I’ve just given it a glance and here are some things that I’ve noticed:
- Section on security in SDLC
- Incorporates some of the concepts in SP 800-39 about enterprise-wide risk
- Section on common controls
- The process has remained pretty much the same but now references all the other core documents
Where I see this revision’s weaknesses:
- Still possible to view the C&A process as happening at the end of the SDLC as a gateway activity. This is the path to failure–you have to start at the initiation of a project. In other words, I don’t think the SDLC thing is obvious enough for the constituency. C&A should be all about security in the SDLC, and I think we’ve done ourselves a disservice by trying to separate the two.
- Unity: Yes, we have all the pieces there, but the document doesn’t flow as a whole yet. BFD, I’ll get over it soon enough.
- It all goes back to metrics: If completed C&A is going to be one of the core metrics that you use (or OMB uses), then it should be THE core document with everything else being a stub of of it. We have a start, but I don’t think it’s as fleshed-out as it needs to be.
Side-note for NIST: C&A is the implementation of the System Security Engineering Process, some of that SSE has a place in 800-37.
The origingal announcement from NIST is this:
NIST, in cooperation with the Office of the Director of National Intelligence (ODNI), the Department of Defense (DOD), and the Committee on National Security Systems (CNSS), announces the completion of an interagency project to develop a common process to authorize federal information systems for operation. The initial public draft of NIST Special Publication 800-37, Revision 1, Guide for Security Authorization of Federal Information Systems: A Security Lifecycle Approach, is now available for a six-week public comment period. The publication contains the proposed new security authorization process for the federal government (currently commonly referred to as certification and accreditation, or C&A). The new process is consistent with the requirements of the Federal Information Security Management Act (FISMA) and the Office of Management and Budget (OMB) Circular A-130, Appendix III, promotes the concept of near real-time risk management based on continuous monitoring of federal information systems, and more closely couples information security requirements to the Federal Enterprise Architecture (FEA) and System Development Life Cycle (SDLC). The historic nature of the partnership among the Civil, Defense, and Intelligence Communities and the rapid convergence of information security standards and guidelines for the federal government will have a significant impact on the federal government’s ability to protect its information systems and networks. The convergence of security standards and guidelines is forging ahead with the development of a series of new CNSS policies and instructions that closely parallel the NIST security standards and guidelines developed in response to FISMA. The CNSS policies and instructions which address the specific areas of security categorization, security control specification, security control assessment, risk management, and security authorization, coupled with the current NIST publications will provide a more unified information security framework for the federal government and its contracting base. The unified approach to information security is brought together in part by the update to NIST Special Publication 800-37, Revision 1, which provides a common security authorization process and references the NIST and CNSS publications for the national security and non national security communities, respectively. The convergence activities mentioned above along with tighter integration of security requirements into the FEA and SDLC processes will promote more consistent and cost-effective information security and trusted information sharing across the federal government. Comments on the IPD of SP 800-37, Revision 1 should be provided by September 30, 2008 and forwarded to the Computer Security Division, Information Technology Laboratory at NIST or submitted via email to: email@example.com .