This afternoon I tuned-in to a presentation by Tripwire regarding the upcoming release of a NERC CIP policy compliance module that’s due out September 16 for their Tripwire Enterprise product.
I had used Tripwire back in it’s open source days. Back then it was all host-based integrity checking. And that was a Long time ago. I kind of long for those days. The product was simple and reliable. Host based integrity checking, IMHO is still a cornerstone of good security, and I have yet to find a suitable small-footprint replacement.
I must admit that I fell out of touch with the product after it went closed-source and they started building a business around it.
Well, the little script that was has turned into a rather mature, end-to-end, device agnostic policy auditing and compliance solution. Tripwire can audit firewall configurations, router configs, hosts, you name it.
Their Enterprise product is modular, allowing you to install pre-built policy checks for tons of stuff (PCI, CIS, FISMA, COBIT, SOX, ISO 27001, FDCC), or build custom checks.
The purpose of this particular presentation was to learn about a new policy compliance module geared toward evaluating compliance with NERC CIPs.
The North American Electric Reliability Corporation (NERC) Critical Infrastructure Protection (CIP) standards are given, essentially, force of law by the Federal Energy Regulatory Commission (FERC).
I don’t want my reader’s eyes to glaze over, as frequently happens when discussing the myriad of regulatory bodies in the energy space, so I’ll break it down for you:
$1,000,000 per day, per infraction for failure to be in compliance with NERC CIPs.
Let me see if I can explain that in plain English:
$1,000,000 per day, per infraction for failure to be in compliance with NERC CIPs.
The Tripwire policy module focuses on compliance for the technical CIP’s (CIPs 002 to 009, with a focus on 003, 003-6, 005, 007).
Tripwire has a matrix mapping their compliance and auditing checks against the specific NERC CIP requirements, and provides a holistic approach to auditing and assessment.
One nice feature is that where non-compliance is detected, remediation recommendations are presented that can then be attached to a change order so that technicians can implement the recommendations.
The Tripwire people also discussed their products ability to maintain the required auditing and compliance documentation for the minimum required one year.
Concerns
It wouldn’t be one of my posts if I didn’t express some concerns :)
I have two:
1) Does the Tripwire product require an installation on the devices to be audited.
Though I’m not a control system guy, I have heard that some of these devices are extremely ‘fragile’. Certainly no one wants to install a security module that decreases the availability or integrity of a control system device.
I also get nervous because, in some cases, making any modification to a control device can trigger a rather nightmarish change control process that has serious cost and can have serious regulatory implications.
2) Does the Tripwire system generate a great deal of network load while checks are run.
Again, the worry here is that, from what I’ve read, some control networks are extremely sensitive to latency and load.
Spikes in network traffic or device load can have negative consequences.
Special consideration must be given when considering implementing an automated, scheduled auditing system.
Competitors?
Tripwire is a household name in the IT security space, but are there other solutions out there?
Certainly.
Whereas Tripwire is coming from the IT security space, Digital Bond is a control system security research and consulting outfit that, well, specializes in control system security.
Our friends over at Digital Bond have been developing the Bandolier product.
At the moment, the focus of the product seems to be heavily weighted on the assessment side. Nevertheless, there is documentation on how to use Bandolier to test for compliance with the NERC CIP’s.
I expect that as the Bandolier product matures, automated CIP compliance reports may be generated from the product.
Conclusions
I first got interested in control system/criticil infrastructure protection when I began hearing reports of what I perceived to be complete failures of security surrounding SCADA and other control systems.
The more I research, though, I see that there is a lot of work being done in this relatively small space.
And I read more and more about vendors coming to the table.
One neat trend I’m seeing… Vendors who build control system hardware are coming to security outfits with their wares asking for help on how to make them more secure.
Now that’s good stuff right there.
Bill
Updated 20080627:
More vendors joining the automated NERC CIP compliance front:
Nexant, Promia to Offer Compliant Cyber Security to Energy Firms