Joe Weiss has an interesting blog
post, Why SOCs are not comprehensive enough for ICS cyber security, over on
ControlGlobal.com. At first glance, it is a re-working of a common complaint of
Joe’s, the inability to initially differentiate between control system errors
and cyber-attacks; a very important problem in process industries. But Joe
points out a very real need to coordinate safety, physical security and
cybersecurity activities in the process environment. And that is worth serious
discussion.
Joe and I have talked about this on more than a couple of
occasions. We both got into the cybersecurity world via the process side of
operations; Joe in nuclear power plant engineering and me as a manufacturing
process chemist. For both of us, process safety was an important consideration
in everything we did.
Safety Reviews
A key tool that we both have used (with a variety of names)
is the process hazard analysis, or PHA. In the chemical industry, this is a
process for looking at the chemical manufacturing process that employs a step
by manufacturing step analysis of a process to identify all of the things that
can go wrong.
While techniques vary, each step of the process is looked
at. A team of individuals (representing the various areas of expertise involved
in a modern manufacturing environment) looks at each process variable
(temperature, mixing, pressure, ingredient addition, etc.) to determine what
would happen if the variable were changed. If the consequence raises a safety
issue, the potential causes of the non-standard situation are identified and
compensating controls are identified to prevent the non-standard occurrence. As
the potential consequence get worse, the team is required to identify more
mitigation measures.
One of the variables that is always included in these
reviews is operator error. When there is an extensive process history available
(these PHAs are periodically re-done, even if no changes are made to the
process), then each of the operator errors that have occurred in the past is
specifically include when the appropriate portion of the process is reviewed.
Otherwise, the team (which always includes at least one operator and an
operations supervisor) looks at what types of operator errors might be expected
to be made.
The one operator error that is almost never included is a
deliberate attempt by the operator to sabotage the process. This is because it
is almost impossible to mitigate this type of ‘operator error’. The only effective
mitigation is the implementation of a two-man rule where an operation can only
be triggered by operating two physically separated controls nearly
simultaneously. This is a very expensive (both in engineering and manpower) and
used in only the most extreme situations.
An item that is always included in the list of things that
can go wrong is the failure of a piece of process equipment. Pumps, valves,
sensor, actuators can all fail and Father Murphy is well known by all process
professionals. Common mitigation measures include routine calibration,
inspection and schedueled preventative maintenance of process equipment. In
situations where equipment failure has the most extreme consequences a common
technique is to have parallel processing capability installed where the failed
piece of equipment can be bypassed automatically or by simple operator action.
Where critical sensors are a concern, multiple and independent sensors are
installed and allowable output variations are established.
Security Reviews
Industry has been slower to conduct formal physical security
reviews of their facilities. Until 9-11, most such reviews (nuclear power
generation facilities excepted) were primarily directed at inventory shrink
more than preventing attacks on the facility. Since 9-11 that has changed and
there has been more attention paid at preventing terrorist attacks and stopping
active shooter situations.
Most physical security reviews (there has not been the level
of standardization of security reviews as we have seen with safety reviews)
focus on identifying critical portions of the facility and positing what
standard attack scenarios are expected and then placing controls in place to
deter, delay and detect such events. As in safety reviews, a physical security
review increases the mitigation measures employed as the potential consequences
(or the probability) of attack increases.
Formal cybersecurity reviews for the process industries are
much less common and seem (from the limited data that I have seen) to focus on
vulnerability management (patching) and access controls. We are just starting
to see implementation of tools to actively monitor process controls to detect
intrusions.
Linking Safety and Security
Safety and security have very similar purposes in the
process industry, prevention of unintended consequences, particularly hurtful
consequences. In very many ways they are two sides of the same coin. Safety
protects against random system failures and security prevents system failures
caused by deliberate actions. Understanding the potential consequences of any
given system failure allows for prioritization of costs and efforts.
Security folks need to have representation on the PHA teams.
Not so much for their contributions to safety (though that is an obvious
benefit), but so that they can truly understand the critical portions of the
process environment. If they understand what the key safety components of the
control system are, they may be able to plan a more effective defense-in-depth
that provides additional security against intrusion (or more quickly identifies
intrusion) into those critical parts of the control system.
Likewise, safety people and process people need to be
represented on the security reviews, both physical and cyber (if those are done
separately). Their input will be necessary to understand how security measures
will impact operations and safety. Planning for a police response to an active
shooter incident at a facility handling flammable materials will require
careful consideration of safety issues. Allowing for multiple (and
contemporaneous) operator logon to controls systems may be necessary. These are
just two of the possible operations and safety considerations that need to be
accounted for in a security review.
Protecting facilities from incidents that impact operations
or the local community is the goal of both safety and security managers. Close
cooperation between the two and with the operations team is something that has
to take place for all three teams to succeed in supporting a successful
business.
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