R1.1, the entity draws up their Supply Chain Cyber Security Risk Management plan, while in R2 and R3 the plan is implemented and then reviewed annually. If the entity doesn’t draw up a good plan because they don’t know what to put in it, they obviously won’t implement anything worth implementing, or review anything worth reviewing. For that entity, the whole CIP-013 exercise will be a waste of time and money.
But the loss will go beyond the entity. As the Russian cyber attacks recently brought into the open by DHS show, the bad guys have figured out that the best way into every large organization nowadays – and most certainly electric utilities – isn’t to mount a full assault on the front gate of the castle, with its myriad protections. It’s to go around to the back door with a single lock on it that the tradesmen use. To continue the somewhat strained metaphor, if the attackers can find a place to hide in the cart that brings in the hay for the animals, they stand a much better chance of breaking in to the castle. So supply chain attacks are already becoming the vector of choice for the discriminating cyber hacker. This is the biggest vulnerability for the electric sector, even though as of now there haven't been any successful supply chain attacks on control networks, except for two wind turbines.
In this post from August, I stated that I think CIP-013 R1.1 is un-auditable, because it provides nothing for the entity to key on to include in their plan – and I used CIP-010 R4 Attachment 1 as my poster child for a good plan-based requirement. As long as NERC auditors are only allowed to focus on whether the entity has complied strictly with the specific wording of a requirement (which is the case now, unfortunately), a requirement that doesn’t have some specific wording for the auditors to key on is simply un-auditable. CIP-010 R4 Attachment 1 provides specific (although not prescriptive) criteria for what should be in the plan; CIP-013 R1.1 doesn’t.
However, I’m exaggerating when I imply that R1.1 provides no help at all to the entity as they develop their plan; there is some information in there, and it is enough to get you started in writing your plan. This post will list the information that I have found in R1.1. It doesn't provide anything near a workable guide to developing a CIP-013 plan, but it at least is a start.
Here’s the full text of R1.1:
(The plan(s) shall include)…one or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from: (i) procuring and installing vendor equipment and software; and (ii) transitions from one vendor(s) to another vendor(s).
And here’s what I get out of this all-too-brief text:
- The last time I took a close look at R1.1 in this blog, I decided there was no significance to be assigned to the fact that it begins by mandating “..processes used in planning..” That seems to be the Department of Redundancy Department at work. You are developing a plan for supply chain cyber security risk management. You aren’t developing a plan for “processes used in planning supply chain cyber security risk management”. So ignore these words.
- The plan is to “identify and assess cyber risks to the BES from vendor products and services…” You may notice that there’s nothing about mitigating those risks. I assume this is just an oversight. Of course, being required to identify and assess risks, but not having to do anything to mitigate those risks, wouldn’t make any sense. So you need to read this as a requirement to “identify, assess and mitigate” risks.
- But what are these risks you have to mitigate? Aye, there’s the rub. CIP-010 R4 also requires you to develop a risk management plan. In Attachment 1 to that requirement, you find a list of types of risk that you need to mitigate in the plan, as well as high-level suggestions for how to mitigate these risks. What do you find in CIP-013 R1.1? You find the two bullet points (i) and (ii). What are these? Are these risks to be mitigated, too?
- No, I call these “risk areas”. They are essentially subdivisions of the overall world of supply chain cyber security. They aren’t risks themselves, so you still need to find risks to address within each one of these areas. But this does at least provide guidance on where to start.
- What specifically are the risk areas? Even though there are two bulleted points, there are actually five risk areas. Notice that the two points are preceded by the words “risks…from vendor products or services..” This means you need to consider each of the two bullet points from the points of view of both vendor products and vendor services.
- Next, notice that bullet (i) is “procuring and installing vendor equipment and software”. Breaking this up yields “procuring vendor equipment and software” and “installing vendor equipment and software”. Each of these is itself a risk area, but remember that we are supposed to look at these from the points of view of both products (which means hardware and software) and services. So this means we have to add “procuring vendor services” and “installing vendor services” to the list of risk areas.
- Of course, you don’t “install” services! But you do utilize them. So I reword the second of these as “utilizing vendor services”.
- As for bullet point (ii), it’s already sufficiently general that we don’t need to list separate risks areas for products and services.
So here’s my list of risk areas that need to be addressed in your CIP-013 plan (and these are enforceable, since they are explicitly stated in the requirement, even if they’re a little hard to see initially):
a) Procuring vendor equipment and software;
b) Installing vendor equipment and software;
c) Procuring vendor services;
d) Utilizing vendor services; and
e) Transitions between vendors.
Now you know at least where to begin as you develop your plan. Your plan needs to address each of these five risk areas. From there, you need to find important risks to mitigate in each area. There’s more information for your plan, to be gleaned from R1.2. I’ll discuss that in another post soon.
Any opinions expressed in this blog post are strictly mine and are not necessarily shared by any of the clients of Tom Alrich LLC.
If you would like to comment on what you have read here, I would love to hear from you. Please email me at firstname.lastname@example.org. Please keep in mind that if you’re a NERC entity, Tom Alrich LLC can help you with NERC CIP issues or challenges like what is discussed in this post – especially on compliance with CIP-013. And if you’re a security vendor to the power industry, TALLC can help you by developing marketing materials, delivering webinars, etc. To discuss any of this, you can email me at the same address.