Categorie: Cyber security hazard

Inherent more secure design

The question I raise in this blog is: “Can we reduce risk by reducing consequence severity?” Dale Peterson touched upon this topic in his recent blog.

It has been a topic I struggled with for several years, initially thinking “Yes, this is the most effective way to reduce risk”, but now many risk assessments (processing thousands of loss scenarios) later I come to the conclusion it is rarely possible.

If we visualize a risk matrix with horizontally the likelihood and vertically the consequence severity, we can theoretically reduce risk by either reducing the likelihood or the consequence severity. But is this really possible in today’s petro-chemical, refining, or oil and gas industry? Let’s investigate.

If we want to reduce security risk by reducing consequence severity, we need to reduce the loss that can occur when the production facility fails due to a cyber attack. I translate this in we need to create an inherently safer design.

This topic is already a very old topic addressed by Trevor Kletz and Paul Amyotte in their book “A handbook for inherently Safer Design, 2nd edition 2010”. This book is based on an even earlier work (Cheaper, safer plants, or wealth and safety at work: notes on inherently safer and simpler plants – Trevor Kletz 1984) from the mid-eighties which shows that the drive to make plants inherently safer is a very old objective and a very mature discipline. Are there any specific improvements to the installation that we did not consider necessary from a process safety point of view, but should be done from an OT security point of view?

Let’s look at the options we have. If we want to reduce the risk induced by the cyber threat we can approach this in several ways:

  • Improve the technical security of the automation systems, all the usual stuff we’ve written a lot of books and blogs about – Likelihood reduction;
  • Improve automation design, use less vulnerable communication protocols, use more cyber-resilient automation equipment – Likelihood reduction;
  • Improve process design in a way that the threat actor has less options to cause damage. For example do we need to connect all functions to a common network so we can operate them centrally, or is it possible to isolate some critical functions making an orchestrated attack more difficult – Likelihood / consequence reduction;
  • Reduce the plant’s inventory of hazardous materials, so if something would go wrong the damage would be limited. This is what is called intensification/minimization – Consequence reduction;
  • An alternative for intensification is attenuation, here we use a hazardous material under the least hazardous conditions. For example storing liquefied ammonia as a refrigerated liquid at atmospheric pressure instead of storage under pressure at ambient temperature – Consequence reduction;
  • The final option we have is what is called substitution, in this case we select safer materials. For example replacing a flammable refrigerant by a non-flammable one – Consequence reduction.

So theoretically there are four options that reduce consequence severity. In the past 30 years the industry has invested very much in making plants more safe. There are certainly still unsafe plants in the world, partially a regional issue / partially lack off regulations, but in the technologically advanced countries these inherent unsafe plants have almost fully disappeared.

This is also an area where I as OT security risk analyst have no influence, if I would suggest in a cyber risk report that it would be better for security risk reduction to store the ammonia as a refrigerated liquid they would smile and ask me to mind my own business. And rightfully so, these are business considerations and the cyber threat is most likely a far less dangerous threat than the daily safety threat.

Therefor the remaining option to reduce consequence severity seems to be to improve process design. But can we really find improvements here? To determine this we have to look at where do we find the biggest risk and what causes this risk?

Process safety scenarios where we see the potential for severe damage are for example: pumps (loss of cooling, loss of flow), compressors, turbines, industrial furnaces / boilers (typically ignition scenarios), reactors (run-away reactions), tanks (overfilling), and the flare system. How does this damage occur? Well typically by stopping equipment, opening or closing valves / bypasses, manipulating alarms / measurements/positioners, overfilling, loss of cooling, manipulating manifolds, etc.

A long list of possibilities, but primarily secured by protecting the automation functions. So a likelihood control. The process equipment impacted by a potential cyber attack are there for a reason. I never encountered a situation where we identified a dangerous security hazard and came to the conclusion that the process design should be modified to fix it. There are cases where a decision is taken not to connect specific process equipment to the common network, but this is also basically a likelihood control.

Another option is to implement what we call Overrule Safety Control (OSC) this is a layer of safety instrumentation, which cannot be turned off or overruled by anything or anybody. When the process conditions enter a highly accident-prone, life-safety critical state such as for example the presence of hydrogen in a sub-merged nuclear reactor containment (mechanically open the enclosure to flood the containment with water) or the presence of methane on an oil drilling rig, an uninterruptible emergency shutdown is automatically triggered. However this is typically a mechanical or fully isolated mechanism because as soon as it has an electronic / programmable component it can be hacked if it would be network connected. So I consider this solution also as a yes/no connection decision.

I don’t exclude the possibility that situations exist where we can manage consequence severity, but I haven’t encountered them in the past 10 years analyzing OT cyber risk in the petro-chemical, refining, oil & gas industry apart from these yes / no connect questions. The issues we identified and addressed were always automation system related issues, not process installation issues.

Therefor I think that consequence severity reduction, though the most effective option if it would be possible, is not going to bring us the solution. So we end up focusing on improving automation design and technical security managing the exposure of the cyber vulnerabilities in these systems, Dale’s suggested alternative strategy seems not feasible.

So to summarize, in my opinion there is not really an effective new strategy available by focusing on reducing cyber risk by managing consequence severity.

There is no relationship between my opinions and references to publications in this blog and the views of my employer in whatever capacity. This blog is written based on my personal opinion and knowledge build up over 43 years of work in this industry. Approximately half of the time working in engineering these automation systems, and half of the time implementing their networks and securing them, and conducting cyber security risk assessments for process installations since 2012.

Author: Sinclair Koelemij

OTcybersecurity web site

OT security engineering principles

Are there rules an engineer must follow when executing a new project? This week Yacov Haimes passed away at the age of 86 years. Haimes was an American of Iraqi decent and a monument when it comes to risk modeling of what he called systems of systems. His many publications among which his books “Modeling and Managing Interdependent Complex Systems of Systems” (2019) and “Risk Modeling, Assessment, And Management” (2016) provided me with a lot of valuable insights that assisted me to execute and improve quantitative risk assessments in the process industry. He was a man who tried to analyze and formalize the subjects he taught and as such created some “models” that helped me to better understand what I was doing and guide me along the way.

Readers that followed my prior blogs know that I consider automation systems as Systems of Systems (SoS) and have discussed these systems and their interdependencies and interconnectedness (I-I) often in the context of OT security risk. In this blog I like to discuss some of these principles and point to some of the gaps I noticed in methods and standards used for risk assessments conflicting with these principles. To start the topic I introduce a model that is a merger between two methods, on one side the famous 7 habits of Covey and on the other side a system’s development process, and use this model as a reference for the gaps I see. Haimes and Schneiter published this model in a 1996 IEEE publication, I kind of recreated the model in Visio so we can use it as a reference.

A holistic view on system’s engineering Haimes and Schneiter (C) 1996 IEEE

I just pick a few points per habit where I see gaps between the present practice advised by standards of risk engineering / assessment and some practical hurdles. But I like to encourage the reader to study the model in far more detail than I cover in this short blog.

The first Stephen Covey habit is, habit number 1 “Be proactive” and points to the engineering steps that assist us in defining the risk domain boundaries and help us to understand the risk domain itself. When we start a risk analysis we need to understand what we call the “System under Consideration”, the steps linked to habit 1 describe this process. Let’s compare this for four different methods and discuss how these methods implement these steps, I show them above each other in the diagram so the results remain readable.

Four risk methods

The ISO 31000 is a very generic model, that can be used both for quantitative risk assessment as well as qualitative risk assessment. (See for the definitions of risk assessments my previous blog) The NORSOK model is a quantitative risk model used for showing compliance with quantitative risk criteria for human safety and the environment. The IEC/ISA 62443.3.2 model is a generic or potentially a qualitative risk model specifically constructed for cyber security risk as used by the IEC/ISA 62443 standard in general. The CCPS model is a quantitative model for quantitative process safety analysis. It is the 3rd step in a refinement process starting with HAZOP, then LOPA, and if more detail is required than CPQRA.

Where do these four differ if we look at the first two habits of Covey? The proactive part is covered by all methods, though CCPS indicates a focus on scenarios, this is primarily so because the HAZOP covers the identification part in great detail. Never the less for assessing risk we need scenarios.

An important difference between the models rises from habit 2 “Begin with the end”. When we engineer something we need clear criteria, what is the overall objective and when is the result of our efforts (in the case of a risk assessment and risk reduction, the risk) acceptable?

This is the first complexity and strangely enough are these criteria a hot topic between continents, my little question “when is risk acceptable?” is for many Americans an unacceptable question, the issue is their legal system which mixes “acceptability” and “accountability” so they translate this into “when is risk tolerable”. However the problem here is that there are multiple levels for tolerable. European law is as usual diverse, we have countries that follow the ALARP principle (As Low As Reasonably Practical) and we have countries that follow the ALARA principle (As Low As Reasonably Achievable). ALARP has a defined “DE MINIMIS” level, kind of a minimum level where we can say risk is reduced to a level that is considered an acceptable risk reduction by a court of law. Contrary to ALARA where we need to reduce the risk to the level it is no longer practicable, so there is no cost criterium but only a pure technical criterium.

ALARP, ALARA comparison

For example the IEC/ISA 62443-3-2 standard compares risk with the tolerable level without defining what that level is. For an ALARA country (e.g. Germany, Netherlands) that level is clearly defined by the law and the IEC / ISA interpretation (stopping further risk reduction at this level) would not be acceptable, for an ALARP country (e.g. UK) the limits and conditions are also well defined but cost related. The risk reduction must go all the way to the DE MINIMUS level if cost would allow it. Which is in cyber security for a chemical plant often the case, this because the cost of a cyber incident – that can cause one or multiple fatalities – in the UK this cost is generally higher than the cost of the cyber security measures that could have prevented it. The cost of a UK fatality is set to approx. 1.5 million pound, actually an American is triple that cost 😊according to the US legal system, the Dutch and Germans (being ALARA) are of course priceless.

So it is important to have clear risk acceptance criteria established and objectives when we start a risk assessment. If we don’t – such as is the case for IEC/ISA 62443.3.2 comparing initial and residual risk with some vaguely defined tolerable risk level – the risk reduction most likely fails a legal test in a court room. ALARP / ALARA are also legal definitions, and cyber security also needs to meet these. Therefore the step risk planning is an essential element of the first NORSOK step and in my opinion should always be the first step, engineering requires a plan towards a goal.

Another very important element according Haines is the I-I (interdependencies, interconnectedness) element. Interconnectedness is covered by IEC/ISA 624433.2 by the zone and conduit diagram, conduits connect zones, though these conduits are not necessarily documented at the level allowing us to identify connections within the zone that can be of relevance for cyber risk (consider e.g. ease of malware propagation within a zone).

Interdependencies are ignored by IEC/ISA 62443. The way to identify these interdependencies is typically conducting a criticality analysis or a Failure Mode and Effect Analysis (FMEA). Interdependencies propagate risk because the consequence of function B might depend on the contribution of function A. A very common interdependency in OT is when we take credit in a safety risk analysis for both a safeguard provided by the SIS (e.g. a SIF) and a safeguard provided by the BPCS (e.g. an alarm), if we need to reduce risk with a factor 10.000, there might be a SIL 3 SIF defined (factor 1000) and the BPCS alarm (factor 10). If a cyber attack can disable one of the two the overall risk reduction fails. Disabling process alarms is relatively easy to do with a bit of ARP poisoning, so from a cyber security point of view we have an important interdependency to consider.

Habit 1 and 2 are very important engineering habits, if we follow the prescriptions taught by Haines we certainly shouldn’t ignore the dependencies when we analyze risk as some methods do today. How about habit 3? This habit is designed to help concentrate efforts toward more important activities, how can I link this to risk assessment?

Especially when we do a quantitative risk assessment vulnerabilities aren’t that important, threats have an event frequency and vulnerabilities are merely the enablers. If we consider risk as a method that wants to look into the future, it is not so important what vulnerability we have today. Vulnerabilities come and go, but the threat is the constant factor. The TTP is as such more important than the vulnerability exploited.

Of course we want to know something about the type of vulnerability, because we need to understand how the vulnerability is exposed in order to model it, but if we yes/no have a log4j vulnerability is not so relevant for the risk. Today’s log4j is tomorrow’s log10k. But it is essential to have an extensive inventory of all the potential threats (TTPs) and how often these TTPs have been used. This information is far more accessible than how often a specific exposed (so exploitable) vulnerability exists. We need to build scenarios and analyze the risk per scenario.

Habit 4 is also of key importance, win-win makes people work together to achieve a common goal. The security consultant’s task might be to find the residual risk for a specific system, but the asset owner typically wants more than a result because risk requires monitoring, risk requires periodic reassessment. The engineering method should support these objectives in order to facilitate the risk management process. Engineering should always consider the various trade-offs there are for the asset owner, budgets are limited.

Habit 5 “Seek first to understand, then to be understood” can be directly linked to the risk communication method and linked to the perspective of the asset owner on risk. So reports shouldn’t be thrown over the wall but discussed and explained, results should be linked to the business. Though this might take considerably more time it is never the less very important.

But not an easy habit to acquire as engineer since we often are kind of nerds with an exclusive focus on “our thing” expecting the world to understand what is clear for us. One of the elements that is very important to share with the asset owner are the various scenarios analyzed. The scenario overview provides a good insight in what threats have been evaluated (typically close to 1000 today, so a sizeable document of bow-ties describing the attack scenarios and their consequences) and the overview allows us to identify gaps between the scenarios assessed and the changing threat landscape.

Habit 6 “Synergize”, is to consider all elements of the risk domain but also their interactions and dependencies. There might be influences from outside the risk domain not considered, never the less these need to be identified another reason why dependencies are very important. Risk propagates in many ways, not necessarily exclusively over a network cable.

Habit 7 “Sharpen the saw”, if there is one discipline where this is important than it is cyber risk. The threat landscape is in continuous movement. New attacks occur, new TTP is developed, and proof of concepts published. Also whenever we model a system, we need to maintain that model, improve it, continuously test it and adjust where needed. Threat analysis / modelling is a continuous process, results need to be challenged, new functions added.

Business managers typically like to develop something and than repeat it as often as possible, however an engineering process is a route where we need to keep an open eye for improvements. Habit 7 warns us against the auto-pilot. Risk analysis without following habit 7 results in a routine that doesn’t deliver appropriate results, one reason why risk analysis is a separate discipline not just following a procedure as it still is for some companies.

There is no relationship between my opinions and references to publications in this blog and the views of my employer in whatever capacity. This blog is written based on my personal opinion and knowledge build up over 43 years of work in this industry. Approximately half of the time working in engineering these automation systems, and half of the time implementing their networks and securing them, and conducting cyber security risk assessments for process installations since 2012.

Author: Sinclair Koelemij

OTcybersecurity web site

Why process safety risk and cyber security risk differ


When cyber security risk for process automation systems is estimated I often see references made to process safety risk. This has several reasons:

  • For estimating risk we need likelihood and consequence, the process safety HAZOP and LOPA processes used by plants to estimate process safety risk, identify the consequence of the process scenarios they identify and analyze. These methods also classify the consequence in different categories such as for example finance, process safety, and environment.
  • People expect a cyber security risk score that is similar to the process safety risk score, a score expressed as loss based risk. The idea is that the cyber threat potentially increases the process safety risk and they like to know how much that risk is increased. Or more precisely how high is the likelihood that the process scenario could occur as result of a cyber attack.
  • The maturity of the process safety risk estimation method is much higher than the maturity of cyber security risk estimation methods in use. Not that strange if you consider that the LOPA method is about 20 years old, and the HAZOP method goes back to the end sixties. When reading publications, or even the standards on cyber security risk (e.g. IEC 62443-3-2) this lack of maturity is easily detected. Often qualitative methods are selected, however these methods have several drawbacks which I discuss later.

This blog will discuss some of these differences and immaturities. I’ve done this in previous blogs mainly by comparing what the standards say and what I’ve experienced and learned over the past 8 years as a cyber risk analysis practitioner for process automation systems doing a lot of cyber risk analysis for the chemical, and oil and gas industries. This discussion requires some theory, I will use some every day examples to explain to make it more digestible.

Let us start with a very important picture to explain process safety risk and its use, but also to show how process safety risk differs from cyber security risk.

Process safety FN curve

There are various ways to express risk, the two most used are risk matrices and FN plots / FN curve. FN curves require a quantitative risk assessment method, such as used in process safety risk analysis by for example LOPA. In an FN curve we can show the risk criteria. The boundaries for what we consider acceptable risk and what we consider unacceptable risk. I took a diagram that I found on the Internet where we have a number of process safety scenarios (shown as dots on the blue line) their likelihood of occurrence ( the vertical ax) and in this case the consequence expressed in fatalities when such a consequence can happen (horizontal ax). The diagram is taken from a Hydrogen plant, these plants belong to the most dangerous plants, this is why we see the relative high number of scenarios with a single or multiple fatalities.

Process safety needs to meet regulations / laws that are associated with their plant license. One such “rule” is that the likelihood of “in fence” fatalities must be limited to 1 every 1000 years (1.00E-3) If we look at the risk tolerance line (RED) in the diagram we see that what is considered tolerable and intolerable is exactly at the point where the line crosses the 1.00E-03 event frequency (likelihood). Another often used limit is the 1.00E-04 frequency for the limit used as acceptable risk, risk not further addressed.

How does process safety determine this likelihood for a specific process scenario? In process safety we have several structured methods for identifying hazards. One of them is the Hazard and Operability study, in short the HAZOP. In a hazop we analyze, for a specific part of the process, if specific conditions can occur. For example we can take the flow through an industrial furnace and analyze if we can have a high flow, no flow, maybe reverse flow. If such a condition is possible we look at the cause of this (the initiating event), perhaps no flow because a pump fails. If we have established the cause (the initiating event) we consider what would be the process consequence. Well possibly the furnace tubing will be damaged, the feed material would leak into the furnace and an explosion might occur. This is what is called the process consequence. This explosion has an impact on safety, one or multiple field operators might be in the neighborhood and killed by the explosion. There will also be a financial impact, and possibly an environmental impact. A hazop is a multi-month process where a team of specialists goes step by step through all units of the installation and considers all possibilities and ways how to mitigate this hazard. This results in a report with all analysis results documented and classified. Hazops are periodically reviewed in a plant to account for possible changes, this we call the validity period of the analysis.

However we don’t have yet a likelihood expressed as an event frequency such as used in the FN curve. This is where the LOPA method comes in. LOPA has tables for all typical initiating events (causes), so the event frequency for the failure of a pump has a specific value (for example 1E-01, once every 10 years). How were these tables created? Primarily based on statistical experience. These tables have been published, but can also differ between companies. It is not so that a poly propylene factory of company A uses by default the same tables as a poly propylene factory of company B. All use the same principles, but small differences can occur.

In the example we have a failing pump with an initiating frequency of once every 10 years and a process consequence that could result in a single fatality. But we also know that our target for single fatalities should be once per 1000 years or better. So we have to reduce this event frequency of 1E-01 with at least a factor 100 to get to once per 1000 years.

This is why we have protection layers, we are looking for one or more protection layers that offer us a factor one hundred extra protection. One of these protection layers can be the safety system, for example a safety controller that detects the no flow condition by measuring the flow and shuts down the furnace to a safe state using a safety valve. How much “credit” can we take for this shutdown action? This depends on the safety integrity level (SIL) of the safety instrumented function (SIF) we designed. This SIF is more than the safety controller where the logic resides, the SIF includes all components necessary to complete the shutdown function, so will include transmitters that measure the flow and safety valves that close any feed lines and bring other parts of the process into a safe condition.

We assign a SIL to the SIF. We typically (SIL 4 does exist) have 3 safety integrity levels: SIL 1, 2, and 3. According to LOPA a SIL 1 SIF gives us a reduction of a factor 10, SIL 2 will reduce the event frequency by a factor 100, and SIL 3 by a factor 1000.

How do we estimate if a SIF meets the requirements for SIL 1, 2, or 3? This requires us to estimate the average probability of failure on demand for the SIF. This estimation makes use of mean time between failure of the various components of the SIF and the test frequency of these components. For this blog I skip this part of the theory, we don’t have to go into that level of detail. High level we estimate what we call the probability of failure on demand for the protection layer (the SIF). In our example we need a SIF with a SIL 2 rating, a protection level relatively easy to create.

In the FN curve you can also see process scenarios that require more than a factor 100, for example a factor 1000 like in a SIL 3 SIF. This requires a lot more, both from the reliability of the safety controller as well as from the other components. Maybe a single transmitter is not reliable enough anymore and we need some 2oo3 (two out of three) configuration to have a reliable measurement. Never the less the principle is the same, we have some initiating event, we have one or more protection layers capable of reducing the event frequency with a specific factor. These protection layers can be a safety system (like in my example), but also some physical device (e.g. pressure relief valve), an alarm from the control system, an operator action, a periodic preventive maintenance activity, etc. LOPA gives each of these protection layers what is called a credit factor, a factor with which we can reduce the event frequency when the protection layer is present.

So far the theory of process safety risk,. One topic I avoided discussing here is the part where we estimate the probability of failure on demand (PFDavg) for a protection layer. But it has some relevance for cyber risk estimates. If we would go into more detail and discuss these formulas to estimate the effectiveness / reliability of the protection layer we see that the formulas for estimating PFDavg we depend on what is called the demand rate. The demand rate is the frequency which we expect the protection layer will needs to act.

The standard (IEC 61511) makes a difference between what is called low-demand rate and high / continuous demand rate. The LOPA process is based upon the low demand-rate formulas, the tables don’t work for high / continuous demand rate. This is an important point to notice when we start a quantitative cyber risk analysis because the demand rate of a cyber protection layer is by default a high / continuous demand rate type of protection layer. This difference impacts the event frequency scale and as such the likelihood scale. So if we were to estimate cyber risk in a similar manner as we estimated process safety risk we end up with different likelihood scales. I will discuss this later.

A few important points to note from above discussion:

  • Process safety risk is based on randomly occurring events, events based on things going wrong by accident, such as a pump failure, a leaking seal, an operator error, etc.
  • The likelihood scale of process safety risk has a “legal” meaning, plants need to meet these requirements. As such a consolidated process safety and cyber security risk score is not relevant and because of estimation differences not even possible.
  • When we estimate cyber security risk, the process safety risk is only one element. With regard to safety impact the identified safety hazards will most likely be as complete as possible, but the financial impact will not be complete because financial impact might also result from scenarios that do not impact process operations but might impact the business. The process safety hazop or LOPA does not generally address cyber security scenarios for systems that have no potential process impact, for example a historian or metering function.
  • The IEC 62443 standard tries to introduce the concept of “essential” functions and ties these functions directly to the control and safety functions. However plants and automation functions have many essential tasks not directly related to the control and safety functions, for example various logistic functions. The automation function contains all functions connected to level 0, level 1, level 2, level 3, and demilitarized zone. When we do a risk analysis these systems should be included, not just the control and safety elements. The problem that a ship cannot dock to a jetty also has significant cost to consider in a cyber risk analysis.
  • Some people suggest that cyber security provides process safety (or worse the wider safety is even suggested.) This is not true, process safety is provided by the safety systems. The various protection layers in place. Cyber security is an important condition for these functions to do their task, but not more as a condition. The Secret Service protects the president of the US against various threats, but it is the president of the US that governs the country – not the Secret Service by enabling the president to do his task.

Where does cyber security risk differ from process safety risk? Well first of all they have different likelihood scales. Process safety risk is based on random events, cyber security risk is based on intentional events.

Then there is the difference that a process safety protection layer always offers full protection when it is executed, many cyber security protection layers don’t. We can implement antivirus as a first protection layer, application white listing as a 2nd protection layer, they both would do their thing but still the attacker can slip through.

Then there is the difference that a cyber security protection layer is almost continually “challenged”, where in process safety the low demand rate is most often applied, which sets the maximum demand rate to once a year.

If we would look toward cyber security risk in the same way as LOPA does toward process safety risk, we could define various events with their initiating event frequency. For example we could suggest an event such as a malware infection to occur bi-annually. We could assign protection layers against this, for example anti-virus and assign this protection layer a probability of failure on demand (risk reduction factor), so a probability on a false negative or false-positive. If we have an initiating event (the malware infection) with a certain frequency and a protection layer (antivirus) with a specific reduction factor we can estimate a mitigated event frequency (of course taking high demand rate into account).

We can also consider multiple protection layers (e.g. antivirus and application white listing) and arrive at a frequency representing the residual risk after applying the two protection layers. Given various risk factors and parameters to enter the system specific elements and given a program that evaluates the hundreds of attack scenarios, we can arrive at a residual risk for one or hundreds of attack scenarios.

Such methods are followed today, not only by the company I work for but also by several other commercial and non-commercial entities. Is it better or worse than a qualitative risk analysis (the alternative)? I personally believe it is better because the method allows to take multiple protection layers into account. Is it actuarial type of risk, no it is not. But the subjectivity of a qualitative assessment has been removed because of the many factors determining the end result and we have risk now as residual risk based upon taking multiple countermeasures into account.

Still there is another difference between process safety and cyber security risk not accounted for. This is the threat actor in combination with his/her intentions. In process safety we don’t have a threat actor, all is accidental. But in cyber security risk we do have a threat actor and this agent is a factor that influences the initiating event frequency of an attack scenario.

The target attractiveness of facilities differ for different threat actors. A nation state threat actor with all its capabilities is not likely to attack the local chocolate cookie factory, but might show interest in an important pipeline. Different threat actors mean different attack scenarios to include but also influence the initiating event frequency it self. Where non-targeted attacks show a certain randomness of occurrence, a targeted attack doesn’t show this randomness.

We might estimate a likelihood for a certain threat actor to achieve a specific objective for the moment that the attack takes place, but this start moment is not necessarily random. Different factors influence this, so to express cyber risk on a similar event frequency scale as process safety risk is not possible. Cyber security risk is not based on the randomness of the event frequencies. If there is a political friction between Russia and Ukraine, the amount of cyber attacks occurring and skills applied is much bigger than in times without such a conflict.

Therefore cyber security risk and process safety risk cannot be compared. Though the cyber threat certainly increases the process safety risk (both initiating event frequency can be higher and the protection layer might not deliver the level of reliability expected), we can not express this rise in process safety risk level because of the differences discussed above. Process safety risk and cyber security risk are two different things and should be approached differently. Cyber security has this “Secret Service” role, and process safety this “US president” role. We can estimate the cyber security risk that this “Secret Service” role will fail and the US government role is made to do bad things, but that is an entirely different risk than that the US government role will fail. It can fail even when the “Secret Service” role is fully active and doing its job. Therefore cyber security risk has no relation with process safety risk, they are two entirely different risks. The safety protection layers provide process safety (resilience against accidental failure), the cyber security protection layers provide resilience against an intentional and malicious cyber attack.

There is no relationship between my opinions and references to publications in this blog and the views of my employer in whatever capacity. This blog is written based on my personal opinion and knowledge build up over 43 years of work in this industry. Approximately half of the time working in engineering these automation systems, and half of the time implementing their networks and securing them, and conducting cyber security risk assessments for process installations since 2012.

Author: Sinclair Koelemij

OTcybersecurity web site

ISA 62443-3-2 an unfettered opinion


This blog is about the in April published new ISA 99 standard, where risk and securing process control and automation systems meet. My blog is an evaluation of part ISA 62443 3-2: Security risk assessment for system design – April 2020).

I write the blog because I struggle with several of the methods applied by the standard and apparent lack of input from the field. The standard seems to ignore practices successfully used in major projects today and replaces these by in my opinion incomplete and inferior alternatives. Practices that for example are used for process safety risk analysis.

Since I executed in recent years several very large risk assessments for greenfield refineries, chemical plants and national critical industry, my technical heart just can’t ignore this. So I wanted to address these issues, because I believe the end result of this standard does not meet the quality level appropriate for an ISA 62443 standard. Very hard conclusion I know, but I will explain in the blog why this is my opinion.

When criticizing the work of others, I don’t want to do this without offering alternatives, so also in this case where I think the standard should be improved I will give alternatives. Alternatives that worked fine in the field and where applied by asset owners with a great reputation in cyber security of their plants. If I am wrong, hopefully people can show me where I am wrong and convince me the ISA 62443 3-2 can be applied.

I have been struggling with the text of this blog for 3 weeks now, I found my response too negative and not appreciating all the work done by people in the task group primarily in their spare time. So let me, before continuing with my evaluation, express my appreciation for making the standard. It is important to have a standard on this subject and it is a lot of work to make it. Having a standard document is always a good step forward, even if just for target practicing. Never the less I also have to judge the content, therefore my evaluation.

It is a lengthy blog this time, even longer than usual. But not yet a book, for a book it lacks the details on how, it has a rather quick stop and not a happy end. Perhaps one day when I am retired and free of projects I will create such a book, this time just a lengthy blog to read. People that conduct or are interested in risk assessments for OT cyber security should read it, for all others it might be too much to digest. Just a warning.

Because I can imagine that not everyone reads or has read the ISA 62443-3-2, I provide a high level overview of the various steps. I can’t copy the text 1 on 1 from the standard, that would violate ISA’s copy right. So I have to do it using my own words, which are in general a little less formal than the standard’s text. Since making standards requires a lot of word smithing, I hope I don’t deviate too much from the intentions of the original text. For the discussion I focus on those areas in the standard that surprised me most.

The standard uses 7 steps between the start of a risk assessment project to the end.

  • First step is to identify what the standard calls the “system under consideration”. So basically making an inventory of the systems and its components that require protection;
  • Second step in the proposed process is an initial cyber security risk assessment. This step I will evaluate in more detail because I believe the approach here is wrong and I question if it really is a risk assessment;
  • Third step is to partition the system into zones and conduits. High level I agree with this part, though I do have some minor remarks;
  • Fourth step asks the question if the initial risk found in the second step exceeds tolerable risk? Because of my issues with step 2, I also have issues with the content of this step;
  • Fifth, if the risk exceeds tolerable risk a detailed risk assessment is required. I have a number of questions here, not so much the principle itself but the detail;
  • In the sixth step the results are documented in the form of security requirements, plus adding some assumptions and constraints. Such a result I would call a security design / security plan. The standard doesn’t provide much detail here, so only a few comments from my side;
  • And finally in the seventh step there is an asset owner approval. Too logical for debate.

High level these 7 steps represent a logical approach, it are the details within these steps that inspire my blog.

Let me first focus on some theoretical points considering risk, starting with the fundamental tasks that we need to do before being able to estimate risk and than check the standard how it approaches these tasks.

In order to perform a cyber security risk analysis, it is necessary to accomplish the following fundamental tasks:

  • Identify the assets in need of protection;
  • Identify the kind of risks (or threats) that may affect the assets;
  • Determine the risk criteria for both the risk levels as well as the actions to perform when a risk level is reached;
  • Determine the probability of the identified risk occurring;
  • And determine the impact or effect on the plant if a given loss occurs.

Let’s evaluate the first steps of the standard against these fundamental principles.

Which assets are in need of protection for an ICS/IACS?

The ISA 62443-3-2 standard document doesn’t define the term asset, so I have to read the IEC 62443-1-1 to understand what according to IEC/ISA 62443 an asset is. According to the IEC 62443-1-1 standard the asset is defined as – in less formal words as used by the standard – an asset is a “physical or logical object” owned by a plant. The standard is here less flexible than my words because an asset is not necessarily owned by a plant, but to keep things simple I take the most common case where the plant owns the assets. The core of the definition is, an asset is a physical or a logical object. So translated into technical language, an asset is either equipment or a software function.

IEC 62443-1-1 specifies an additional requirement for an asset, it needs to have either a perceived or actual value. Both equipment and a software function have an actual value. But there is in my opinion a third asset with a perceived value that needs protection. This is the channel, the communication protocol / data flow used to exchange data between the software functions. Not exactly a tangible object but still I think I can call at minimum an asset if I consider it a data flow using a specific protocol.

Protection of a channel is important, cyber security risk is for a large part linked to exposure of a vulnerability. Vulnerable channels, for example a data flow using the Modbus TCP / IP protocol (this protocol has several vulnerabilities that can be exploited), induce risk. So for me the system under consideration is:

  • The physical equipment (e.g. computer equipment, network equipment, and embedded devices);
  • The functions (software, for example SIS (Safety Instrumented System) and BPCS (Basic process Control System). But many more in today’s systems);
  • And the channels (the data flows, e.g. Modbus TCP/IP or a vendor proprietary protocol).

The ISA 62443-3-2 standard document doesn’t mention these three as explicitly as I do, but the text is also not in conflict with my definition of assets in need of protection. So no discussion here from my side. Before we can assess OT cyber security risk we need to have a good overview of these “assets”, the scope of the risk assessment.

The second step is an initial risk assessment, here I start to have issues. The standard asks us to identify the “worst case unmitigated cyber security risk” that could result from a cyber attack. It suggests to express this in terms of impact to health, safety, production loss, product quality, etc. This is what I call mission risk or business risk. The four primary factors that induce this risk are:

  • Process operations;
  • Process safety;
  • Asset integrity;
  • Cyber security;

Without process safety many accidents can occur, but even a plant in a perfect “safe” state can impact product quality and production loss. So we need to include process operations as well. Failing assets can also lead to production loss, or even impact to health. Asset integrity is the discipline that evaluates the maintenance schedules and required maintenance activities. Potential failures made by this discipline also add to the business / mission risk. And then we have cyber security. Cyber security can alter or halt the functionality of the various automation functions, and can alter data integrity, and even compromise the confidentiality of a plant’s intellectual property. All above are elements that can result in a loss and so induce mission risk. But cyber security can do more than this, it can make implemented safety integrity functions (SIF) for process safety ineffective, it can misuse the SIF logic to cause loss. Additionally cyber security can also cause excessive wear of process equipment not accounted for by asset integrity. Cyber security is an element that influences all.

For determining initial risk, the approach taken by the standard is to use the process hazard analysis (PHA) results as input for identifying the worst case impacts. And additional to this the standard requests us to consider information from the sector, governments, and other sources to get information on the threats.

I have several issues here. The first, can we have risk without likelihood? The PHA can define a likelihood in the PHA sheet, but this likelihood has no relationship with the likelihood of facing a cyber attack. So using it would would not result in cyber security risk.

Another point is that if we consider the impact, the PHA would offer us the worst case impact based upon the various deviations analyzed from a process safety perspective. But this is not necessarily the worse case impact from a business perspective.

See the definition for process safety: “The objective of process safety management is to ensure that potential hazards are identified and mitigation measures are in place to prevent unwanted release of energy or hazardous chemicals into locations that could expose employees and others to serious harm.”

The PHA would not necessarily analyze the impact of product quality for the company. Pharmaceutical business and food and beverage business can face major impact if its products would have a quality issue, while their production process can be relatively safe compared to a chemical plant.

If we would take the PHA as input, will it address the “worst case impact”? PHA will certainly be complete for the analysis of the process deviations (the structured approach of the PHA process enforces this) and complete for the influence of these deviations on process safety, so should also be complete for the consequences too if all process deviations are examined.

But the PHA might not be complete when it comes to the possible causes, because PHA generally doesn’t consider malicious intent. So there might be additional causes that are not considered as possible by the PHA.

Causes are very important because these result from functional deviations as result of the cyber attack. It is the link between the functional deviation and its physical effect on the production process that causes the process deviations and its consequence / impact.

If it is not guaranteed that the PHA covers all potential causes, the reverse path from “worst case impact” in the PHA to the “cyber security functional deviation” that causes a process deviation is interrupted. This interruption doesn’t only prevent us from getting a likelihood value, but also prevents us from identifying all mitigation options. Walking the event path in the reverse direction is not going to bring us the likelihood of the process deviation happening as result of a cyber attack, so we don’t have risk.

If I follow the methodology of analyzing risk using event paths, I have the following event path:

A threat actor executes a threat action to exploit a vulnerability resulting in some desired consequence, this consequence is a functional deviation causing a process deviation with some process consequence.

The process consequence has a specific impact for the business / mission, such as production loss, potential casualties, a legal violation, etc. This impact (expressed as loss) creates business risk.

The picture shows that the risk path between a cyber security breach resulting in mission impact requires several steps. The standard jumps right to the end (business impact) not considering intermediate consequences, by doing this the standard ignores options to reduce risk. But more on this later.

The path toward mission risk

So as an example of an event path: A nation sponsored organization (threat actor) gains unauthorized access into an ICS (threat action) by capturing the access credentials of an employee without two factor authentication (vulnerability), modifying the range of a tank level instrument (functional deviation), causing a too high level in the tank (process deviation) with as potential consequence overfilling the tank (process consequence) resulting in a loss of containment of a potentially flammable fluid causing toxic vapors requiring an evacuation resulting in potentially multiple casualties and an approximate $500.000 production and cleaning cost loss (business impact).

An extended event path in more detail

The likelihood that this event path, scenario, happens as result of a cyber attack is determined by the likelihood of the cyber security failure. The PHA might have considered a similar process deviation (High level in the tank) during the analysis, perhaps with as cause mentioned a failed level transmitter, and reached the same process consequence as potential loss of containment. All very simplified, don’t worry we do apply additional controls.

But the likelihood assigned to this process safety hazard would have been derived from a LOPA (Layers Of Protection Analysis) assignment based on an initiating frequency assignment and an IPL (Independent Protection Layer) reduction factor and MTBF factors of the instrument to estimate a SIL required for the safeguard. There is no relationship between the likelihood of the process deviation in the PHA and the cyber security likelihood.

Important is to realize that not all risk estimates are necessarily linked to a loss. Ideally this is so, because the loss justifies the investment in mitigation. But in many cases we can use what are called risk priority numbers, a risk score based on likelihood and severity for ranking purposes. A risk priority number is often enough for us to decide on mitigation and prioritizing mitigation. For design we only need business risk if the investment needs to be justified. The risk priority numbers already show the most important risk from a technical perspective.

However my conclusion is that the standard is not approaching the initial risk assessment by estimating cyber security risk, it seems to focus on two other aspects:

  • What is the worst impact (Expressed as a loss);
  • and what does the threat landscape look like.

Neither of them providing a risk value. I fully understand the limitation, because so early in a project there is not enough information available to estimate risk at a level of detail showed above.

So in my opinion an alternative approach is required, and such alternatives exist. Better they have been widely applied in the industry in recent years, but for some reason are ignored by the task group and replaced by something questionable in my opinion.

So how did projects resolve the lack of information and still get important information for understanding the business impact and threats to protect against? Following activities were performed in projects:

  • Create a threat profile by conducting a threat assessment;
  • Conduct a criticality assessment / business impact analysis.

What is a threat profile? The objective of a threat profile is to:

  • Identify the threat actors to be considered;
  • Identify and prioritize cyber security risk;
  • Align information security risk and OT security risk strategies within the company.

Identifying and prioritizing cyber security risk is done by studying the threat landscape based upon various reliable sources, such as information from a local CERT, MITRE, FIRST, ISF, and various commercial sources. These organizations show the developments in the threat landscape explaining the activities of threat actors and what they do.

Threat actors are identified and their relevance for the company can be rated based on criteria such as: intent, origin, history, motivation, capability, focus. Based on these criteria a threat strength and likelihood can be estimated. Various methods have been developed, for example the method developed by ISF is frequently used.

Based on the information on threat actors and their methods and their focus, a threat heat map is created. So the asset owner can decide on what the priorities are. This is an essential input for anyone responsible for the cyber security of a plant, but also important information for a cyber security risk assessment. Threat actors considered as relevant, play a major role in the required risk reduction for an appropriate protection level. If we don’t consider the threat actor we will quickly over-spend or under-spend on risk mitigation.

In the ISA 62443-3-2 context, the target security level (SL-T) is used as the link toward the threat actor. Because ISA security levels link to motivation, capability, and resources of the threat actor, a security level also identifies a threat actor. The idea is to identify a target security level for each security zone and use this to define the technical controls for the assets in the zone, specified as capability security levels (SL-C) in the IEC 62443-3-3. The IEC 62443-3-3 provides the security requirements that the security zones and conduits must meet to offer the required level of protection.

The ISA 62443-3-2 document does not explain how this SL-T is defined. But if the path is to have an SL-T per security zone, then we need to estimate zone risk. Zone risk is something very different from asset risk or threat based risk. The ANSSI standard provides a method to determine zone risk and uses the result to determine a security class (A,B, C) something similar as the ISA security levels.

I would expect a standard document on security risk assessment to explain the zone risk process, but the standard doesn’t. Because the methodology actually seems to continue with an asset based risk approach I assume the idea is that the asset with the highest risk level in a zone determines the overall zone risk level. This is a valid approach but more time consuming than the ANSSI approach.

For a standard / compliance based security strategy a zone risk approach would have been sufficient. The use of SL-T and SL-C and reference to IEC 62443-3-3 seems to suggest a standard’s / compliance based security approach.

How about the other method in use, the criticality assessment. What does it offer? The criticality assessment helps to establish the importance of each functional unit and business process as it relates to the production process. Illustrating which functions need to be recovered, how fast do they need to be recovered and what their overall importance is from both a business perspective as well as from a cyber security perspective. Which are two totally different perspectives. An instrument asset management system might have a low importance from a business point of view, but because of its connectivity to all field instrumentation it can be considered an important system to protect from a cyber security perspective.

So executing a criticality assessment as second step provides the criticality of the functions (importance and impact do correlate), and it provides us with information on the recovery timing.

OT cyber security risk should not exclusively focus on the identification of the risk related to the threats and how to mitigate it. Residual business risk is not only influenced by preventative and detective controls but also by the recovery potential and speed, because the speed of recovery determines business continuity and lack of business continuity can be translated to loss.

ISA 62443-3-2 doesn’t address the recovery aspect in any way. As the risk assessment is used to define the security requirements, we can not ignore recovery requirements. NIST CSF does acknowledge recovery as an important security aspect, I don’t understand why the ISA 62443-3-2 task group ignored recovery requirements as part of their design risk assessment.

It is important to know the recovery point objective (RPO), recovery time objective (RTO) and maximum tolerable downtime (MTD) for the ICS / IACS. Designing recovery for a potential cyber threat, for example a ransomware infection, differs quite a lot from data recovery from an equipment failure.

In a plant with its upstream and down stream dependencies and storage limitations, these parameters are important information for a security design. See below diagram for the steps in a typical cyber incident. Depending on their detailed procedures, these steps can be time consuming.

Response and recovery

The criticality assessment investigates Loss of Ability to Perform over a time span, for example how do we judge criticality after 4 hours, 8 hours, a day, a week, etc… This allows us to consider the dependencies of upstream and downstream processes, and storage capacity. But apart from looking at loss of ability to perform, loss of required performance and loss on confidentiality are also evaluated in a cyber security related criticality assessment. Specifically the loss of required performance links to the “worst impact” looked for by the ISA 62443-3-2.

We also need to consider recovery point objectives (RPO) and understand how the plant wants to recover, are we going to use the most recent controller checkpoint or are there requirements for a controller checkpoint that brings the control loops into an known start-up state.

We need to understand the requirements for the recovery time objective (RTO), this differs for cyber security compared to a “regular” failure. For cyber security we need to include the time taken by the incident response tasks, such as containment and eradication of the potential malware or intruder.

It makes a big difference in time if our recovery strategy opts for restoring a back-up to new hard drives, or if we decide to format the hard drives before we restore (and what type of reformatting would be required). Other choices to consider are back-up restore over the network from one or more central locations, or restore directly at computer level using USB drives. All of this and more has time and cost impact that the security design needs to take into account.

The role of the criticality assessment is much bigger than discussed here, but it is an essential exercise for the security design and as such for the risk assessment that also requires us to assess consequence severity. Consequence severity analysis is actually just an extension of the criticality analysis.

Another important aspect of criticality analysis is that it includes ICS / IACS functions not being related to any of the hazards identified by the PHA. For our security design we need to include all IACS systems, not limit our selves to systems at Purdue reference model level 0, 1 and 2.

A modern IACS has many functions, all ignored by the ISA 62443-3-2 standard if we start at the PHA. IACS includes not only the systems at the Purdue level 0, 1 and 2, (systems typically responsible for the PHA related hazards) but also the systems at level 3. Systems that can still be of vital importance for the plant. The methodology of the standard seems to ignore these.

Another role for the criticality assessment is directly related to the risk assessment. An important question in a large environment is do we assess risk per sub-system or for the whole system. Doing it for the whole system (IACS) with all its sub-systems (BPCS, SIS, MMS, …) and a large variation of different consequences and cross relations, or do we assess risk per function and consolidate these results for comparison in for example a risk assessment matrix.

The standard seems to go for the first approach, which in my opinion (based upon risk assessments for large installations) is a far too difficult and complex exercise. If we keep the analysis very general (and as a result superficial, often at an informal gut-feeling-risk level) it is probably possible, but the results often become very subjective and we miss out on the benefits that other methods offer.

As the base for a security design that is resilient to targeted attacks and its subsequent risk based security management (this would require a risk register) of the complete ICS/IACS, I believe it is an impossible task. All results of a risk assessment need to meet the sensitivity test, and the results need to be discriminitive enough to have value. This requires that methods applied, prevent any subjective inputs that steer the results into a specific direction.

If we select a risk assessment approach per function to allow for more detail, we have to take the difference in criticality of the function into account when comparing risk of different functions. This is of minor importance when we compare risk results from SIS (Safety Instrumented System) or BPCS (Basic Process Control System), because both are of vital importance in a criticality analysis. But we will already see differences in results when we would compare BPCS with MMS (Machine Monitoring System), IAMS (Instrument Asset Management System) or DAHS (Data Acquisition Historian System).

As I already mentioned in my previous blog, risk assessment methodologies have evolved and the method suggested by ISA 62443-3-2 seems to drive toward an approach that can’t handle the challenges of today’s IACS. Certainly not for the targeted attacks where threat actors with “IACS specific skills” ( SL 3, SL 4). To properly execute a risk assessment in an OT environment requires knowledge on the different methods for assessing risk, their strong and weak points, and above all a clear objective for the selected method.

So to conclude my assessment of the second step of the ISA 62443-3-2 process, “Initial risk assessment”, I feel the task group missed too much in this step. The result offers too little, is incomplete and actually providing very little useful information for the next steps, among which the “security zone partitioning”.

Now lets look at the zone partitioning step, to see how the standard and my field experience aligns here.

First of all what is the importance of security zone partitioning with regard to security risk assessment?

  • If we want to use zone risk we need to know the boundaries of the security zone;
  • For asset risk and threat based risk we need to know the exposure of the asset / channel and connectivity between zones over conduits is an important factor.

So it is an important step in a security risk assessment, even for none security standard based strategies. Let’s start with the overview of what project steps the standard specifies:

  • Establish zones and conduits;
  • Separate business and ICS/IACS assets;
  • Separate safety related assets;
  • Separate devices that are temporarily connected;
  • Separate wireless devices;
  • Separate devices connected via external networks.

Looks like a logical list to consider when creating security zones, but certainly not a complete list. The list seems to be driven by exposure, which is good. But there are other sources of exposure. We can have 24×7 manned and unmanned locations, important for yes / no a session lock of operator stations, so a security characteristic. We have to consider the strength of the zone boundary, is it a physical perimeter (e.g. network cable connected to the port of a firewall), a logical perimeter (e.g. a virtual LAN), or do we have a software defined perimeter (e.g. a hypervisor that separates virtual machines on virtual network segments).

The standard, and as far as I am aware none of the other ISA standards, consider virtualization. This is a surprise for me because virtualization seems to be core for the majority of greenfield projects, and even as part of brown field upgrade projects virtualization is a frequent choice today. Considering that the standard is issued April 2020, and ISA has a policy to refresh standards every 5 years, this is a major gap because software zone perimeters for security zones is an important topic.

Considering that virtualization is a technology used in many new installations, and considering the changes that technology like APL and IIoT are bringing us. Not addressing these technologies in a risk based design document that discusses zone partitioning makes the standard almost obsolete in the year it is issued.

Perhaps a very hard verdict, but a verdict based on my personal experience where 4 out of 5 large greenfield projects were based on virtualized systems a subject that should have been covered. Ignoring virtualization for zone partitioning is a major gap in 2020 and the years to come.

There is a whole new “world” today of virtual machine hosts, virtual machines, hardware clusters, and software defined perimeters. And this has nothing to do with the world of private clouds or Internet based clouds, virtualization is proven technology for at least 5+ years now, conquering ICS/IACS space with increasing speed. It should not have been missed.

The 62443-3-2 standard is not very specific with regard to the other subjects in this step, so little reason for me to criticize the remainder of the text. If I have to add a point, then I might say that the paragraph on separating safety and non-safety related assets is very thin. I would have expected a bit more in April 2020, plenty of unanswered design questions for this topic.

The next step the standard asks us to do is “risk comparison“, we have to compare initial risk (step 2) with residual risk, the risk after the zone partitioning step. There is the “little” issue that neither in the initial risk assessment step, nor in the zone partitioning step we estimate risk. Nor do we establish anywhere risk criteria, important information when we want to compare risk.

Zone partitioning does change the risk, we influence exposure through connectivity, but there is no risk estimated in the partitioning step. Perhaps the idea is to take the asset with the highest risk in the zone and use this for the SL-T / SL-C and identify missing security requirements, but this is not specified and would be an iterative process because also asset risk depends among others on exposure from connectivity.

I had expected something in the partitioning task that would estimate / identify zone risk and assign the zone a target security level using some transformation matrix from risk to security level. The standard doesn’t explain this process, it doesn’t seem to be an activity of the zone partitioning task, it doesn’t refer to another standard document for solving it. Which is an omission in my opinion.

But ok no problem, if we can’t accept the residual risk we are going to do the next step, the detailed risk assessment and keep iterating till we accept the residual risk. So perhaps I must read this more as a first step in an evaluation loop. Doesn’t take away that if I decide first time I am happy with the residual risk, I will have nothing else than what the initial risk assessment produced, and this was not cyber security risk.

The fifth step is the detailed risk assessment. Let’s see what we need to do:

  • Identify cyber security threats;
  • Identify vulnerabilities;
  • Determine consequences and impact;
  • Determine unmitigated likelihood;
  • Determine unmitigated cyber security risk;
  • Determine security level target to link to the IEC 62443-3-3 standard.

If the unmitigated risk exceeds tolerable risk we need to continue with mitigation. Following steps are defined:

  • We need to identify and evaluate existing countermeasures;
  • We are asked to reevaluate the likelihood based on these existing countermeasures;
  • Determine the new residual risk;
  • Compare residual risk against tolerable risk and reiterate the cycle if the residual risk is still too high;
  • If all residual risk is below the tolerable risk, we document the results in the risk assessment report.

To do all of the above we need to have risk criteria, these are not mentioned in the standard neither is mentioned what criteria there are. The standard seems to adopt the three risk levels often used for process safety: acceptable risk, tolerable risk, and unacceptable risk.

Unfortunately this is too simple for cyber security risk. When process safety risk is unacceptable, an accepted policy is too stop and fix it before continuing. For tolerable risk there would be a plan in place on how to improve it when possible.

Cyber security doesn’t work that way, I have seen many high cyber security risks, but only in a few cases noted that plant managers were willing to accept a loss (production stop) to fix it. An example where loss because of security risk was accepted was when Aramco and 2 weeks later Qatar gas were attacked by the Shamoon malware. At that time the regional governments instructed the plants to disconnect the ICS/IACS from their corporate network, this induces extra cost. We have seen similar decisions caused by ransomware infections, plants pro-actively stopping production to prevent an infection propagating.

Cyber security culture differs from process safety culture, this translates into risk criteria and the action-ability of risk. The less risk levels, the more critical the decision. As result, plants seem to have a preference for 5 or 6 risk levels. This allows them a bit more flexibility.

Tolerable risk is the “area” between risk appetite and risk tolerance. Risk appetite being the level we can continue production without actively pursuing further risk reduction, and risk tolerance being the limit above which we require immediate action. Risk criteria are important, in the annex ISA 62443-3-2 provides some examples in risk matrices. A proper discussion on risk criteria is missing. Likelihood levels, severity levels, impact levels, importance levels all need to be defined. It is important that if we say this is a high risk, all involved understand what this means. Also actions need to be defined for a risk level, risk needs to result into some action if it exceeds a level.

The standard limits itself to business risk, impact expressed as a loss. Business risk is great to justify investment but does very little for identifying the most important mitigation opportunities because it is a worst case risk. It is like saying if I am walking in a thunderstorm I can die from being struck by lightning, so I no longer need to analyze the risk using a zebra to cross the road.

Another point of criticism I have is why only risk reduction based on likelihood reduction is considered. The standard seems to ignore addressing opportunities on the impact side for taking away consequences? Reduction on the consequence side has proved to be far more effective. In the methodology chosen by the standard this is not possible because the only impact / consequence recognized is the ultimate business impact. The consequences leading to this impact, the functional deviation in IACS functions, are not considered.

Risk event path

The three step process described in above block diagram of risk and shown in more detail in my previous blog as the “event path” doesn’t exist for the ISA adopted method. Though it are the countermeasures and safeguards we use to reduce the cyber security risk.

For example there are many plants that do not allow the use of the Modbus TCP/IP protocol for switching critical process functions using PLCs that depend on Modbus communication. If such an action is required they hardwire the connection to prevent being vulnerable for various Modbus TCP/IP message injection and modification attacks. This is a safeguard taking a way a very critical consequence such as an unauthorized start or stop of a motor, compressor or other by injecting a Modbus message.

Another point we are asked to do is to determine the security level target (SL-T). Well assuming there is some transformation matrix converting risk into security level (not in the ISA 62443-3-2) we can do this, but how?

It is a repeating issue, the standard doesn’t explain if I need to use zone risk like ANSSI does, or determine zone risk as the asset with the maximum risk in a zone. And when I have risk what would be the SL-T?

Once we have an SL-T we can compare this with the security level capability (SL-C) to get the security requirements from the IEC 62443-3-3. ISA 62443-3-2 seems to be restrict to the standard based security strategy. A good point to start but not a solution for critical infrastructure.

ISA 62443 3-2 is a standards-based security strategy.

Another surprise I have is the focus on the unmitigated risk, why not include the existing countermeasures immediately? Why are we addressing risk mitigation exclusively by addressing likelihood. Where do we include the assets to protect (equipment, function, channel)? I think I know the answer, the risk methodology adopted doesn’t support it. The task group either didn’t investigate the various risk estimation methodologies available or worked for some reason toward applying a methodology that is not capable of estimating risk for multiple countermeasures / safeguards. Which is strange choice because in process safety this methodology is successfully applied through LOPA.

So how to summarize this pile of criticism? First of all I want to say that this is the standard document I criticize the most, maybe because it is the subject that comes closest to my work. There are always small points where opinions can deviate, but in this case I have the feeling the standard doesn’t offer what it should bring, it seems to struggle with the very concept of risk analysis. Which is amazing because of the progress made by both science and asset owners in recent years.

Because risk is such an essential concept for cyber security I am disappointed in the result, despite all the editing of this blog and the many versions that were deleted I think the blog still shows this disappointment.

It is my feeling that the task group didn’t investigate the available risk methodologies sufficiently, didn’t study the subject of risk analysis, and they didn’t seem to compare results of the different methods. They aimed for one method and wrote the standard around it. That is a pity because it will take another 5 years before we see an update and 5 years in cyber security are an eternity.

There is no relationship between my opinions and references to publications in this blog and the views of my employer in whatever capacity. This blog is written based on my personal opinion and knowledge build up over 42 years of work in this industry. Approximately half of the time working in engineering these automation systems, and half of the time implementing their networks and securing them.

Author: Sinclair Koelemij

OTcybersecurity web site

Playing chess on an ICS board


This week’s blog discusses what a Hazard and Operability study (HAZOP) is and some of the challenges (and benefits) it offers when applying the method for OT cyber security risk. I discuss the different methods available, and introduce the concept of counterfactual hazard identification and risk analysis. I will also explain what all of this has to do with the title of the blog, and I will introduce “stage-zero-thinking”, something often ignored but crucial for both assessing risk and protecting Industrial Control Systems (ICS).

What inspired me this week? Well one reason – a response from John Cusimano on last week’s Wake-up call blog.

John’s comment: “I firmly disagree with your statement that ICS cybersecurity risk cannot be assessed in a workshop setting and your approach is to “work with tooling to capture all the possibilities, we categorize consequences and failure modes to assign them a trustworthy severity value meeting the risk criteria of the plant.”.  So, you mean to say that you can write software to solve a problem that is “impossible” for people to solve.  Hm. Computers can do things faster, true. But generally speaking, you need to program them to do what you want. A well facilitated workshop integrates the knowledge of multiple people, with different skills, backgrounds and experience. Sure, you could write software to document and codify some of their knowledge but, today, you can’t write a program to “think” through these complex topics anymore that you could write a program to author your blogs.”

Not that I disagree with the core of John’s statement, but I do disagree with the role of the computer in risk assessment. LinkedIn is a nice medium, but responses always are a bit incomplete, and briefness isn’t one of my talents. So a blog is the more appropriate place to explain some of the points raised. Why suddenly an abstract? Well this was an idea of a UK blog fan.

I write my blogs not for a specific public, though because of the content, my readers most likely are involved in securing ICS. I don’t think the “general public” public can digest my story easily, so they probably quickly look for other information when my blog lands in their window or they read it till the end and think what was this all about. But there is a space between the OT cyber security specialist, and the general public. I call this space “sales” technical guys but at a distance, and with the thought in mind that “if you know the art of being happy with simple things, then you know the art of having maximum happiness with minimum effort”, I facilitate the members of this space by offering a content filter rule – the abstract.

The process safety HAZOP or Process Hazard Analysis as non-Europeans call the method, was a British invention in the mid-sixties of the previous century. The method accomplished a terrific breakthrough in process safety and made the manufacturing industry a much safer place to work.

How does the method work? To explain this I need to explain some of the terminology I use. A production process, for example a refinery process, is designed creating successive steps of detail. We start with what is called a block flow diagram (BFD), each block represents a single piece of equipment or a complete stage in the process. Block diagrams are useful for showing simple processes or high level descriptions of complex processes.

For complex processes the BFD use is limited to showing the overall process, broken down into its principal stages. Examples of blocks are a furnace, a cooler, a compressor, or a distillation column. When we add more detail on how these blocks connect, the diagram is called a process flow diagram. A process flow diagram (PFD) shows the various product flows in the production process, an example of a PFD is the next text book diagram of a nitric acid process.

Process Flow Diagram. (Source Chemical Engineering Design)

We can see the various blocks in a standardized format. The numbers in the diagram indicate the flows, these are specified in more detail in a separate table for composition, temperature, pressure, … We can group elements in what we call process units, logical groups of equipment that accomplish together a specific process stage. But what we are missing here is the process automation part, what do we measure, how do we control the flow, how do we control pressure? This type of information is documented in what is called a piping and instrument diagram (P&ID).

The P&ID shows the equipment numbers, valves, the line numbers of the pipes, the control loops and instruments with an identification number, pumps, etc. Just like for PFDs we also used use standard symbols in P&IDs to describe what it is, to show the difference between a control valve and a safety valve using different symbols. The symbols for the different types of valves already covers more than a page. If we look at the P&ID of the nitric acid process and zoom into the vaporizer unit we see that more detail is added. Still it is a simplified diagram because the equipment numbers and tag names are removed, alarms have been removed, and there are no safety controls in the diagram.

The vaporizer part of the P&ID (Source Chemical Engineering Design)

On the left of the picture we see a flow loop indicated with FIC (the F from flow, the I from indicator, and the C from control), on the right we see a level control loop indicated with (LIC). We can see which transmitters are used to measure the flow (FT) or the level (LT). We can see the that control valves are used (the rounded top of the symbol). Though above is an incomplete diagram, it shows very well the various elements of a vaporizer unit.

Similar diagrams, different symbols and of course a totally different process, exist for power.

When we engineer a production / automation process P&IDs are always created to describe every element in the automation process. When starting an engineering job in the industry, one of the first things to learn is this “alphabet” of P&ID symbols the communication language for documenting the relation between the automation system (the ICS) and the physical system. For example the FIC loop will be configured in a process controller, there will be “tagnames” assigned to each loop, graphic displays created so the process operator can track what is going on and intervene when needed. Control loops are not configured in a PLC, process controllers and PLCs are different functions and have a different role in an automation process.

So far the introduction for discussing the HAZOP / PHA process. The idea behind a HAZOP is that we want to investigate: What can go wrong; What the consequence of this would be for the production process; And how we can enforce that if it goes wrong the system is “moved” to a safe state (using a safeguard).

There are various analysis methods available, I discuss the classical method because this is similar to what is called a computer HAZOP and like the method John suggests. The one that is really different, counterfactual analysis, and is especially used for complex problems like OT cyber security for ICS I discuss last.

A process safety HAZOP is conducted in a series of workshop sessions with participation of subject matter experts of different disciplines (Operations, safety, maintenance, automation, ..) and led by a HAZOP “leader”, someone not necessarily a subject matter expert on the production process but a specialist in the HAZOP process it self. The results of HAZOPs are as good as the participants and even with very knowledgeable subject matter experts and an inexperienced HAZOP leader results might be bad. Experience is a key factor in the success of a HAZOP.

The inputs for the HAZOP sessions are the PFDs and P&IDs. P&IDs typically represent a process unit but if this is not the case, the HAZOP team selects a part of the P&ID to zoom into. HAZOP discussions focus on process units, equipment and control elements that perform a specific task in the process. Our vaporizer could be a very small unit with a P&ID. The HAZOP team could analyze the various failure modes of the feed flow using what are called “guide words” to guide the analysis in the topics to analyze. Guide words are just a list of topics used to check a specific condition / state. For example there is a guide word High, and another Low, or No, and Reverse. This triggers the HAZOP team to investigate if it is possible to have No flow, is it possible to have High flow, Low flow, Reverse flow, etc. If the team decides that it is possible to have this condition, for example No Flow, they write down the possible causes that can create the condition. What can cause No flow, well perhaps a cause is a valve failure or a pump failure.

When we have the cause we also need to determine the consequence of this “failure mode”, what happens if we have No flow or Reverse flow. If the consequence is not important we can analyze the next, otherwise we need to decide what to do if we have No flow. We certainly can’t keep heating our vaporizer, so if there is no flow so we need to do something (the safeguard).

Perhaps the team decides on creating a safety instrumented function (SIF) that is activated on a low flow value and shuts down the heating of the vaporizer. These are the safeguards, initially high level specified in the process safety sheet but later in the design process detailed. A safeguard can be executed by a safety instrumented system (SIS) using a SIF and are implemented as mechanical devices. Often multiple layers of protection exist, the SIS being only one of them. A cyber security attack can impact the SIS function (modify it, disable it, initiate it), but this is something else as impacting process safety. Process safety typically doesn’t depend on a single protection layer.

Process safety HAZOPs are a long, tedious, and costly process that can take several months to complete for a new plant. And of course if not done in a very disciplined and focused manner, errors can be made. Whenever changes are made in the production process the results need to be reviewed for their process safety impact. For estimating risk a popular method is to use Layers Of Protection Analysis (LOPA). With the LOPA technique, a semi-quantitative method, we can analyze the safeguards and causes and get a likelihood value. I discuss the steps later in the blog when applied for cyber security risk.

Important to understand is that the HAZOP process doesn’t take any form of malicious intent into account, the initiating events (causes) happen accidentally not intentionally. The HAZOP team might investigate what to do when a specific valve fails closed with as consequence No Flow, but will not investigate the possibility that a selected combination of valves fail simultaneously. A combination of malicious failures that might create a whole new scenario not accounted for.

A cyber threat actor (attacker) might have a specific preference on how the valves need to fail to achieve his objective and the threat actor can make them fail as part of the attack. Apart from the cause being initiated by the threat actor, also the safeguards can be manipulated. Perhaps safeguards defined in the form of safety instrumented functions (SIF) executed by a SIS or interlocks and permissives configured in the basic process control system (BPCS). Once the independence of SIS and BPCS is lost the threat actor has many dangerous options available. There are multiple failure scenarios that can be used in a cyber attack that are not considered in the analysis process of the process safety HAZOP. Therefore the need for a separate cyber security HAZOP to detect this gap and address it. But before I discuss the cyber security HAZOP, I will briefly discuss what is called the “Computer HAZOP” and introduce the concept of Stage-Zero-Thinking.

A Computer HAZOP investigates the various failure modes of the ICS components. It looks at the power distribution, operability, processing failures, network, fire, and sometimes at a high level security (can be both physical as well as cyber security). It might consider malware, excessive network traffic, a security breach. Generally very high level, very few details, incomplete. All of this is done using the same method as used for the process safety HAZOP, but the guide words are changed. In a computer HAZOP we work now with guide words such: “Fire”, Power distribution” “Malware infection”, etc. But still document the cause, consequence, and consider safeguards in a similar manner as for the process safety HAZOP. Consequences are specified at high level such as loss of view, loss of control, loss of communications, etc.

At a level we can judge their overall severity but not link it to detailed consequences for the production process. Cyber security analysis at this level would not have foreseen such advanced attack scenarios as used in the Stuxnet attack, it remains at a higher level of attack scenarios. The process operator at the Natanz facility also experienced a “Loss of View”, a very specific one the loss of accurate process data for some very specific process loops. Cyber security attacks can be very granular, requiring more detail than consequences as “Loss of View” and “Loss of Control” offer, for spotting the weak link in the chain and fix it. If we look in detail how an operator HMI function works we soon end up with quite a number of scenarios. The path between the finger tips of an operator typing a new setpoint and the resulting change of the control valve position is a long one with several opportunities to exploit for a threat actor. But while threat modelling the design of the controller during its development many of these “opportunities” have been addressed.

The more complex the number of scenarios we need to analyze the less appropriate the execution of the HAZOP method in the traditional way is because of the time it takes and because of the dependence on subject matter experts. Even the best cyber security subject matter specialists can miss scenarios when it is complex, or don’t know about these scenarios because they don’t have the knowledge of the internal workings of the functions. But before looking at a different, computer supported method, first an introduction of “stage-zero-thinking”.

Stage-zero refers to the ICS kill chain I discussed in an earlier blog where I tried to challenge if an ICS kill chain always has two stages. A stage 1 where the threat actor collects the specific data he needs for preparing an attack on the site’s physical system, and a second stage where actual attack is executed. We have seen these stages in the Trisis / Triton attack , where the threat actors attacked the plant two years before the actual attempt collect information in order to attack a safety controller for modifying the SIS application logic.

What is missing in all descriptions of TRISIS attack so far is stage 0, the stage where the threat actor made his plans to cause a specific impact on the chemical plant. Though the “new” application logic created by the threat actors must be known (part of the malware), it is nowhere discussed what the differences were between the malicious application logic and the existing application logic. This is a missed opportunity because we can learn very much from understanding rational behind the attackers objective. Generally objectives can be reached over multiple paths, fixing the software in the Triconex safety controller might have blocked one path but it is far from certain if all paths leading to the objective are blocked.

For Stuxnet we know the objective thanks to the extensive analysis of Ralph Langner, the objective was manipulation of the centrifuge speed to cause excessive wear of the bearings. It is important to understand the failure mode (functional deviation) used because this helps us to detect it or prevent it. For the attack on the Ukraine power grid, the objective was clear … causing a power outage .. the functional deviation was partially unauthorized operation of the breaker switches and partially the corruption of protocol converter firmware to prevent the operator to remotely correct the action. This knowledge provides us with several options to improve the defense. Another attack, the attack on the German Steel mill the actual method used is not known. They gained access using a phishing attack but in what way the attacker caused the uncontrolled shutdown is never published. The objective is clear but the path to it not, so we are missing potential ways to prevent it in future. Just preventing unauthorized access is only blocking one path, it might still be possible to use malware to do the same. In risk analysis we call this the event path, the longer we oversee this event path the stronger our defense can be.

Attacks on cyber physical systems have a specific objective, some are very simple (like the ransomware objective) some are more complex to achieve like the Stuxnet objective or in power the Aurora objective. Stage-zero-thinking is understanding which functional deviations in the ICS are required to cause the intended loss on the physical side. The threat actor starts at the end of the attack and plans an event path in the reverse direction. For a proper defense the blue team, the defenders, needs to think like the red team. If they don’t they will always be reactive and often too late.

The first consideration of the Stuxnet threat actor team must have been how to impact the uranium enrichment plant to stop doing what ever they were doing. Since this was a nation state level attack there were of course kinetic options, but they selected the cyber option with all consequences for the threat landscape of today. Next they must have been studying the production process and puzzling how to sabotage it. In the end they decided that the centrifuges were an attractive target, time consuming to replace and effectively reducing the plant’s capacity. Than they must have considered the different ways to do this, and decided on making changes in the frequency converter to cause the speed variations responsible for the wear of the bearings. Starting at the frequency converter they must have worked their way back toward how to modify the PLC code, how to hide the resulting speed variations from the process operator, etc, etc. A chain of events on this long event path.

in the scenario I discussed in my Trisis blog I created the hypothetical damage through modifying a compressor shutdown function and subsequently initiating a shutdown causing a pressure surge that would damage the compressor. Others suggested the objective was a combined attack on the control function and process safety function. All possible scenarios, the answer is in the SIS program logic not revealed. So no lesson learned to improve our protection.

My point here is that when analyzing attacks on cyber physical systems we need to include the analysis of the “action” part. We need to try extending the functional deviation to the process equipment. For many process equipment we know the dangerous failure modes, but we should not reveal them if we can learn from them to improve the protection. This because OT cyber security is not limited to implementing countermeasures but includes considering safeguards. In IT security, there is a focus on the data part for example: the capturing of access credentials; credit card numbers; etc.

In OT security need to understand the action, the relevant failure modes. As explained in prior blogs, these actions are in the two categories I have mentioned several times: Loss of Required Performance (deviating from design or operations intent) and Loss of Ability to Perform (the function is not available). I know that many people like to hang on to the CIA or AIC triad, or want to extend, the key element in OT cyber security are these functional deviations that cause the process failures to address these on both the likelihood and impact factors we need to consider the function and than CIA or AIC is not very useful. The definitions used by the asset integrity discipline offer us far more.

Both loss of required performance and loss of ability to perform are equally important. Causing the failure modes linked to loss of required performance the threat actor can initiate the functional deviation that is required to impact the physical system, with failure modes associated with the loss of ability to perform the threat actor can prevent detection and / or correction of a functional deviation or deviation in the physical state of the production process.

The level of importance is linked to loss and both categories can cause this loss, it is not that Loss of Performance (kind of equivalent of the IT integrity term) or Loss of Ability to Perform (The IT availability term) cause different levels of loss. The level of loss depends on how the attacker uses these failure modes to cause the loss, a loss of ability can easily result in a runaway reaction without the need of manipulation of the process function, some production processes are intrinsically unstable.

All we can say is that loss of confidentiality is in general the least important loss if we consider sabotage, but can of course lead to enabling the other two if it concerns confidential access credentials or design information.

Let’s leave the stage-zero-thinking for a moment and discuss the use of the HAZOP / PHA technique for OT cyber security.

I mentioned it in previous blogs, a cyber attack scenario can be defined as:

A THREAT ACTOR initiates a THREAT ACTION exploiting a VULNERABILITY to achieve a certain CONSEQUENCE.

This we can call an event path, a sequence of actions to achieve a specific objective. A threat actor can chain event paths, for example in the initial event path he can conduct a phishing attack to capture login credentials, followed-up by an event path accessing the ICS and causing an uncontrolled shut down of a blast furnace. The scenario discussed in the blog on the German steel mill attack. I extend this concept in the following picture by adding controls detailing the consequence.

Event path

In order to walk the event path a threat actor has to overcome several hurdles, the protective controls used by the defense team to reduce the risk. There are countermeasures acting on the likelihood side (for instance firewalls, antivirus, application white listing, etc.) and we have safeguards / barriers acting on the consequence side to reduce consequence severity by blocking consequences to happen or detect them in time to respond.

In principal we can evaluate risk for event paths if we assign an initiating event frequency to the threat event, have a method to “measure” risk reduction, and have a value for consequence severity. The method to do this is equivalent to the method used in process safety Layer Of Protection Analysis (LOPA).

In LOPA the risk reduction is among others a factor of the probability of demand (PFD) factor we assign to each safeguard, there are tables that provide the values, the “credit” we take for implementing them. The multiplication of safeguard PFDs in the successive protection layers provides a risk reduction factor (RRF). If multiplied with the initiating event frequency we get the mitigated event frequency (MEF). We can have multiple layers of protection allowing us to reduce the risk. The inverse of the MEF is representative for the likelihood and we can use it for the calculation of residual risk. In OT cyber security the risk estimation method is similar, also here we can benefit from multiple protection layers. But maybe in a future blog more detail on how this is done and how detection comes into the picture to get a consistent and repeatable manner for deriving the likelihood factor.

To prevent questions, I probably already explained in a previous blog, but for risk we have multiple estimation methods. We can use risk to predict an event to happen, this is called temporal risk, we need statistical information to get a likelihood. We might get this one day if we have every day an attack on ICS, but today there is not enough statistical data for ICS cyber attacks to estimate temporal risk. So we need another approach, and this is what is called a risk priority number.

Risk priority numbers allow us to rank risk, we can’t predict but we can show which risk is more important than another and we can indicate which hazard is more likely to occur than another. This is done by creating a formula to estimate the likelihood of the event path to reach its destination, the consequence.

If we have sufficient independent variables to score for likelihood, we get a reliable difference in likelihood between different event paths.

So it is far from the very subjective assignment method of a likelihood factor by a subject matter expert as explained by a NIST risk specialist in a recent presentation organized by the ICSJWG. Such a method would lead to a very subjective result. But enough about estimating risk this is not the topic today, it is about the principles used.

Counterfactual hazard identification and risk analysis is the method we can use for assessing OT cyber security risk in a high level of detail. Based on John Cusimano’s reaction it looks like an unknown approach. Though the method is at least 10+ years in every proper book on risk analysis and in use. So what is it?

I explained the concept of the event path in the diagram, counterfactual risk analysis (CRA) is not much more than building a large repository with as many event paths as we can think of and then processing them in a specific way.

How do we get these event paths? One way is to study the activities of our “colleagues” working in threat_community inc. They potentially learn us in each attack they execute one or more new event paths. Another way to add event paths is by threat modelling, at least than we become proactive. Since cyber security also entered the development processes of ICS in a much more formal manner, many new products today are being threat modeled. We can benefit of those results. And finally we can threat model ourselves at system level, the various protocols (channels) in use, the network equipment, the computer platforms.

Does such a repository cover all threats, absolutely not but if we do this for a while with a large team of subject matter experts in many projects the repository of event paths grows very quickly. Learning curves become very steep in large expert communities.

How does CRA make use of such a repository? I made a simplified diagram to explain.

The Threat Actor (A) that wants to reach a certain consequence / objective (O), has 4 Threat Actions (TA) at his disposal. Based on A’s capabilities he can execute one or more. Maybe a threat actor with IEC 62443 SL 2 capabilities can only execute 1 threat action, while an SL 3 has the capabilities to execute all threat actions. The threat action attempts to exploit a Vulnerability (V), however sometimes the vulnerability is protected with a countermeasure(s) (C). On the event path the threat actor needs to overcome multiple countermeasures if we have defense in depth, and he needs to overcome safeguards. Based on which countermeasures and safeguards are in place event paths are yes or no available to reach the objective, for example a functional deviation / failure mode. We can assign a severity level to these failure modes (HIGH, MEDIUM, etc)

In a risk assessment the countermeasures are always considered perfect, there reliability, effectiveness and detection efficiency is included in their PFD. In a threat risk assessment, where also a vulnerability assessment is executed, it becomes possible to account for countermeasure flaws. The risk reduction factor for a firewall that starts with the rule permit any any will certainly not score high on risk reduction.

I think it is clear that if we have an ICS with many different functions (so different functional deviations / consequences, looking at the detailed functionality), different assets executing these functions, many different protocols with their vulnerabilities, operating systems with their vulnerabilities, and different threat actors with different capabilities, the number of event paths grows quickly.

To process this information a CRA hazard analysis tool is required. A tool that creates a risk model for the functions and their event paths in the target ICS. A tool takes the countermeasures and safeguards implemented in the ICS into account, a tool that accounts for the static and dynamic exposure of vulnerabilities, and a tool that accounts for the severity of the consequences. If we combine this with the risk criteria defining the risk appetite / risk tolerance we can estimate risk and can quickly show which hazards have an acceptable risk, tolerable risk, or unacceptable risk.

So a CRA tool builds the risk model through configuring the site specific factors, for the attacks it relies on the repository of event paths. Based on the site specific factors some event paths are impossible, others might be possible with various degrees of risk. More over such a CRA tool makes it possible to show additional risk reduction by enabling more countermeasures. Various risk groupings become possible, for example it becomes possible to estimate risk for the whole ICS if we take the difference in criticality between the functions into account. We might want to group malware related risk by filtering on threat actions based on malware attacks or other combinations of threat actions.

Such a tool can differentiate risk for each threat actor with a defined set of TTP. So it becomes possible to compare SL 2 threat actor risk with SL 3 threat actor risk. Once we have a CRA model many points of view become available, could even see risk vary for the same configuration if the repository grows.

So there is a choice, either a csHAZOP process with a workshop where the subject matter experts discuss the various threats. Or using a CRA approach where the workshop is used to conduct a criticality assessment, consequence analysis, and determine the risk criteria. It is my opinion that the CRA approach offers more value.

So finally what has this all to do with the title “playing chess on the ICS board”? Well apart from a OT security professional I was also a chess player, playing chess in times there was no computer capable of playing a good game.

The Dutch former world champion Max Euwe (also professor Informatics) was of the opinion that computers can’t play chess at a level to beat the strongest human chess players. He thought human ingenuity can’t be put in a machine, this is about 50 years ago.

However large sums of money were invested in developing game theory and programs to show that computers computers can beat humans. The first time that this happened was when an IBM computer program “Deep Blue” won from then reigning world champion Gary Kasparov in 1997. The computers approached the problem brute force in those days, generating for each position all the possible moves, analyzing the position after the move and going to the next level for a new move for the move or moves that scored best. Computers could do this so efficiently that looked 20/30 moves (plies) ahead, far more than any human could do. Humans had to use their better understanding of the position and its weaknesses and defensive capabilities.

But the deeper a computer could look and the better its assessment of the position became the stronger it became. And twenty years ago it was quite normal that machines could beat humans at chess, including the strongest players. This was the time that chess games could not be adjourned anymore because a computer could analyse the position. Computers were used by all top players to check their analysis in the preparation of games, it considerably changed the way chess was played.

Than recently we had the next generation based on AI (E.g. Alpha Zero) and again the AI machines proofed stronger, stronger then the machines making use of the brute force method. But these AI machines offered more, the additional step was that humans started to learn from the machine. The loss was no longer caused by our brains not being able to analyze so many variations, but the computer actually understood the position better. Based upon all the games played by people the computers recognized patterns that were successful and patterns that would ultimately lead to failure. Plans that were considered very dubious by humans were suddenly shown to be very good. So grandmasters learned and adopted this new knowledge even by today’s world champion Magnus Carlsen.

So contrary John’s claim if we are able to model the problem we create a path where computers can conquer complex problems and ultimately be better than us.

CRA is not brute force – randomly generating threat paths – but processing the combined knowledge of OT security specialists with detailed knowledge of the inner workings of the ICS functions contained in a repository. Kind of the patterns recognized by the AI computer.

CRA is not making chess moves on a chess board, but verifying if an event path to a consequence (Functional deviation / failure mode) is available. An event path is a kind of move, it is a plan to a profitable consequence.

Today CRA uses a repository made and maintained by humans, but I don’t exclude it that tomorrow AI assisting us to consider which threats might work and which not. Maybe science fiction, but I saw it happen with chess, Go, and many other games. Once you model a problem computers have proofed to be great assistants and even proofed to be better than humans. CRA exists today, an AI based CRA may exist tomorrow.

So in my opinion the HAZOP method in the form applied to process safety and in computer HAZOPs leads to a generalization of the threats when applied for cyber security because of the complexity of the analysis. Generalization leads to results comparable with security standard-based or security-compliance-based strategies. For some problems we just don’t need risk, if I cross a street I don’t have to estimate the risk. Crossing in a straight line – shortest path – will reduce the risk. The risk would be mainly how busy the road is.

For achieving the benefits of a risk based approach in OT cyber security we need tooling to process all the hazards (event paths) identified by threat modelling. The more event paths we have in our brain, the repository, the more value the analysis produces. Counter fact risk analysis is the perfect solution for achieving this, it provides a consistent detailed result allowing for looking at risk from many different viewpoints. So computer applications offer significant value, by offering a more in depth analysis, for risk analysis if we apply the right risk methodology.

There is no relationship between my opinions and references to publications in this blog and the views of my employer in whatever capacity. This blog is written based on my personal opinion and knowledge build up over 42 years of work in this industry. Approximately half of the time working in engineering these automation systems, and half of the time implementing their networks and securing them.

Author: Sinclair Koelemij

OTcybersecurity web site

A wake-up call

Process safety practices and formal safety management systems have been in place in the industry for many years. Process safety management has been widely credited for reductions in the number of major accidents, proactively saving hundreds of lives and improving industry performance.

OT cyber security, the cyber security of process automation systems such as used by the industry, has a lot in common with the management of process safety and we can learn very much from the experience of formal safety management, build over more than 60 years. Last week I saw a lengthy email chain on a question “if the ISA 99 workgroup (the developers of the IEC 62443 standard) should look for a closer cooperation with the ISO 27001 developers to better align the standards”. Of course such a question results in discussions addressing the importance of ISO 27001 and others emphasizing the difficulties to apply the standard in the industry.

If there is a need for ISA to cooperate with another organization for aligning its standard, than in my opinion they should have a more close cooperation with the AIChE, the ISA of the chemical engineering professionals. The reason for this is that there is a lot to learn from process safety and though IEC 62443 is supposed to be a standard for industrial control systems, there is still a lot of “IT methodology” in the standard.

In this week’s blog I like to address the link between process safety and cyber security again, and discuss some of the lessons in process safety we can (actually should in my opinion) learn from. Not for adding safety to the security triad as some suggest, this is in my opinion for multiple reasons wrong, but because process safety management and OT cyber security management have many things in common when we compare their design and management processes and process safety management is much further in its development than OT cyber security management.

I accomplished in my career several cyber security certifications such as: CISSP, CISM, CRISC, ISO 27001 LA and many more with a pure technical focus. Did all this course material ever discuss industrial control systems (ICS)? No they didn’t, still they where very valuable for developing my knowledge. As an employee working for a major vendor of ICS solutions, my task became more to adopt what was applicable, learn from IT and park those other bits of knowledge for which I saw no immediate application. As my insights further developed I started to combine bits and pieces from other disciplines more easily. In the OT cyber security world, which is relatively immature, we can learn a lot from more mature disciplines such as process safety management. Such learning generally requires us to make adaptions to address the differences.

But despite these differences we can learn from studying the accomplishments of the process safety discipline, this will certainly steepen the learning curve of OT cyber security to make it more mature. If we want to learn from process safety, where better to start than the many publications of CCPS (Center for Chemical Process Safety) and the AIChE.

Process safety starts at risk, process safety studies the problem first before they attempt to solve the problem. Process safety recognizes that all hazards and risk are not equal, consequently it focuses more resources on higher hazards and risks. Does this also apply to cyber security, in my opinion very sparingly.

More mature asset owners in the industry adopted a risk approach in their security strategy, but the majority of asset owners is still very solution driven. They decide on purchasing solutions before they inventoried the cyber security hazards and prioritized them.

What are the advantages of a risk based approach? Risk allows for optimally apportioning limited resources to improve security performance. Risk also provides a better insight in where the problems are and what options there are to solve a problem. Both OT cyber security risk and process safety risk are founded on four pillars:

  • Commit to cyber security and process safety – A workforce that is convinced that their management fully supports a discipline as part of its core values will tend to follow process even when no one else is checking this.
  • Understand hazards and risk – This is the foundation of a risk based approach, it provides the required insight to make justifiable decisions and apply limited resources in an effective way. This fully applies for both OT cyber security and process safety.
  • Manage risk – Plants must operate and maintain the processes that pose risk, keep changes to those processes within the established risk tolerances, and prepare for / respond to / manage incidents that do occur. Nothing in here that doesn’t apply for process safety as well as OT cyber security.
  • Learn from experience – If we want to improve, and because of the constantly changing threat landscape we need to improve, we need to learn. Learning we do by observing and challenging what we do. Metrics can help us here, preferably metrics that provide us with leading indicators so we see the problem coming. Also this pillar applies for both disciplines, where process safety tracks near misses OT cyber security can track parameters such as AV engines detecting malware, or firewall rules bouncing off traffic attempting to enter the control network.

Applying these four pillars for OT cyber security would in my opinion significantly improve OT cyber security over time. Based upon what I see in the field, I estimate that less than 10 percent of the asset owners adopted a risk based methodology for cyber security, while more than 50 percent adopted a risk based methodology for process safety or asset integrity.

If OT cyber security doesn’t want to learn from process safety, it will take another 15 years to reach the same level of maturity. If this happens we are bound to see many serious accidents in future, including accidents with casualties. OT cyber security is about process automation lets use the knowledge other process disciplines build over time.

The alternative for a risk based approach is a compliance based approach, well known examples are for North America the NERC CIP standard, and for Europe the French ANSSI standard for cyber security or if we look at process safety the OSHA regulations in the US. All compliance driven initiatives. A compliance driven approach can lead to:

  • Decisions based upon ” If it isn’t a regulatory requirement, we are not going to do it”.
  • The wrong assumption that stopping the more frequent and easier to measure incidents (like for example the mentioned malware detection) discussed in standards will also stop the low-frequency / high consequence incidents.
  • Inconsistent interpretation and application of the practices described in the standard. Standards are often a compromise between conflicting opinions, resulting in soft requirements open for different interpretations.
  • Overemphasized focus on the management system, forgetting about the technical aspects of the underlying problems.
  • Poor communication between the technically driven staff and the business driven senior management, resulting in management not understanding the importance of the messages they receive and subsequently fail to act.
  • High auditing costs, where audits focus on symptoms instead of underlying causes.
  • Not moving with the flow of time. Technology is continuously changing, posing new risk to address. Risk that is not identified by a standard developed even as recent as 5 years ago.

This criticism on a compliance approach doesn’t mean I am against standards and their development. Merely I am against standards as an excuse to switch off our brain, close our eyes and ignore where we differ from the average. Risk based processes offer us the foundation to stay aware of all changes in our environment while still using standards as a checklist to make certain we don’t forget the obvious.

The four available strategies

Like I mentioned for cyber security the majority of the asset owners would fall in the category standards-based or compliance-based. It is a step forward compared to 10 years ago, when OT cyber security was ignored by many, but it is a long way off from where asset owners are for process safety.

Where we see in process safety the number of accidents decline, we see in cyber security that both the threat event frequency and the threat capability of the threat community rise. To keep up with the growing threat, critical infrastructure should adopt a risk based strategy to keep track with the threat community. Unfortunately many governments are driving for a compliance based strategy because they can more easily audit this and doing this they are setting the requirements too low for a proper protection against the growing threat.

A risk based approach doesn’t exclude compliance with a standard, it just makes the extra step predicting the performance of the various cyber security aspects, independent of any loss events, and improving its security. As such it adds pro-activity to the defense and allows us to keep track with the threat community.

The process safety community recognized the bottlenecks of a compliance based strategy and jumped forward by introducing a risk based approach allowing them to further reduce the number of process safety accidents after several serious accidents happened in the 1980s. Accidents caused by failure of the compliance based management systems.

Because of the malicious aspects inherent to cyber security, because of the fast growing threat capabilities of the threat community and because of an increase in threat events, not jumping to a risk based strategy like the process safety community did is waiting for the first casualties to occur as a result of a cyber attack. TRISIS had the potention be the first attack causing loss of life, we were lucky it failed. But the threat actors have undoubtedly learned from their failure and work on an improved version.

I don’t include the alleged attack on a Siberian pipeline in 1982 as a cyber event as some do. If such an event would happen due to a cyber attack this would be an act of war. So for me we have been lucky so far that cyber impact was mainly a monetary value, but this can change either willingly or accidentally.

It would become a very lengthy blog if I would discuss each of the twenty elements of the risk based safety program or reliability program. But each of these elements has a strong resemblance with what would be appropriate for a cyber security program.

The element I like to jump to is the Hazard Identification and Risk Analysis (HIRA) element. HIRA is the term used to bundle all activities involved in identifying hazards and evaluating the risk induced by these hazards. In my previous blog on risk I showed a more detailed diagram for risk, splitting it in three different forms of risk. For this blog I like to focus on the the hazard part using the following simplified diagram for the same three forms of risk.

Simplified risk model

On the left side we have the consequence of the cyber security attack, some functional deviation of the automation system. This is what was what was categorized as loss of required performance and loss of ability to perform. The 3rd category, loss of confidentiality, will not lead directly to a process risk so I ignore it here. Loss of required performance caused the automation system to either execute an action that should not have been possible (not meeting design intent) or an action that does not perform as it should (not meeting operation intent). In the case of loss of ability to perform, the automation system could not execute one or more of its functions.

So perhaps the automation system’s configuration was changed in a way that the logical dimensions configured in the automation system no longer represent the physical dimensions of the equipment in the field. For example if the threat actor increases the level range of a tank this does not result into a bigger physical tank volume, so a possibility exists that the tank is overfilled without the operator noticing this in his process displays. The logical representation of the physical system (its operating window) should fit the physical dimensions of the process equipment in the plant. If this is not the case this would be the failure mode “Integrity Operating Window (IOW) deviation” in the “Loss of Required Performance” category.

Similar the threat actor might prevent the operator to stop or start a digital output, the failure mode “Loss of Controllability” in the category “Loss of Ability to Perform”. Not being able to stop or start a digital output might translate to the inability to stop or start a pump in the process system. At least stopping or starting by using the automation system. We might have implemented an electrical switch (safeguard) to do it manually if the automation system would fail.

Not being able to modify a control parameter would give rise to a whole other category of issues for the production process. Each failure mode has a different consequence for the process system equipment and the production process.

Cyber security hazards are a description of a threat actor (threat community) executing a threat event (threat action exploiting a vulnerability) resulting in a specific consequence (the functional deviation) entering a specific failure mode for the automation system function. What the consequence is for the production process and its equipment depends on the automation system function affected and the characteristics of the production system equipment and production process. This area is investigated by the process (safety) hazards. Safety is here between brackets because not every functional deviation results in a consequence for process safety, there can also be consequences for product quality or production loss not impacting process safety at all. If the affected function would be the safety instrumented system (SIS), a deviation in functionality would always affect process safety.

The HIRA for process risk would focus on how the functional deviations influence the production process and the asset integrity of its equipment. As such the HIRA has a wider scope than it would have in a typical process safety hazard analysis / hazop. For cyber security it combines what we call the computer hazop, the analysis of how failures in the automation system impact the production system and the process safety hazop.

On the other hand from a safeguard perspective of the safety hazop / PHA the scope is smaller because we can only influence the functionality of the “functional safety” functions provided by the SIS. Safety has multiple layers of protection and multiple safeguards and barriers that contain a dangerous situation. A cyber security attack can only impact the programmable electronic components (e.g. SIS) of the process safety protection functions.

This is the reason why I protest if people talk about “loss of safety” in the context of cyber security, there are in general more protection mechanism implemented, so safety is not necessarily lost. Adding safety to the triad is also incorrect in my opinion, this should be at minimum adding functional safety because that is the only safety layer that can be impacted by a cyber threat event, but functional safety is also already covered within the definition of loss of required performance.

IEC 62443’s loss of system integrity is not covering all the failure modes covered by loss of required performance. The IEC 62443-1-1 defines integrity as: “Quality of a system reflecting the logical correctness and reliability of the operating system, the logical completeness of the hardware and software implementing the protection mechanisms, and the consistency of the data structures and occurrence of the stored data.”

This definition is fully ignoring the functional aspects in an automation system, therefore it is a too limited cyber security objective for an automation system. For example where do we find in the definition that an automation action needs to be performed on the right moment in the right sequence and appropriately coordinated with other functions.

Consider for example the coordination / collaboration between a conveyor and filling mechanism or a robot. The IEC 62443 seven foundation requirements don’t cover all aspects of an automation function / industrial control system. The combined definitions used by risk based asset integrity management and risk based process safety management do cover these aspects, an example of a missed chance to learn something from an industry that has considerably more experience in its domain than the OT cyber security community has in its own field.

Can we conduct the HIRA process for cyber security in a similar way as we do for process safety? My only answer here is a firm NO!. The malicious aspects of cyber security make it impossible to work in the same way as we do for process safety. The job would just not be repeatable (so results are not consistent) and too big (so extremely time consuming). The number of possible threat events, vulnerabilities, and consequences is just too big to approach this in a workshop setting as we do for process hazard analysis (PHA) / safety hazop.

So in cyber security we work with tooling to capture all the possibilities, we categorize consequences and failure modes to assign them a trustworthy severity value meeting the risk criteria of the plant. But in the end, we end with a risk priority number just like we have in risk based process safety or risk based asset integrity to rank the hazards.

The formula for cyber security risk is more complex because we not only have to account for occurrence (threat x vulnerability) and consequence, but also for detection, and the risk reduction provided by countermeasures, safeguards and barriers. But these are normal deviations, also risk based asset integrity management and risk based process safety management differ at detail level.

The following key principles need to be addressed when we develop, evaluate, or improve any management system for risk:

  • Maintain a dependable and consistent practice – So the practice should be documented, the objectives of the benefits must be in terms that demonstrate to management and employees the value of the activities;
  • Identify hazards and evaluate risks – Integrate HIRA activities into the life cycle of the ICS. Both design and security operations should be driven by risk based decisions;
  • Assess risks and make risk based decisions – Clearly define the analytical scope of HIRAs and assure adequate coverage. A risk system should address all the types of cyber security risk that management wants to control;
  • Define the risk criteria and make risk actionable – It is crucial that all understand what a HIGH risk means, and that it is defined what the organization will do when something attains this level of risk. Risk appetite differs depending on the production process or process units within that process;
  • Follow through on risk assessment results – Involve competent personnel, make a consistent risk judgement so we can follow through without too much debate if results require this;

Risk diagrams to express process risk generally have less risk levels as a risk assessment diagram for cyber security. This because it has a more direct relationship with the business / mission risk, so actions have a direct business justification. An example risk assessment diagram for process risk is shown in the following diagram:

Risk assessment diagram for process risk example

The ALARP acronym stands for As Low As Reasonably Practicable a commonly used criterion for process related risk. Once we have the cyber security hazards and their process consequence we can assign a business impact to each hazard and create risk assessment matrices for each impact category as explained in my blog on OT cyber security risk using the impact diagram as example. or if preferred the different impact categories can be shown in a single risk assessment matrix.

Mission impact example

So far this discussion about the parallels between risk based process safety, risk based asset integrity, and risk based OT cyber security. I noticed in responses to previous blogs, that for many this is an uncharted terrain because they might not be familiar with all three disciplines and the terminology used. Most risk methods used for cyber security have an IT origin. This results in ignoring the action part of an OT system, OT being Data + Action driven where IT is Data driven only. Another reason to more closely look at other risk based management processes applied in a plant.

There is no relationship between my opinions and references to publications in this blog and the views of my employer in whatever capacity. This blog is written based on my personal opinion and knowledge build up over 42 years of work in this industry. Approximately half of the time working in engineering these automation systems, and half of the time implementing their networks and securing them.

Author: Sinclair Koelemij

OTcybersecurity web site

Dare for More, featuring the ICS kill-chain and a steel mill

When selecting a topic for a blog I generally pick one that entails some controversy. This time I select a topic that is generally accepted and attempt to challenge it to create the controversy. I believe very much that OT security is about learning, and that learning requires to continuously challenging the new knowledge we acquire. So this blog is not about trying to know better, or trying to refute a well founded theorem, but simply by applying some knowledge and ratio to investigate the feasibility of other options. In this case, is a one stage ICS attack feasible?

Five years ago Michael Assante and Robert Lee wrote an excellent paper called “The Industrial Control System Cyber Kill Chain“. I think the readers of this blog should carefully study this document, the paper provides a very good structure on how threat actors approach attacks on industrial control systems (ICS). The core message of the paper is that attacks on ICS, with the objective to damage production equipment, are two stage attacks.

The authors describe a first stage where the threat actor team collects information by penetrating the ICS and establishing a persistent connection, this is called in the paper the “Management and Enablement Phase“. This phase is followed by the “Sustainment, Entrenchment, Development, and Execution” phase, the phase where the threat actor captures additional information and prepares for the attack on the industrial control system (ICS).

Both phases are part of the first attack stage. The information collected in stage 1 is used to prepare the second stage in the kill chain. The second stage conducts the attack on the process installation to cause a specific failure mode (“the damage of the production system”). Typically there is considerable time between the first stage and the second stage, time used for the development of the second stage.

I assume that the rational of the authors for suggesting two stages is that each plant is unique, and as such each ICS configuration is unique, so to damage the process installation we need to know its unique configuration in detail before we can strike.

Seems like fair reasoning and the history of ICS attacks supports the theorem of two stage attacks.

  • Stuxnet required the threat actor team to collect information on: which variable speed drives were used to cause the necessary speed variations causing the excessive wear in the centrifuge bearings. The threat actor team also needed information on which process tags were configured in the Siemens control system to hide these speed variations from the process operator, and the threat actors required a copy of the PLC program code so they could modify it to execute the speed variations. The form of Stuxnet’s stage 1 differs probably very much from the ICS kill chain stage 1 scenario in general (Probably partially a non electronic old fashioned espionage activity), but this isn’t important. There is a stage 1 collecting information, and a stage 2 that “finishes” the job. So high level it matches the ICS kill chain pattern described in the paper.
  • The two attacks on the Ukraine power grid in 2015 and 2016 follow a similar pattern. It is very clear from the efficiency of the attack, developed tools and the very specific actions carried out, that the threat actor team had detailed knowledge on what equipment was installed, and which process tags were related to the breaker switches. So also in this case the threat actor team executed a stage 1 collecting information, than based on this information the threat actor team plans the stage 2 attack, and in the stage 2 attack the actual objective is realized.
  • The third example TRISIS / TRITON, follows the same pattern. Apparently the objective of this attack was to modify the safety integrity function in a Tristation safety controller. Details here are incomplete when reading / listening to the various sources. An interesting story, though perhaps at times a bit too dramatic for those of us that regularly spend their days at chemical plants, is for example the Darknet diaries on the TRISIS attack. Featuring among others Robert Lee and my former colleague Marina Krotofil. Was the attack directed against a Fire & Gas Tristation, or was the emergency shutdown function the target? This is not very clear in the story, because of the very different set of consequences for the production process an important detail if it comes to understanding the objective of the attack. Never the less also in the TRISIS case we saw a clear two stage approach, again an attack in two stages. First attack collecting the process information and Tristation configuration and logic, and a second attack attempting to install the modified logic and initiate (or wait for) something to happen. In my TRISIS revisited blog I explained a possible scenario to cause considerable damage and showed for this to happen that we don’t need to have a simultaneous attack on the control system.

What am I challenging in this blog? For me the million dollar question is, can an attacker cause physical equipment damage in a one stage attack, or are ICS attacks by default two stage attacks? Is a one stage attack, where all knowledge required is readily available in the public space and known by a subject matter experts, possible? And if it is a possibility, what are the characteristics that make such a scenario possible?

Personally I believe it is possible and I might even have seen an example of such an attack that I will discuss in more detail. I believe that an attacker with some basic hands-on practice working with a controls system, can do it it in a single stage.

I am not looking for scenarios that cause a loss of production, like for example a ransomware attack would cause. This is too “easy”, I am looking for targets that when attacked in the first stage would suffer considerable physical damage.

I am looking into these scenarios always for better understanding how such an attack would work and what we can learn from it to prevent such a scenario or make at least make it more difficult. Therefore I like to follow the advice of the Chinese general Sun Tzu, to learn to know the opponent, as well as our own shortcomings.

Sun Tzu wrote over 2500 years ago, the following important lesson which is also true in OT security:

  • “If you know the enemy and you know yourself, you don’t have to fear the result of a hundred battles.”
  • “If you know yourself, but not the enemy, you will also be defeated for every victory achieved.”
  • “If you don’t know the enemy or yourself, you will succumb in every battle.”

So lets investigate some scenarios that can lead to physical damage. In order to damage process equipment we have to focus on consequences with failure modes belonging to the categories: Loss of Required Performance and Loss of Ability (See my earlier blogs for an explanation) This since only failure modes in those categories can cause physical damage in a one stage attack.

Loss of confidentiality is basically the outcome of the first stage in a two stage attack, access credentials intellectual property (e.g. design information), or information in general all might assist in preparing stage 2. But I am looking for a single stage attack so need to rely on knowledge available in the public domain without the need to collect it from the ICS, gain access into the ICS and cause the damage on the first entry.

From a functional aspect, the type of function to attack for causing direct physical damage would be: BPCS (Basic Process Control System), SIS (Safety Instrumented System), CCS (Compressor Control System), MCC (Motor Control Center), BMS (Boiler Management System), PMS (Power Management System), APC (Advanced Process Control), CPS (Condition Protection System), and IAMS (Instrument Asset Management System).

So plenty of choice for the threat actor team depending on the objective. It is not difficult for a threat actor to find out which systems are used at a specific site and which vendor provided these functions. This because if we know the product made, we know which functions are mandatory to have. If we know the the business a bit we can find many detailed success stories on the Internet, revealing a lot of interesting detail for the threat actor team. Additionally threat actors can have access to a similar system for testing their attack strategies, such as for example the TRISIS threat actor team had access to a Triconix safety system for its attack.

To actually make the damage happen we also need to consider the failure modes of the process equipment. Some process equipment would be more vulnerable than others. Interesting candidates would be:

  • Extruders such as used in the thermoplastic industry, an extruder melts raw plastic, adds additives to it and passes it through a die to get the final product. This is a sensitive process where too high heath would change the product structure or an uneven flow might cause product quality issues. But the worst condition is no flow, if no flow happens this would result in that the melted plastic would solidify within the extruder. If this would happen, considerable time is required to recover from this. But this is a failure mode that happens once in a while also under normal circumstances, so an annoyance but process operations knows how to handle this so hardly an interesting target for a cyber attack attempting to cause significant damage.
  • How about a kiln in a cement process? If a kiln doesn’t rotate, the construction would collapse under its own weight. So stopping a kiln could be a potential target, however it is not that complex to create a safeguard creating a manual override to bypass the automation system to keep the kiln rotating. So also not an interesting target to pursuit for this blog.
  • How about a chemical process where runaway reactions are a potential failure mode? A runaway reaction is a thermally unstable reaction that accelerates with rising temperature and can ultimately lead to explosions and fires. A relatively recent example of such an accident is the Shell Moerdijk accident in 2014. Causing a runaway reaction could certainly be a scenario because these can be induced relatively easy. The threat actor team wouldn’t need that much specific information to carry out the attack, they could perhaps stop the agitator in the reactor vessel, or stop a cooling process to trigger the runaway reaction. If the threat actor gained access to the control system, this action is not that complex to do if familiar with control systems. So for me a potential single stage attack target.
  • Another example that came to mind was the attack on the German steel mill in 2014. According to the BSI report the attacker(s) gained access into the office network through phishing emails, once the threat actor had access into the office network they worked their way into the control systems. How this happened is not documented, but could have been through some key logger software. Once the threat actor had access to the control system they caused what was called “an uncontrolled shutdown” by shutting down multiple control system components. This looks like a one stage attack, lets have a closer look.

LESSON 1: Never allow access from the office domain into the control domain without implementing TWO-FACTOR AUTHENTICATION. Not even for your own personnel. Not implementing two-factor implementation is denying the risk of phishing attacks and ignoring defense in depth. When doing so we are taking a considerable risk. See also my blog on remote access, RULE 3.

For the steel mill attack there are no details known on what happened other than that the threat actor according to the BSI report shuts down multiple control system components and causes massive damage. Just speculating from now on what might have happened but a possible scenario could have been shutting down shutting down the cooling system and shutting down BPCS controllers so the operator can’t respond that quickly. The cooling system is one of the most critical parts of a blast furnace. Because the BSI report mentions both “Anlagen” and “Steurungskomponenten” it might have been above suggestion, first shutting down the motors of the water pumps and than shutting down the controllers to prevent a quick restart of the pumps.

The picture on the left (Courtesy of HSE) shows a blast furnace. A blast furnace is charged at the top with iron ore, coke, sinter, and limestone. The charge materials gradually work their way down, reacting chemically and thermally on their path down. This process takes about 6-8 hours depending on the size of the furnace. The furnace is heated by injecting hot air (approx. 1200 C) mixed with pulverized coal, and sometimes methane gas through nozzles called Tuyeres in the context of a blast furnace.

This results in a furnace temperature of over 2000 C. To protect the blast furnace shell against these high temperatures it is critical to cool the refractory lining (See picture). This cooling is done by pumping water into the lining. Cooling systems are typically fully redundant having doubled all equipment.

There would be multiple electrical pump systems and turbine (steam) driven pump systems. If one system fails, the other would take immediately over. One being steam driven, the other being electrical driven. So all looks fine from a cooling system failure perspective. The problem is that when we consider OT cyber security we also have to consider malicious failures / forced shutdowns. In those cases redundancy doesn’t work multiple motors can be switched of, neither is it so that if a process valve fails to a closed or open position there might not be another valve doing the same or in opposite direction. Frequently we see in process safety HAZOP analysis that double failures are not taken into account, this is the field of the cyber security HAZOP translating the various failure modes of the ICS functions in how they can be used to cause process failures.

The question in above scenario is could the attacker shutdown both pumps, and would there be a manual restart of the cooling system possible. If this would fail, the lining would overheat very quickly. In the case of a Corus furnace in Port Talbot, the cooling system was designed to run simultaneously two pumps, each producing 45.000 litres per minute. So a flow equivalent to 90.000 1 liter water bottles per minute. If we would need a crowd of people to consume this amount of water per minute, we get a very sizable crowd. Just to give you an idea how much water this is. If the cool water flow was stopped, the heat in the lining would rise very quickly and as a result the refractory lining would be damaged through the huge thermal stress created.

For safety purposes there is generally also an emergency water tower which acts when the water pressure drops. This system supplies water through gravitational force, it might not have worked, or maybe insufficient capacity to prevent damage. Or perhaps the attacker also knew a way to stop this safety control.

Do we need a two-stage attack for above scenario?

I believe a threat actor with sufficient hands-on experience with a specific BPCS, can relatively quickly locate these critical pumps and could shut them down. With the same level of knowledge he can subsequently shutdown the controller if his authorizations would allow this. Typically engineer level access would be required, but I also encountered systems were process operators could shutdown a controller. How blast furnaces work and what the critical functions are, even which companies specialize in supplying these functions is all in the public domain. So perhaps a single stage attack is possible.

If above is a credible scenario on what might have happened in the case of the German steel mill, what can we learn from it and do to increase the resilience against this attack?

  • First, we should not allow any remote access (access from the corporate network is also remote access) without two-factor authentication if the user would have “write” possibilities in the ICS. The fact that an attacker could gain access into the corporate network and from there could get access into the control network and causing an uncontrolled shutdown is in my opinion a significant (and basic) security flaw.
  • Second, we should consider implementing dual control for critical functions in the process that have a steady state. For example a compressor providing instrument air, or in this case a cool water pump and its redundant partners that should be on as the normal state. Dual control would demand that two users approve the shutdown action before the control system executes the command, this would generally be users with a different authorization level. Such a control would further raise the bar for the threat actor.

LESSON 2: For critical automation functions that can cause significant damage when initiated, consider to either isolate them from the control system (hardwired connections) or implement DUAL CONTROL to not only depend on a single layer of protection – access control. Defense in depth should never be ignored for critical functions, WHEN CRITICAL DON’T RELY ON A SINGLE CONTROL, APPLY DEFENSE IN DEPTH!

Above two additional security controls would make the sketched scenario much more difficult, almost impossible to succeed. OT security is more than installing AV, patching and a firewall. To reduce risk we need to assess security from all points of view: the automation function and its vulnerabilities, our protection of these vulnerabilities, our situational awareness of what is happening, and what threats there are – which attack scenarios could happen.

IEC 62443 specifies the “dual control” requirement as an SL 4 requirement, I personally consider this as a flaw in the standard and believe it should already be a mandatory requirement for SL 3 because unauthorized access to critical process equipment is well within the capabilities of the “sponsored attacker” type of threat actor.

Having dual control as a requirement doesn’t mean that all control actions should have this implemented, but there are critical functions in a plant that are seldom switched on or off where adding dual control adds security by adding DEFENSE IN DEPTH. When critical, don’t rely on a single control.

Also today’s blog is a story on the need for approaching OT security of ICS in a different manner as we do for IT systems where network security and hardening are the core activities for prevention. Network security and hardening of the computer systems are also essential first steps for an OT system but we should never forget the actual automation functions of the OT systems.

This is why OT security teams should approach OT security differently and construct bow-tie diagrams for cyber security hazards, relating cause (threat actor initiating threat action exploiting a vulnerability) to consequence (the functional deviation) and identifying security countermeasures, safeguards, and barriers. Only following this path we can analyze possible process failures as result of a functional deviation and can design OT systems in a secure way. However for this method to provide the required information we need a far higher level of detail / discrimination than terminology used in the past offered. Terminology such as loss of view and loss of control don’t lead to identifying countermeasures, safeguards and barriers. To make a step toward how a cyber attack can impact a production system we need much more granularity, therefor the 16 failure modes discussed in a prior blog.

Each ICS main function (BPCS, SIS, CCS, PMS, ….) has a fixed set of functions and potential deviations, it is the core task of the cyber security HAZOP to identify what risk they bring. Not to identify these deviations, these are fixed because each main function has a set of automation tasks it carries out. It are the deviations, their likelihood and severity for the production installation that are of importance, because than we know what benefits controls bring and which controls are of less importance. But we need to consider all options before we can select.

LESSON 3 – My final lesson of the day, first analyze what the problem is prior to trying to solve it.

Many times I see asset owners surfing the waves of the latest security hype. Every security solution has its benefits and “exciting” features, but this doesn’t mean it is the right solution for your specific problem or addressing your biggest security gap.

To know what are the right solutions you need to have a clear view on the cyber security hazards in your system, and then priority and select those that contribute most. There are often many features already available, start using them.

This leads to reusing methodologies we have learned to apply successfully for almost 60 years now in process safety, we should adapt them where necessary and reuse them for OT security.

There is no relationship between my opinions and references to publications in this blog and the views of my employer in whatever capacity. This blog is written based on my personal opinion and knowledge build up over 42 years of work in this industry. Approximately half of the time working in engineering these automation systems, and half of the time implementing their networks and securing them.

Author: Sinclair Koelemij

OTcybersecurity web site

Letting a goat into the garden

Criticizing a standard is no easy matter, once a group moves with a common idea the individual is supposed to stay in line. But the Dutch are direct, some might call it blunt, others rude. And I am Dutch and have a strong feeling the IEC 62443 standard is promising more than it can deliver, so want to address this in today’s blog. Not to question the value of the standard, neither to criticize the people contributing to it often in their private time, just to clarify where the standard has great value and where flaws are appearing.

This is a story about risk, and since the many wonders of OT security risk have my special attention, it is time to clarify my position on the standard in more detail.

The Dutch have a phrase “De knuppel in het hoenderhok gooien”, literally translated it means “Throwing the bat into the chicken shed”. The proper English translation seems to be to “Throw the cat among the pigeons”. Both expressions don’t align very well with my nature, agility and the purpose of this blog. So I was looking for a better phrase and decided to use the Russian phrase “пустить козла в огород” (let a goat into the garden). It seems to be a friendly action from the perspective of both the goat and the threat actor, so let me be the guy that lets the goat into the garden.

As always I like to learn, better understand the rational behind choices made, I don’t write this blog to confront those waiting in their trenches to fight for an unshakable belief in the blessings of a particular standard. Standards have strong points and weaker points.

I am in favor of standards, not too many standards if they merely overlap others, and I see their value when we make our initial steps to guide us in protecting our ICS targets.

I also see their value for vendors when they need to show asset owners that their products have been evaluated for meeting an established set of security requirements, to show that their development teams create new products with security processes embedded in their product development process, and to show that we operate our services with a focus on security. The ISA 99 team has really achieved a fantastic result and contributed to a more secure ICS. ISASecure is an excellent example of this.

But I also see that standards are sometimes misused by people to hide behind, for example if a standard doesn’t address a specific topic. “If the standard doesn’t address it, it isn’t important we can ignore it”. I see that standards are sometimes referred to in procurement documents to demand a certain level of protection. However standards are not written as procurement documents, they allow for many shades of gray and above all their development and refresh cycle struggles with the speed of change of technology in an continuously changing ICS threat landscape. Standards are good, but also have their pitfalls to be aware off. So I remain critical when I apply them.

Europe is a patchwork of standards without many major differences between those standards. Standards seem to bring out the dog in us, by developing new standards without substantially differentiating from existing. Standards sometimes seem to function as the next tree on a dogs walk through life. It is apparently a pleasant activity to develop new standards, though they often developed more into trust zones to make them look different creating hurdles in a global community.

The IEC 62443 / ISA 99 was the first standard that guided us (I know ISO 27001 has older roots, but not aimed at ICS). The standard had a significant influence in our thinking, also on my thinking, vocabulary and became the foundation for many standards since. Thanks to the standard we could make big steps forward.

But I feel the standard also makes promises it can’t meet in my opinion. Specifically the promise that it also addresses the threat posed by advanced threat actors with all the resources they need and operating in multi-discipline teams. The security level 3 and security level 4 type of threat actors of IEC 62443. This aspect I like to address in the blog.

IEC 62443-3-2 was recently released. The key concept of IEC 62443 turns around the definition of security zones and conduits between zones that pass the traffic, the conceptual pipeline that passes the channels (protocols) flowing between assets in the zones.

The standard wants us to determine “zone risk” and uses this risk to assign target security levels to a zone. A similar approach is also used by ANSSI the French standards institute, their standard also includes the risk model on how to estimate the risk.

Such an approach is the logical consequence from a drive to create a list of security requirements and provide a mechanism to select which of the many security requirements are an absolute must to stop a specific threat actor. “Give me a list on what to do” is a very human reaction when we are in a hurry and are happy with what our neighbors do to address a problem. However such an approach does not always take into account that the neighbor might be wrestling with a different problem.

ANSSI doesn’t link their risk result to a threat actor, IEC 62443 does link it to a threat actor in its SL1, SL2, SL 3, and SL4 definitions. ANSSI introduces the threat actor into its risk formula, taking a more capable threat actor into account raises the risk. The risk value determines the security class for the zone and the standard specifies which requirements must be met by the zone.

Within IEC 62443-3-2, the target level is the result of a high level risk assessment and a conversion from risk to a target security level. The IEC 62443-3-3 specifies the security requirements for this target level. Small differences between the two standards not important for my argument, though from a risk analysis perspective the ANSSI method is the theoretical better approach. It doesn’t need the transformation from risk to target level.

Where do I see a flaw in both ANSSI as well as IEC 62443 when addressing cyber security for critical infrastructure. This has to do with the concept of zone risk. Zone risk is in the IEC 62443 a kind of neighborhood risk, the assets live in a good or worse neighborhood. If you happen to live in the bad neighborhood you have to double your door locks, add iron bars before you windows and to also account for situational awareness and incident response you have to buy a big dog.

However zone risk / neighborhood risk doesn’t take the individual asset or threat into account. The protection required for the vault of a bank differs in the neighborhood from the protection required by the grocery that also wants to invite some customers in to do some business. You might say, the bank shouldn’t be in the bad neighborhood but that doesn’t work in an ICS where automation functions often overlap multiple zones.

There are a lot of intrinsic trust relations between components in an ICS that can be misused if we don’t take them into account. That would make security zones either so big that we could account anymore for differences in other characteristics (for example an 24×7 attended environment or an unattended environment) or make the zones so small that we get into trouble protecting the zone perimeter. The ideal solution would be what cyber security experts call the zero-trust-model, each asset is its own zone. This would be an excellent solution, but I don’t see it happen the gap with today’s ICS solutions is just too big, and also here there remain differences that require larger security zones.

Zone risk automatically leads to control based risk, a model where we compare a list with “what-is-good-for-you” controls with a list of implemented controls. The gap between the two lists can be seen as exposing non-protected vulnerabilities that can be exploited. The likelihood that this happens and the consequence severity would result into risk.

Essential for a control based risk model is that we ignore the asset and also don’t consider all threats, just those threats that result from the gap in controls. The concept works when you make your initial steps in life and learn to walk, but when attempting the steeple chase you are flat on your face very soon.

Zone risk is of course ideal for governance because we can make “universal rules”, it is frequently our first reaction to control risk.

The Covid-19 approach in many countries shows the difficulties this model faces. The world has been divided in different zones, sometimes countries, sometimes regions within a country. Governance within that zone has set rules for these regions, and thanks to this we managed to control the attack. So what is the problem?

Now we are on our way back to the “normal” society, while the threat hasn’t disappeared and is still present, we see the cracks in the rule sets. We have to maintain 1.5 meter distance (though rules differ by zone, we have 1 meter zones, and 2 meter zones). We allow planes to fly with all seats occupied, at the same time we deny this for buses and trains. We have restrictions in restaurants, theaters, sport schools, etc.

I am not challenging the many different rules, but just want to indicate that the “asset” perspective differs from the zone perspective and there are times that the zone perspective is very effective to address the initial attack but has issues when we want to continue with our normal lives. Governance today has a difficult job to justify all the differences, while trying to hold on their successful zone concept.

The same I see for OT security, to address our initial security worries the zone approach adopted by IEC 62443 worked fine. The defense team of the asset owners and vendors made good progress and raised the bar for the threat actor team. But the threat actor team also matured and extended their portfolio of devious attack scenarios, and now cracks become apparent in our defense. To repair these cracks I believe we should step up from control based risk to other methods of risk assessment.

The next step on the ladder is asset based risk. In asset based risk we take the asset and conduct threat modeling to identify which threats exist and how we best address them. This results in a list of controls to address the risk. We can compare this list with the controls that are actually implemented and the gap between the two will bring us on the path of estimating risk. Assets in this model are not necessarily physical system components, the better approach is to define assets as ICS functions. But the core of the method is we take the asset/function, analyse what can go wrong and define the required controls to prevent this from happening.

The big problem for governance is that this approach doesn’t lead to a confined set of controls or security requirements. New insights caused by changes in the function or environment of the function may lead to new requirements. But it is an approach that tends to follow technical change. For example the first version of IEC 62443-3-3 ignored the new technologies such as wireless sensors, virtual systems, and IIoT. This technology didn’t exist at the time, but today’s official version is still the version from September 2011. It took approximately 5 years to develop IEC 62443-3-3 and I believe it is an ISA policy to refresh a standard each 5 year. This is a long time in the security world. Ten years ago we had the Stuxnet attack, a lot has happened since than.

In threat based risk we approach it from the threat side, what kind of threats are feasible, what would be the best target for the threat actor team to execute the threat. If we have listed our threats, we can can analyze which controls would be necessary to prevent and detect them if attempted. These controls we can compare with the controls we actually applied in the ICS, and can construct risk from this gap to rank the threats in order of importance.

Following this approach, we truly follow the advice of the Chinese general Sun Tzu when he wrote “If you know the enemy and you know yourself, you don’t have to fear the result of a hundred battles. (Threat based risk) If you know yourself, but not the enemy, you will also be defeated for every victory achieved (Asset based risk). If you don’t know the enemy or yourself, you will succumb in every battle. (Control based risk)” Control based risk neither takes the asset into account (knowing yourself), nor the threat (knowing your enemy).

I don’t know if I have to call the previous part of the blog a lengthy intro, a historical context, or part of my continued story on OT cyber security risk. In the remainder of the blog I like to explain the concept of risk for operational technology, the core of every process automation system, meant to be the core of this blog.

When we talk about risk we make it sound as if only one type of risk exists, we sometimes mix up criticality and risk, and we use terms as high level risk where initial risk better represents what actually is attempted.

Let me try to be more specific starting with a picture I made for this blog. (Don’t worry the next diagrams are bigger).

The risk model

For me there are three types of risk related to ICS:

  • Cyber security risk
  • Process risk
  • Mission (or business) risk

Ultimately for an asset owner and its management, there is only one risk they are interested in, this is what I call mission risk. It is the risk related to the impact expressed in monetary value, in safety consequence, environmental damage, company image, regulations, and service delivery. Risk that directly threatens the companies existence. See the diagram I shared showing some of the impact categories in my earlier blog on OT cyber security risk.

If we can translate the impact of a potential cyber security incident (a cyber security hazard) into a credible mission risk value we catch the attention of any plant manager. Their world is for a large part risk driven. Management struggles with requests such as “I need a better firewall” (better means generally more expensive) without understanding what this better does in terms of mission risk.

Above model (I will enlarge the diagram) shows risk as a two stage / two step process. Let me explain starting at stage 1.

Cyber security risk

Part of what follows I already discussed in my ode to multiple honor and glory for Consequence, but I repeat it here partially for clarity and to add some more detail readers requested for in private messages.

The formula for cyber security risk is simple,

Cyber security risk = Threats x Vulnerability x Consequence.

I use the word consequence here, because I reserve the word impact for mission risk.

There is another subtle difference I like to make, I consider IT cyber security risk as a risk where consequence is primarily influenced by data. We are worried that data confidentiality is lost, data integrity is affected, or data is no longer available. The well known CIA triad.

Security in the context of automation adds another factor, that is the actions of the automated function. The sequence of actions certainly becomes of importance, time starts playing a role, it is becoming a game of action and interaction. Another factor, a very dominant factor enters the game. Therefore consequence needs to be redefined, to do this we can group consequence into three “new” categories:

  • Loss of required performance (LRP) – Defined as “The functions, do not meet operational / design intent while in service”. Examples are program logic has changed, ranges were modified, valve travel rates were modified, calibrations are off, etc.
  • Loss of Ability (LoA) – Defined as “The function stopped providing its intended operation” Examples are loss of view, loss of control, loss of ability to communicate, loss of functional safety, etc.
  • Loss of confidentiality (LoC) – Defined as “Information or data in the system was exposed that should have been kept confidential.” Examples are loss of intellectual property, loss of access credential confidentiality, loss of privacy data, loss of production data.

The “new” is quoted because the first two categories are well known categories in asset integrity management used on a daily base in plants. The data part (LoC) is simple, very much alike the confidentiality as defined in IT risk estimates. But for getting a more discriminating level of risk we need to split it up in additional sub-categories, sub-categories I call failure modes. For confidentiality there are four failure modes:

  • Loss of intellectual property – Examples of this can be a specific recipe, a particular way of automating the production process that needs to remain secret;
  • Loss of production data confidentiality – This might be data that can reveal production cost / efficiency, the availability to deliver a service;
  • Loss of access credential confidentiality – This is data that would allow a threat actor to raise his/her access privileges for a specific function;
  • Loss of privacy data confidentiality – This type of data is not commonly found in ICS, but there are exceptions where privacy data and with this the GDPR regulations are very important.

Failure modes differ for each function, there are functions for which none of above failure modes play a role and there are functions for which all play a role. Now let’s go to the next two categories Loss of Required Performance and Loss of Ability. These two are very specific for process automation systems like ICS. Loss of required performance has 6 failure modes assigned, in random sequence:

  • Integrity Operating Window (IOW) deviations – This applies to functional deviations that allow that the automation functions comes outside its design limitations which could cause immediate physical damage. Examples are modifying a level measurement range, potentially allowing to overfill a tank, or modifying a temperature range potentially damaging the coils in an industrial furnace. IOW is very important in a plant, so many standards have been addressing them;
  • Control Performance (CP) deviations – This failure mode is directly linked to the control dynamics, so where in the previous category the attacker modified engineering data, in this failure mode the attacker modifies operator data. For example raising a flow, stopping a compressor, shutting down a steel mill furnace. There are many situations in a plant where this can lead to dangerous situations, examples are when filling a tank with a non-conductive fluids, there are conditions that a static electricity buildup can create a spark. If there would be an explosive vapor in this tank this can lead to major accidents with multiple casualties. Safety incidents have been reported where this happened accidentally. One way to prevent this is to restrict the flow used to fill the tank. If an attacker would have access to this flow control he might maliciously maximize it to cause such a spark and explosion;
  • Functional safety configuration / application deviations (FS) – If safety logic or configuration was affected by an attack many things can happen, in most cases bad things because the SIS primary task is to prevent bad things from happening. Loss of functional safety and tampering with the configuration / application is considered a single category. This because there is no such thing as a bit of safety, safety is an all or nothing failure mode;
  • Monitoring and diagnostic function deviations (MD) – ICS contains many monitoring and diagnostic functions, for example vibration monitoring functions, condition protection functions, corrosion monitoring, analyzers, gas chromatography, emission monitoring systems, visual monitoring functions such as cameras monitoring the flare, and many more. Impacting these functions can be just as bad, as an example if an attacker were to modify settings in an emission monitoring solution the measured values might be reported as higher than they actually are. If this would become publicly known this would cause a stream of negative publicity and impact the company public image. Modifying vibration monitoring settings might prevent the detection of mechanical wear leading to a larger physical damage than would be the case if detected in time;
  • Monitoring data or alarm integrity deviation (MDAI) – This type of failure mode causes that data is no longer accurately represented, or alarms don’t occur when they should (Either too early, too late, maybe too many overflowing a process operator). The ICS function does in all cases its job as designed, however it is fed with wrong data and as a consequence might act in the wrong manner or too early or too late;
  • Loss of deterministic / real-time behavior behavior (RB) – This type of failure mode is very specific for real-time OT components. As I explained in my blog on real-time systems tasks are required to finish in time. if a task is not ready when its time slot ended it is bad luck, next time the task starts it starts at the beginning creating the possibility of starvation, where specific tasks never complete.

All above six failure modes have in common that the ICS functions, only it doesn’t function as intended. Either the design has been tampered with or its operational response doesn’t do the job as intended.

The next main category of consequences is Loss of Ability to perform, in this category the function is no longer available. But also here we have multiple failure modes (6) for grouping consequences.

  • Loss of controllability and / or intervention (LoCI) – When this occurs we lost the ability to move a system what is called its configuration space. We can’t adjust the flow anymore, pressure controls are lost, this might occur because the actuators fail, or because an operator has no longer access to the functions that allow him to do so.
  • Loss of observability (LoO) – This is the situation when we no longer can observe the actual physical state of the production process. This can be because we no longer measure this, but can also occur when we freeze the measured data by for example continuously replaying the same measurement message over and over again.
  • Loss of alarm or alerting function (LoAA) – This is the situation where there are no alarms or alerts warning the process operators of anomalies that they should respond to. Not necessarily restricted to BPCS alarms, it can also be alarms on a fire and alarm panel or a PAGA that doesn’t function.
  • Loss of coordination and / or collaboration (LoCC) – In an automation system, many functions collaborate or coordinate functions together. Coordination / collaboration is much more than communication, the activities need to be “synchronized” need to be aware of what the other is doing or things might go wrong with a potential high impact.
  • Loss of data communication (LoDC) – When we can’t communicate we can’t exchange commands or data. This doesn’t necessarily mean we can’t do anything, many functions can act isolated, sometimes there are hardwired connections to act.
  • Loss of reporting functions (historical data / trending) – This failure mode prevents us to report on ICS performance or observe slowly changing trends (creep) by blocking trending capabilities. Loss of reporting can be serious under certain circumstances, specifically for FDA and regulatory compliance.

This were the sixteen failure modes / sub-categories we can use to group consequences, functional deviations caused by a cyber attack. Not every function has all failure modes, and the failure modes have different severity scores for each function. But in general we can group hundreds of functional deviations of an ICS with its many functions (BPCS, SIS, CCS, IAMS, CDP, DAHS, PMS, MCC, MMS, ….) into these 16 failure modes and assign a severity value to each which we use for estimating cyber security risk for the various cyber security hazards.

I will not discuss all blocks of the diagram, that would be a book and no blog, but the criticality block is of importance. Why is criticality (the importance of the function) important?

For OT security criticality is a twin, one is criticality as the importance for the plant’s mission and the other is the importance for the threat actor. They are different things, for example a function such as Instrument Asset Management System (IAMS), is for the plant’s mission not so important, but for the threat actor’s mission it might be a very interesting object because it provides access to all field equipment.

The same differences we see with various technical and security management functions that if used by a threat actor provide him / her with many benefits. If we want to compare cyber security risk from different functions we can not just base this on consequence severity, we need to take function criticality into account. Another important aspect of criticality is that it is not a constant, criticality can increase over time. This provides us with information for our recovery time objectives, recovery point objectives, and maximum tolerable downtime. All critical security design parameters!

The zone and conduit model plays an important role in the Threat x Vulnerability, the likelihood, side of the cyber security risk equation. A very important factor here is exposure, which has two parts: dynamic exposure and static exposure. Connectivity is one of the three parameters for “measuring” static exposure.

The final block of the stage 1 side I like to discuss briefly, perhaps in a later blog in more detail, are the Functional Indicators of Compromise (FIoC).

In cyber security we are used to talk about IoC, general in the form that the threat actor makes some modifications in the registry or transfers some executable into a specific location. The research companies evaluating the cyber attacks, document these IoC in their reports.

But when we discuss functional deviations such as in OT cyber security as result of a cyber attack we have Indicators of Compromise here too, FIoC. This because often data is stored in multiple locations in the system. For example when we configure a controller we set various parameters for the field equipment connected. This data can be downloaded to the field equipment or separately managed by an IAMS. But it is not necessarily so that if changed in one place the other places are tracking it and automatically update.

This offers us one way of detecting inconsistencies and alert upon them. For multiple reasons an important function, but not always done. Similarly many settings in an ICS are always within a certain range, if they vary it are small variations. A cyber attack generally initiates bigger changes we can identify.

Not for all, but for many consequences / failure modes there is a functional indicator of compromise (FIoC) available to warn that something unusual occurred and we should check it.

Process risk and mission risk

Let’s slowly move to the end of the blog, I already surpassed my reading time long ago, let’s look at stage 2 the path from cyber security risk to mission risk.

Stage 1 provided us two results, a likelihood score and a set of functional deviations, that we need to bring over to stage 2. The identified functional deviations can cause deviations in the production process, perhaps a too high flow in my tank example, perhaps the possibility to close one or more valves simultaneously.

In order to evaluate their consequence for process risk we need to inspect which functional deviations have unforeseen potential process deviations. Process safety analysis thoroughly goes over the various failure modes that can occur in a plant and analyses how to prevent these to cause a personal safety incident or damage to the equipment.

But what process safety analysis does not do is looking for foul play. A PHA sheet might conclude that the failure of a specific valve is no issue because there is an open connection available, but what if that open connection would be blocked at the same time the threat actor manipulates initiates the failure of the valve. Two or more actions can occur simultaneously in an attack.

That is the activity in the second stage of the risk analysis, needed to arrive at mission risk. First we need to identify the process consequence that are of importance before we can translate this into business / mission impact. The likelihood of such an incident is the same as the likelihood of the cyber security incident that caused all the trouble.

Though the method of analyzing the process safety sheet and the checklist to process is probably just as interesting as many of the stage 1 processes a blog needs to end. So perhaps a later blog, or a book when I am retired.

What did I try to say in this blog? Well first of all I like to repeat, standards are important and the IEC 62443 is the most influential of all and contributes very much to the security of ICS. Doesn’t take away they are not above criticism, it is after all a men made product.

The structure of standards such as IEC 62443 or the French ANSSI standard leads to control based risk because of their zone based strategy. Nothing wrong with this, but in my opinion not sufficient to protect more critical systems that are attacked by more capable threat actors. Like the SL 3 and SL 4 type of threat actors. There I see gaps in the method.

I explained we have three forms of risk, cyber security risk, process risk, and mission risk. They differ because they need different inputs. We cannot just jump from cyber security risk to mission risk forgetting about how the functional deviations in the ICS caused by the cyber attack impact the production process, we need to analyse this step.

I have shown and discussed a two stage method to come from a cyber security hazard to a process failure hazard to mission risk. I didn’t explain the method on how I identified all these cyber security hazards, nor the method of risk analysis analysis to estimate likelihood. This can still be either threat based or asset based, maybe another blog to explain the details.

But at minimum the asset specific elements and the threats are accounted for in the method described, this is missing in the zone risk approach. Functional deviations (consequences) play no role in zone risk estimates.

Does this mean the IEC 62443 isn’t good enough, no absolutely not. All I say in this blog it is not complete enough, security cannot be achieved with just a list of requirements. This plays no role when the objective is to keep the cyber criminals (SL 2) out, it plays a role when attacks become targeted and ICS specific. It is my opinion that for SL 3 and SL 4 we need a detailed asset or threat based risk analysis that potentially adds new requirements (and in my hands-on experience it does) to the requirements identified by the zone risk analysis.

So what would I like to see different?

  • IEC 62443 starts with an inventory, this seems for me the right first step.
  • Then IEC 62443 starts with a high level risk assessment, this I believe is wrong. Apart from the name (should have been initial risk assessment) I think there is no information available to determine likelihood, so it becomes primarily an impact driven assessment. Than the proper choice in my opinion would have been to conduct a criticality assessment, for criticality I don’t need likelihood. Apart from this, criticality in a plant has a time aspect because of upstream / down stream dependencies. This provides us with recovery time objectives (for the function), recovery point objectives, and maximum tolerable downtime when multiple functions are impacted. This part is missing in the IEC 62443 standard, while an important design parameter. Another reason is of course that when we do asset based or threat based risk and start comparing risk between multiple functions we need to take the function’s criticality into account.
  • Then IEC 62443 creates a zone and conduit diagram, no objections here. To determine risk we need static exposure, we need to know which assets go where. So good step.
  • Then IEC 62443 does a detailed risk assessment, also the right moment to do so. Hopefully also in IEC 62443 will see the importance of asset or threat based risk assessment. The standard doesn’t discuss this, it might as well be a control based risk assessment. But because there is no criticality assessment I concluded it must be a control based assessment not looking at risk at function level.

I hope I didn’t step on too many toes, only wanted to give a goat a great day. It is just my opinion as private person working as a consultant during business hours. Who on a daily base, during working hours, needs to secure systems, many of them part of national critical infrastructure.

Above is what I am missing, a criticality assessment, and a risk assessment that meets the SL3 / SL4 threat.

There is no relationship between my opinions and publications in this blog and the views of my employer in whatever capacity. this blog is written based on my personal opinion and knowledge build up over 42 years of work in this industry. Approximately half of the time working in engineering these automation systems, and half of the time implementing their networks and securing them.

Author: Sinclair Koelemij

OTcybersecurity web site

Power transformers and Aurora

Almost 2 weeks ago, I was inspired by the Wall Street Journal web site and a blog from Joe Weiss to make a blog on a power transformer that was seized by the US government while on its way to its destination. “Are Power transformers Hackable”, the conclusion was yes they can be tampered with but it is very unlikely they are in the WAPA case.

Since than there were other discussions / posts, interviews, all in my opinion very speculative and in some cases even wrong. However there was also an excellent analysis report from Sans that provided a good analysis on the topic.

The report shows step by step that there is little ( more accurate there is no) evidence provided by the blogs and news media that China would have tampered with the power transformer in an attempt to attack the US power grid at a later moment in time.

That was also my conclusion, but the report provides much a more thorough and convincing series of arguments to reach this conclusion.

Something I hadn’t noticed at the time, and was added by Joe Weiss in one of his blogs, is the link to the Aurora attack. I have always been very skeptical on the Aurora attack scenario, not that I think it is not feasible, but because I think it will be stopped in time and is hard to properly execute. But the proposition of an Aurora attack in combination with tampering the power transformer is an unthinkable scenario for me.

Let’s step back to my previous blog, but add some more technical detail using the following sketch I made:

Drawing 1 – A hypothetical power transformer (with on load tap changer) control diagram

The diagram shows in the left bottom corner the power transformer with an on load tap changer to compensate for the fluctuations in the net.
Fluctuations that are quite normal now the contribution of renewable power generation sources such as solar and wind energy is increasing. To compensate for these fluctuations an automated tap changer continuously adapts the number of windings in the transformer. So it is not unlikely that the WAPA transformer would have an automated On Load Tap Changer (OLTC).

During an energized condition, which is always the case in an automated situation, this requires a make before break mechanism to step from one tap position to the next. This makes it a very special switching mechanism with various mechanical restrictions with regard to changing position, one of them is that a step is limited to a step toward an adjacent position. Because there is always a moment that both adjacent taps are connected it is necessary to restrict the current, so we need to add impedance to limit the current.

This transition impedance is created in the form of a resistor or reactor and consist of one or more units that are bridging adjacent taps for the purpose of transferring load from one tap to the other without interruption or an appreciable change in the load current. At the same time, they are limiting the circulating current for the period when both taps are used.

See the figure on the right for a schematic view of an OLTC. There is a low voltage and a high voltage side on the transformer. The on-load-tap-changer is at the high voltage side, the side with the most windings. In the diagram the tap changer is drawn with 18 steps, which is a typical value though I have seen designs that allowed as much as 36 steps. A step for this type tap changer might be 1.25% of the nominal voltage. Because we have three phases, we need to have three tap changers. The steps for each of the three phases need to be made simultaneously. Because of the make-before-break principle, the tap can only move one step at the time. It needs to pass all positions on its way to its final destination. When automated on-load-tap-changers are used the operating position needs to be shown in the control room.

For this each position has a transducer (not shown in the drawing) that provides a signal to indicate where the tap is connected. There is a motor drive unit moving the tap upward or downward, but always step by step. So the maximum change per step is approximate 1.25%. If a step change is required, is determined by the voltage regulator (See drawing 1), the voltage regulator measures the voltage (using an instrument transformer) and compares this with an operator set reference level. Based on the difference between reference level and measured level the tap is moved upward (decreasing the number of windings) or downward (increasing the number of windings).

To prevent that there will be jitter, caused by moving the tap upward and immediately downward, the engineer sets a delay time between the steps. A typical value is between 15 – 30 seconds.

Also if there is an operator that wants to manually jump from tap position 5 to tap position 10 (Manual Command mode), the software in the voltage regulator still controls this step by step by issuing consecutive raise/lower tap commands and on the motor drive side this is mechanically enforced by the construction. On the voltage regulator unit itself, the operator can only press a raise and lower button also limited to a single step.

The commands can be given from the local voltage regulator unit or from the HMI station in the substation or remotely from the SCADA in a central control center. But important for my conclusions later on, is to remember it is step by step … tap position by tap position … no athletics allowed or possible.

Now lets discuss the Aurora principle. The Aurora attack scenario is based on creating a repetitive variable load on the generator. For example disconnecting the generator from the grid and quickly connecting it again. The disconnection would cause the generator to suddenly increase its rotation speed because there is no load anymore, connecting the generator again to the grid would cause a sudden decrease in rotation speed. Taking the enormous mass of a generator into account, these speed changes result in a high mechanical stress on the shaft and bearings which would ultimately result into damage requiring to replace the generator. Which takes a long time because also generators are build specifically for a plant.

When we go from full load to no load and back this is a huge swing in mechanical forces released on the generator. This also because of the weight of the generator, you can’t stop it that easy. Additionally behind the generator we have the turbine creates the rotation by the steam from the boilers. So it is a relative easy mechanical calculation to understand that damage will occur when this happens. But this is when the load swings from full load to no load.

Using a tap changer to create an Aurora type of scenario doesn’t work. First of all even if we could have a maximum jump from the lowest tap to the highest tap (which is not the case because the tap would normally be somewhere around the mid-position, and it is mechanically impossible) it is a swing of 20-25% in load.

The load variations from a single step are approximately 1.25%, and the next step is only made after the time delay, in the Aurora scenario a reverse step of 1.25%. This is by no means sufficient to cause the kind of mechanical stress and damage that occurs after a swing from full load to zero load.

Additionally the turbine generator combination is protected by a condition monitoring function that detects various types of vibrations including mechanical vibrations of the shaft and bearings.

Since the transformer caused load swing is so small that it will not cause immediate mechanical issues, the condition monitoring equipment will either alert or shutdown the turbine generator combination when detecting anomalous vibrations. The choice between alert or shutdown is a process engineering choice. But in both cases the impact is quite different from the Aurora effect caused by manipulating breakers.

Repetitive tap changes are not good for generators, therefore the time delay was introduced to prevent any additional wear from happening. The small load changes will cause vibrations in the generator but these vibrations are detected by the condition monitoring system and this function will prevent damage if the vibrations are above the limit.

Than the argument can be, but the voltage regulator could have been tampered with. True, but voltage regulators are not coming from the same company that supplied the transformer. Same argument for the motor drive unit. And you don’t have to seize a transformer to check the voltage regulator, anyone can hand carry it.

And of course as the SANS report noted, the placement of the transformer needs to be right behind the turbine generator section. WAPA is a power distribution company, not a power generation company so not a likely situation too.

I read another scenario on Internet, a scenario based on the use of the sensors for the attack, therefore I added them to diagram 1. All the sensors in the picture check the condition of the transformer. If they would not accurately represent the values, this might lead to undetected transformer issues and a transformer failure over time. But it would be failure at a random point in time, inconvenient and costly but those things happen also if all sensors function. But manipulating them as part of a cyber attack to cause damage, I don’t think this is possible. At most the sensors could create a false positive or false negative alarm. So I don’t see a feasible attack scenario here that works for conducting an orchestrated attack on the power grid.

In general if we want to attack substation functions, there are a few options in diagram 1. The attack can come over the network, the SCADA is frequently connected to the corporate network or even to the Internet. Famous example is the Ukraine attack on the power distribution. We can try penetrating the WAN, these are not always private connections so there are opportunities here. So far never seen an example of this. And we can attack the time source, time is a very important element in the control of a power system. Though time manipulation this has been demonstrated, I haven’t seen it used against a power installation. But all these scenarios are not related to the delivery of a Chinese transformer and a reason for intercepting it.

So based on these technical arguments I don’t think the transformer can be manipulated in a way that causes an Aurora effect. Too many barriers are preventing this scenario. Nor do I think that tampering the sensors would actively enable an attacker to cause damage in a way where the attacker determines the moment of the attack. The various build-in (and independent) safety mechanism would also isolate the transformer before physical damage occurs.

For me it is reasonable hat the US government initiates this type of inspections, if a supply chain attack from a foreign entity is considered a serious possibility, than white listing vendors and inspecting the deliverable is a requirement for the process. If this is a great development for global commerce, I doubt very much. But I am an OT security professional, no economist, so this is just an opinion.

Enough written for a Saturday evening, I think this ends my blogs on power transformers.

There is no relationship between my opinions and publications in this blog and the views of my employer in whatever capacity.

Sinclair Koelemij

Consequence with capital C

In my previous blog I quickly touched upon the subject Consequence and the difference between Consequence and impact and its relationship with functionality. This blog focuses specifically on what Consequence is for OT cyber security risk.

I mentioned that a cyber attack in an OT system consist in its core elements out of:

A threat actor carrying out a threat action by exploiting a vulnerability resulting in a Consequence that causes an impact in the production process.

In reality this is of course a simplification, the threat actor normally has to carry out multiple threat actions to make progress in achieving the objective of the attack, this is explained by the cyber kill chain concept of Lockheed Martin. And of course the defense team will normally not behave like a sitting duck and starts to implement countermeasures to shield the potential vulnerabilities in the automation system and would build barriers and safeguards to limit the severity of specific Consequences. Or where possible remove the potential Consequence all together. Apart from these preventive controls the defense team would establish situational awareness in an attempt to catch the threat actor team as early as possible in the kill chain.

Sometimes it looks like there are simple recipes for both the threat actors and defenders of an industrial control system (ICS):

  • The threat actor team uses the existing functionality for its attack (something we call hacking), the defense team will counter this by reducing functionality available to the attacker (hardening);
  • The threat actor team adds new functionality to the existing system (we call this malware), the defense team will white list all executable code (application white listing);
  • The threat actor team adds new functionality to the existing system using new components (such as in the supply chain attack), the defense team requests for white listing the supply chain (e.g. the widely discussed US presidential order);
  • Because a wise defense team doesn’t trust the perfectness of its countermeasures and respects the threat actor team’s ingenuity and persistence, the defense team will add some situational awareness to the defense by sniffing around in event logs and traffic streams attempting to capture the threat actors red-handed.

Unfortunately there is no such thing as perfectness in cyber security or something like zero security risk. New vulnerabilities pop-up every day, countermeasures aren’t perfect and can even become an instrument for the attack (E.g. the Flame attack in 2012, creating a man-in-the-middle between the Windows Updates System distributing security patches and the systems of a bank in the Gulf Region). New tactics, techniques and procedures (TTP) are continuously developed, and new attack scenarios designed, the threat landscape is continuously changing.

To become more pro-active the OT cyber security defense teams adopted risk as the driver, cyber security risk being equivalent to the formula Cyber Security Risk = Threat x Vulnerability x Consequence.

Threats and vulnerabilities are addressed by implementing the traditional countermeasures. A world of continuous change and research for vulnerabilities, the world of network security.

In this world Consequence is often the forgotten variable to manage, an element far less dynamic than the world of threats and vulnerabilities. But offering a more effective and reliable risk reduction than the Threat x Vulnerability part of the formula. So this time the blog is written to honor this essential element for OT cyber security risk, our heroine of the day – Consequence.

Frequent readers of my blog know that I write long intros and tend to follow them up sketching the historic context of my subject. Same recipe in this blog.

When the industry was confronted with the cyber threat, after more and more asset owners changed over from automation systems based on proprietary technology toward systems build on open technology, a gap in skills became apparent.

The service departments of the vendor organizations and the maintenance departments of the asset owners were not prepared for dealing with the new threat of cyber attacks. In the world of proprietary systems they were protected by the lack of knowledge of the outside world of the internal workings of these systems, the connectivity between systems was less, and the number of functions available was smaller. And perhaps also because in those days it was far more clear who the adversaries were than it is today.

As a consequence asset owners and vendors were looking for IT schooled engineers to expand their capabilities and IT service providers attempted to extend their business scope. IT engineers had grown their expertise since the mid-nineties, they benefited from a learning curve over time to improve their techniques in preventing hacking and preventing infection with malicious code.

So initially the focus in OT security was on network security, a focus on the hardening (attack surface reduction / increasing resilience) of the open platforms, and network equipment. However essential security settings in the functionality of the ICS, the applications running on these platforms, were not addressed or didn’t exist yet.

Most of the time the engineers were not even aware these settings existed. These security settings were set during the installation, sometimes as default settings, and were never considered again if there were no system changes. Additionally the security engineers with a pure IT background had never configured these systems, they were not familiar with the functionality in these systems. If the Microsoft and network platforms were secure the system was secure.

OT cyber security became organized around network security, I (my personal opinion, certainly not my employer’s 🙂 – for those mixing up the personal opinion of a technical security guy and the vision of the employer he works for. ) compare it with the hypothalamus of the brain, the basic functions sex and a steady hart rhythm are implemented, but the wonders of the cerebral cortex are not yet activated. The security risk aspects of the automation system and process equipment were ignored, too difficult and not important because so far never required. This changed after the first attack on cyber physical systems, the Stuxnet attack in 2010.

Network security focuses on the Threat x Vulnerability part of the risk formula, the Consequence part is always linked to the functional aspects of the system. Functional aspects are within the domain of the risk world.

Consequence requires us to look at an ICS as a set of functions, where the cyber attack causes a malicious functional deviation (the Consequence) which ultimately results into impact on the physical part of the system. See my previous blog for an overview picture of some impact criteria.

What makes OT security different from IT security, is this functional part. An IT security guy doesn’t look that much at functionality, IT security is primarily data driven. An OT security guy might have some focus on data (some data is actual confidential) but his main worry is the automation function. The sequence and timing of production activities. OT cyber security needs to consider the Consequence of this functional deviation, they need to think about barriers / safeguards, or what ever name is used to reduce the overall Consequence severity in order to lower risk.

Therefore Sarah’s statement in last week’s post “Don’t look at the system but look at the function” is so relevant when looking at risk. For analyzing OT cyber security risk we need to activate the cerebral cortex part of our OT security brain. So far the historical context of hero in this blog. Let’s discuss Consequence en the functions of ICS in more technical detail.

For me, from an OT security perspective, there are three loss possibilities:

  • Loss of required performance (LRP) – Defined as “The functions, do not meet operational / design intent while in service”. Examples are program logic has changed, ranges were modified, valve travel rates were modified, calibrations are off, etc.
  • Loss of Ability (LoA) – Defined as “The function stopped providing its intended operation” Examples are loss of view, loss of control, loss of ability to communicate, loss of functional safety, etc.
  • Loss of confidentiality (LoC) – Defined as “Information or data in the system was exposed that should have been kept confidential.” Examples are loss of intellectual property, loss of access credential confidentiality, loss of privacy data, loss of production data.

Each of these three categories have sub categories to further refine and categorize Consequence (16 in total). Consequence is linked to functions, but functions in an OT environment are generally not provided by a single component or even by a single system.

If we consider the process safety function discussed in the TRISIS blog, we see that at minimum this function depends on a field sensor function/asset, an actuator function/asset, a logic solver function/asset together called the safety integrity function (SIF). Additionally there is the HMI engineering function/asset, sometimes a separate HMI operations function / asset, and the channels between these assets.

Still it is a single system with different functions such as: safety integrity function (SIF), alerting function (SIF alerts), a data exchange function, an engineering function, maintenance functions, operation functions and some more functions at detailed level such as diagnostics and sequence of event reporting.

Each of these functions could be targeted by the threat actor as part of the plan, some are more likely than others. All these functions are very well documented, for risk we need to conduct what is called Consequence analysis determining failure modes. A proper understanding of which functional deviations are of interest for a threat actor includes not only an ability to recognize a possible Consequence but also distinguish how functions can fail. These failure modes are basically the 16 sub-categories of the three main categories LRP, LoA, LoC.

The threat actor team will consider what functional deviations are required for the attack and how to achieve this, the defense team should consider what is possible and how to prevent it. If the defense team of the Natanz uranium enrichment plant had conducted Consequence analysis, they would have recognized the potential for causing mechanical stress on the bearings of the centrifuge as the result of functional deviations caused by the variable frequency drive of the centrifuges. Using vibration monitoring would have recognized the change in vibration pattern caused by the small repetitive changes in rotation speed and would almost certainly have caused an earlier alert that something was wrong than the time it took now. The damage (Consequence severity / impact) would have been smaller.

If we jump back to the TRISIS attack we can say that the threat actor’s planned functional deviation (Consequence) could have been the Loss of Ability to execute the safety integrity function, so making the automation function vulnerable if a non-safe situation would occur.

Another scenario described in the TRISIS blog, is the Loss of Required Performance, where the logic function is altered in a way that could cause a flow surge when the process shutdown logic for the compressor would be triggered after having made the change to the logic.

A third Consequence discussed was the Loss of Confidentiality that occurred when the program logic was captured in preparation of the attack.

Every ICS has many functions, I extended the diagram in the PRM blog with some typical functions implemented in a new greenfield plant.

Some typical system functions in a modern plant

Quite a collection of automation functions, and this is just for perhaps a refinery or chemical plant. I leave it to the reader to find the acronyms on the Internet, there you can also value the many solutions and differences there are. The functions for the power grid, for a pipeline, for a pulp and paper mill, oil field, or offshore platform differ significantly. Today’s automation world is a little bit more diverse than SCADA or DCS. I hope the reader realizes that ICS has many functions, different packages, different vendors, many interactions and data exchange. And this is just the automation side of it, for security risk analysis we also need to include the security and system management functions, also these induce risk. Some institutes call this ICS SCADA, I need to stay friendly but really a bad term. The BPCS (Basic Process Control System to give one acronym away for free) can be a DCS or a SCADA, but an ICS is a whole lot more today than DCS or SCADA in the last decade functionality exploded and I guess the promise of IIoT will even grow the number of functions.

Each of the functions in the diagram has a fixed set of for the threat actor interesting deviations (Consequences), these are combined with the threat actions that can cause the deviation (the cyber security hazard), these can be combined with the countermeasures and safeguards / barriers that protect the vulnerabilities and limit the Consequence severity to be able to estimate cyber security risk. resulting in a repository of bow-ties for the various functions.

A cyber security hazop (risk assessment) is not the process of a workshop where a risk analyst threat models the ICS together with the asset owner, that would become a very superficial risk analysis with little value considering the many cyber security hazards there are. Costly in time and scarce in result, a cyber security hazop is the confrontation between a repository of cyber security hazards and the installed ICS functionality, countermeasures, safeguards and barriers.

Consequence plays a key role, because Consequence severity is asset owner specific and depends on the criticality analysis of the systems / functions. Consequence severity can never be higher than the criticality of the system that creates the function. All of this is a process, called Consequence analysis, a process with a series of rules and structured checks that allow estimating cyber security risk (I am not discussing the likelihood part in this blog) and link Consequence to mission impact.

Therefore Consequence with capital C.

Maybe a bit much for a mid-week blog, but I have seen far too many risk assessments where Consequence was not even considered, or expressed in for mitigation meaningless terms as Loss of View and Loss of Control.

Since in automation Consequence is such an essential element we can’t ignore it.

Understanding the hazards, is attempting to understand the devious mind of the threat actor team. Only then we can hope to become pro-active.

There is no relationship between my opinions and publications in this blog and the views of my employer in whatever capacity.

Sinclair Koelemij