One more item to consider regarding the latest NIST SP 800-161r1 guidance is 
the requirement for vulnerability disclosure reporting:

 

RA-5: VULNERABILITY MONITORING AND SCANNING

Enterprises, where applicable and appropriate, may consider providing customers 
with a Vulnerability Disclosure Report (VDR) to demonstrate proper and complete 
vulnerability assessments for components listed in SBOMs. The VDR should 
include the analysis and findings describing the impact (or lack of impact) 
that the reported vulnerability has on a component or product. The VDR should 
also contain information on plans to address the CVE. Enterprises should 
consider publishing the VDR within a secure portal available to customers and 
signing the VDR with a trusted, verifiable, private key that includes a 
timestamp indicating the date and time of the VDR signature and associated VDR. 
Enterprises should also consider establishing a separate notification channel 
for customers in cases where vulnerabilities arise that are not disclosed in 
the VDR. Enterprises should require their prime contractors to implement this 
control and flow down this requirement to relevant sub-tier contractors. 
Departments and agencies should refer to Appendix F to implement this guidance 
in accordance with Executive Order 14028, Improving the Nation’s Cybersecurity.

 

 

 

Thanks,

 

Dick Brooks

  

Active Member of the CISA Critical Manufacturing Sector, 

Sector Coordinating Council – A Public-Private Partnership

 

 <https://reliableenergyanalytics.com/products> Never trust software, always 
verify and report! ™

 <http://www.reliableenergyanalytics.com/> 
http://www.reliableenergyanalytics.com

Email:  <mailto:[email protected]> 
[email protected]

Tel: +1 978-696-1788

 

From: [email protected] <[email protected]> On Behalf Of Dick 
Brooks
Sent: Thursday, May 5, 2022 7:38 PM
To: 'SPDX Technical Mailing List' <[email protected]>
Subject: [spdx-tech] NIST released an updated version of the Cyber Supply Chain 
Risk Management (C-SCRM) Guide (SP 800-161r1) today supporting Executive Order 
14028

 

 

Two Foundational requirements are worth noting:

 

1.      Establish internal processes to validate that suppliers and service 
providers actively identify and disclose vulnerabilities in their products.  
2.      Establish a governance capability for managing and monitoring 
components of embedded software to manage risk across the enterprise (e.g., 
SBOMs paired with criticality, vulnerability, threat, and exploitability to 
make this more automated). 

 

https://www.nist.gov/news-events/news/2022/05/new-eo-guidance-cybersecurity-supply-chain-risk-management
 

 

This supplemental guidance is also noteworthy:

 

SBOMs should be produced using only NTIA-supported SBOM formats that can 
satisfy [NTIA SBOM] EO 14028 NTIA minimum SBOM elements. Enterprises producing 
SBOMs should use [NTIA SBOM] minimum SBOM elements as framing for the inclusion 
of primary components. SBOMs should be digitally signed using a verifiable and 
trusted key. SBOMs can play a critical role in enabling organizations to 
maintain provenance. However, as SBOMs mature, organizations should ensure they 
do not deprioritize existing C-SCRM capabilities (e.g., vulnerability 
management practices, vendor risk assessments) under the mistaken assumption 
that SBOM replaces these activities. SBOMs and the improved transparency that 
they are meant to provide for organizations are a complementary, not 
substitutive, capability. Organizations that are unable to appropriately 
ingest, analyze, and act on the data that SBOMs provide likely will not improve 
their overall C-SCRM posture. Federal agencies should refer to Appendix F to 
implement this guidance in accordance with Executive Order 14028 on Improving 
the Nation's Cybersecurity.

Thanks,

 

Dick Brooks

  

Active Member of the CISA Critical Manufacturing Sector, 

Sector Coordinating Council – A Public-Private Partnership

 

 <https://reliableenergyanalytics.com/products> Never trust software, always 
verify and report! ™

 <http://www.reliableenergyanalytics.com/> 
http://www.reliableenergyanalytics.com

Email:  <mailto:[email protected]> 
[email protected]

Tel: +1 978-696-1788

 





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