Draft guidance adds 'provenance' as an explicit risk category, outlines potentially expensive documentation process.
The Obama administration appears to be taking new steps to address concerns about potential vulnerabilities in the IT supply chain. The National Institute for Standards and Technology has released draft guidance on supply chain risk management. The guidance adds the origin and movements of IT components as a new potential risk factor.
China is not mentioned by name in the 278-page document, "Supply Chain Risk Management: Practices for Federal Information Systems and Organizations," but NIST's guidance for suppliers, integrators, and agency purchasers to maintain a history for components and systems reads like an answer to policies being developed in Congress to put controls on acquisitions of Chinese made IT by the federal government.
Currently, special rules apply to NASA, the Commerce and Justice departments, and the National Science Foundation regarding the acquisition of IT gear and software with Chinese origins, thanks to a provision in the continuing resolution that funds the government. House appropriators are looking to extend the measure into fiscal 2014.
The provision was intended largely to exclude Chinese companies ZTE and Huawei from federal procurement, according to its author, Rep. Frank Wolf (R-Va.) Those two companies were cited in an influential 2012 report from the House Permanent Select Committee on Intelligence as potential threats to national security.
However, current legislation requires that all acquisitions of IT, "produced, manufactured or assembled by one or more entities that are owned, directed or subsidized by the People's Republic of China" be subject to special risk assessment and approval. Currently, NASA is applying the restriction to IT from "any organization incorporated under the laws of the People's Republic of China," according to a June guidance.
NIST's proposed addition of "provenance" to the catalog of risk families could potentially chart a path to complying with the China-sourcing provisions, by adding origin and history to the supply chain risk assessment. According to NIST, "Provenance is used when ascertaining the source of goods such as computer hardware to assess if they are genuine or counterfeit. Provenance allows for all changes from the baselines of systems and components to be reported to specific stakeholders. Creating and maintaining provenance within the ICT supply chain helps achieve greater traceability in case of an adverse event and is critical for understanding and mitigating risks."
Per the draft, a provenance policy should include defined responsibilities for maintaining a history of the origin and movements of IT systems and components, tracking shipping activities, securely sharing information on provenance, and procedures for evaluating the risk exposure of changes to the provenance of a particular item.
This end-to-end documentation, along with the rest of the risk mitigation activities proposed by NIST, could prove expensive, as the draft acknowledges. "Suppliers may select to not participate in procurements to avoid increased costs and therefore limit organizations' technology choices," NIST cautions.
Overall, the document serves to extend the guidance in previous NIST publications, to help agencies pick from a menu of risk mitigation options that are keyed to their level of exposure, and to the sensitivity of their systems. It addresses risks posed by counterfeit and poor quality components, as well as the possibility of malicious software, intellectual property theft, and cyber-espionage envisioned by Congressional critics. NIST will be taking comments on the draft through Oct. 15.
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