It’s no secret that cyberattacks against critical infrastructure are increasing. The recent attacks against water treatment plants, pipelines, vital hospital systems and food processing facilities have all made recent headlines and demonstrate the vulnerability of all types of critical infrastructure providers. The attacks have caused chaos, value chain disruption and crippling fuel shortages, and we must not ignore the potential for more physical impact that could come to the point of costing human lives.

Recognizing the disruptive and destructive nature of these attacks, the United States Federal Government recently released a new DHS/TSA Security Directive, “Security Directive Pipeline-2021-01, Enhancing Pipeline Cybersecurity” with an effective date of May 28, 2021 to May 28, 2022. The White House has also warned critical infrastructure companies to step up their cybersecurity programs.

Change is Coming for Pipeline Owner and Operators

The security directive lays out a broad set of requirements for owners/operators, with a focus on three critical actions:

• Requires TSA-specified owner/operator to report cybersecurity incidents to the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA).
• Requires owner/operator to designate a cybersecurity coordinator who is required to be available to the TSA and CISA 24/7 to coordinate cybersecurity practices and address any incidents that arise.
• Requires owner/operator to review their current activities against TSA’s recommendations for pipeline cybersecurity to assess cyber risks, identify any gaps, develop remediation measures, and report the results to the TSA and CISA.

Several key points that should be considered include:

• Each owner/operator should establish and implement a risk-based corporate security program to address and document the organization’s policies and procedures for managing security related threats, incidents and responses.
• Describe the policies and procedures employed to ensure effective communication is maintained on both a routine and emergency basis. The description should include, but not be limited to, types of equipment used, communication methods between personnel, facilities, off-site responders, and procedures for notification of government and law enforcement agencies.
• Conduct a Security Vulnerability Analysis (SVA) to identify potential security vulnerabilities, existing counter measures and their level of effectiveness in reducing identified vulnerabilities.
• Conduct periodic security drills or exercises, including announced or unannounced tests of security and incident plans. These can be conducted in conjunction with other required drills or exercises.

Complying with the Directive and Improving Security

While working towards becoming compliant with the requirements, you should also focus on the overall objective — maintaining a mature security program. Adversaries are emboldened by their success and are not easing up. Three key pillars that the directive calls out and should be staples for any security program are:

• Penetration testing
• Incident response
• Threat management

If your resources are strained, you have other high priority projects, or want outside expertise to streamline your programs, working with a partner can help you simplify the process.

You should also implement an IT/OT security Target Operating Model (TOM), which can help address all phases of the directive from strategy and assessment through implementation and sustainment. The model includes the following components:

Vision

• Assess the maturity of your current OT security operations and capabilities, which includes understanding where your most important assets exist, who has access to them and how they are being protected
• Map out possible gaps that would enable an attacker to compromise your most important assets
• Develop your OT security vision for the future. What is your ultimate objective?
• Develop a business-based description of your desired OT security program based on your objectives
• Describe the capabilities that are needed to achieve your desired OT security program

Strategy, Architecture, Roadmap

• Develop a strategy to implement the vision
• Define the enterprise OT security governance structure (people, technology, and process) and number of in-house resources needed to achieve your vision
• Identify gaps in resource coverage
• Define a third-party sourcing strategy to support the target OT security operating model and fill deficiency holes
• Build a roadmap for the OT security transformation program including which controls, processes and people are needed to achieve each goal
• Establish ownership and accountability for the OT security functions

Implementation and Sustainment

• Implement the program based on which assets need the most protection first
• Develop metrics and dashboards to track the program’s effectiveness
• Operationalize and run the program
• Sustain and improve the program by performing assessments on a quarterly basis or when new changes are made to the environment

If you need assistance building a program to fulfill the directive’s requirements while also maintaining a strong security posture through a meticulous program, our IBM Security experts can help.

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