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CYBERSECURITY IN
MEDICAL DEVICES
PRESENTED BY : SHEERSHA PRAMANIK
(NIPERA1719MD10)
COURSE INSTRUCTOR : DR. MUKTY SINHA
FLOW OF PRESENTATION
 INTRODUCTION
 TECHNOGICAL ADVANCEMENT IN MEDICAL DEVICES
 REASON FOR FOCUSING CYBERSECURITY
 ROLE OF FDA
 MED ISAO
 PRINCIPLES OF MEDICAL DEVICES SECURITY
 TYPES OF ATTACKS
 EXAMPLES OF SOME NETWORKED DEVICES
 EXAMPLES OF SOME ATTACKS
 PREVENTION STEPS
 STANDARDS
INTRODUCTION
 What is a medical device?
 “An instrument, apparatus, implement, machine,contrivance, implant … which is
intended for use in the diagnosis of disease or other conditions, or in the cure,
mitigation, treatment, or prevention of disease”– Food, Drug and Cosmetic Act
 What is Cybersecurity?
 Unauthorized access to data (either resident in or exchanged between
systems)
 Attacks on system resources (i.e. computer hardware, operating system
and application software) by malicious computer programs.
TECHNOGICAL ADVANCEMENT IN
MEDICAL DEVICES
BEFORE AFTER
Data obtained from devices
are stored on paper or locally
Data obtained from devices are stored
in the cloud
Devices are physical products Devices include software and
even databases of health Information
Devices are connected to
patients physically
Devices are connected
wirelessly to patients and other devices
Physical access is needed to
view health data
Health data can be accessed
anywhere on earth
Care is hand-administered at a
health care location
Care is available to patients in
the palm of their hand through apps
WHY CYBERSECURITY IS NOW BEING
FOCUSED MORE ?
THE DRIVER THE IMPACT
TOTAL BUSINESS CONNECTED
A business’ payroll, sales and
products might all be connected
to the Internet—and vulnerable
SYSTEMIC RISKS
A new vulnerability could leave a
once-secure business open to
major problems immediately
RISK TO PHYSICAL ASSETS
Internet-connected products are
vulnerable to physical problems,
including failure
FDA’s GUIDANCE
 Cybersecurity for Networked Medical Devices containing
OTS Software - Jan 14, 2005
 Content of Premarket Submissions for Management of Cybersecurity in Medical
Devices - Oct 2, 2014
 Post Market Management of Cybersecurity in Medical Devices - Jan 22, 2016
PURCHASING
DESIGN
POST MARKET
MONITORING
PRE MARKET SUBMISSIONS
 This guidance has been developed by the FDA to assist industry by identifying issues related to
cybersecurity that manufacturers should consider in the design and development of their medical
devices as well as in preparing premarket submissions for those devices.
 The guidance document consists of :
Premarket Notification (510(k)) including Traditional, Special, and Abbreviated
1.· De novo submissions
·2. Premarket Approval Applications (PMA)
·3. Product Development Protocols (PDP) ·
4. Humanitarian Device Exemption (HDE) submissions.
CONTD.
 Manufacturers should address cybersecurity during the design and development of the medical
device.
 Manufacturers should establish design inputs for their device related to cybersecurity, and
establish a cybersecurity vulnerability and management approach as part of the software
validation and risk analysis that is required by 21 CFR 820.30(g).
 The approach should appropriately address the following elements:
1. Identification of assets, threats, and vulnerabilities;
2. Assessment of the impact of threats and vulnerabilities on device functionality .
3. Assessment of the likelihood of a threat and of a vulnerability being exploited;
4. Determination of risk levels and suitable mitigation strategies.
5. Assessment of residual risk and risk acceptance criteria.
MAIN TAKEAWAYS FROM FDA’S
GUIDANCE
POST MARKET GUIDANCE
 Manufacturers are responsible for remaining vigilant about identifying risks and hazards associated
with their medical devices, including risks related to cybersecurity.
 Monitoring cybersecurity information sources for identification and detection of cybersecurity
vulnerabilities and risk;
 Understanding, assessing and detecting presence and impact of a vulnerability;
 Establishing and communicating processes for vulnerability intake and handling;
 Clearly defining essential clinical performance to develop mitigations that protect, respond and
recover from the cybersecurity risk;
 Adopting a coordinated vulnerability disclosure policy and practice; and
 Deploying mitigations that address cybersecurity risk early and prior to exploitation.
CONTD.
 Manufacturers should report these vulnerabilities to the FDA according to 21 CFR part 806,
unless reported under 21 CFR parts 803 or 1004.
 However, the FDA does not intend to enforce reporting requirements under 21 CFR part 806
if all of the following circumstances are met:
 There are no known serious adverse events or deaths associated with the vulnerability,
 Within 30 days of learning of the vulnerability, the manufacturer identifies and implements
device changes and/or compensating controls to bring the residual risk to an acceptable level
and notifies users, and
 The manufacturer is a participating member of an ISAO, such as NH-ISAC(National Health
Information Sharing and Analysis Center).
*(ISAO : Information Sharing and Analysis Organisation)
MED ISAO
 A medical device “Information Sharing and Analysis Organization”.
 Provides ongoing cybersecurity information tailored to the medical device industry.
 Alerts members of potential threats
 Geared towards smaller manufacturers and startups.
 ISAOs protect privacy of individuals and preserve business confidentiality, safeguarding
information being shared.
 FDA considers participation in an ISAO a critical component of medical device
manufacturers’ comprehensive proactive approach to management of postmarket
cybersecurity threats.
 To improve the Nation’s cybersecurity posture by identifying standards and guidelines
for robust and effective information sharing and analysis related to cybersecurity
risks, incidents, and best practices.
ADVANTAGE OF ISAO MEMBERSHIP
 From the guidance:
 “Participants in an ISAO can request that their information be treated as Protected
Critical Infrastructure Information. Such information is shielded from any release
otherwise required by the Freedom of Information Act or State Sunshine Laws and
is exempt from regulatory use and civil litigation if the information satisfies the
requirements of the Critical Infrastructure Information Act of 2002”
PRINCIPLES FOR MEDICAL DEVICE
SECURITY
Security risk management plan
Security risk analysis
Security risk evaluation
Security risk control
Evaluation of overall residual
security risk acceptability
Security risk management report
Production and post-production
information
From TIR57: Principles for medical device security – Risk management © 2016 by the Association for the Advancement of Medical Instrumentation
TYPES OF ATTACKS
 Carrier Based Methods
 Man in the middle (MiTM) attacks which can steal data Hijack wireless transmission.
 Endpoints based methods . Inject code to tamper with web application or web
services
 Stealing user sensitive phone contents using Malwares
 Wireless interfaces based methods
 Stealing data when its in-transit using wireless channel . Exploit access and
authentication access
 An adversary steals sensitive data by reading SD Card based stored content
ACCIDENTS
 1. PACEMAKER :
 Small device placed in the chest or abdomen to help control abnormal heart
rhythms.
 Uses electrical pulses to prompt the heart to beat at a normal rate
 Have wireless transmitters to allow them to be programmed without an invasive
procedure
PACEMAKERS- THE DANGER
 Due to the convenience of wireless transmitters, security vulnerabilities of remote
attacks on the body are now possible
 Allows for hacking through not only a laptop, but also Malware installed on a
hospital or company computer that may briefly interact with an implant
 Could infect, reprogram, or command the device to perform a more lethal Function
 BARNABY JACK - Discovered a way to hack into a pacemaker via its wireless
transmitter and make the device send an 830-volt shock through a person’s body
 Can be done with a laptop from 30 to 50 feet away
INSULIN PUMPS
 Device used for administration of insulin in the treatment of diabetes
• Many insulin pumps are now wireless
• Allows the patient to check on the pump’s status and activity
• Allows for control of the dosage administered
INSULIN PUMPS – THE DANGER
 Wireless transmitters once again can cause problems, and cause the pump to deliver a deadly
dose of the hormone
 Currently there are patents for insulin pumps that can hook up to WiFi and be controlled via a
web browser
 Huge potential for exploits, especially since exploits to compromise web interfaces are
developed daily
Manufacturer Disclosure Statement
for Medical Device Security (MDS2) v2
 Developed by HIMSS (Healthcare Information and Management Systems Society)
and the National Electrical Manufacturers Association (NEMA)
 Since 2013 Medical device manufacturers have to disclose the cybersecurity
features of medical devices they sell to healthcare providers.
 A hospital risk assessment tool to assess the vulnerabilities and risks of the
medical devices.
 Allows easy comparison of security features across different devices and different
manufacturers
WHAT TO DO TO SAVE THE DEVICE?
• Product design must protect the information& the device against any threats
posed by external circumstances or by other connected devices.
Protect information and maintain device
integrity
• Product design must be equipped with handling patient sensitive information
to meet both HIPAA and FDA regulations.Imbed data privacy management
• Product design must enable identification and management of risk through the
product development life cycleEnable risk identification and mitigation
• Product design must incorporate safety features that meet the regulatory
requirements such as alarm systems to protect users and patients from
unanticipated adverse situation
Incorporate product safety
Applicable standards, technical specifications
and reports
 PAS 277:2015, Health and wellness apps – Quality criteria across the life cycle – Code of practice
 EN ISO 13485:2016, Medical devices – Quality management systems – Requirements for regulatory purposes
 EN ISO 14971:2012, Medical devices. Application of risk management to medical devices
 PD ISO/TR 24971:2013, Medical devices. Guidance on the application of ISO 14971
 EN IEC 62304:2006, Medical device software – Software life cycle processes
 EN ISO IEC 62366-1:2015, Medical devices – Part 1: Application of usability engineering to medical devices
 IEC ISA 62443 series, Industrial communication networks – Network and system security
 ISO IEC 27005:2011, Information technology – Security techniques – Information security risk management
 ISO IEC 27032:2012, Information technology – Security techniques
 ISO IEC 80001 series, Application of risk management for IT-networks incorporating medical devices
 EN IEC TR 80002-1:2009, Medical device software – Part 1: Guidance on the application of ISO 14971 to medical device software
 ISO DTR 80002-2, Medical device software – Part 2: Validation of software for medical device quality systems
 IEC TR 80002-3:2014, Medical device software – Part 3: Process reference model of medical device software life cycle processes (IEC
62304)
 EN IEC TR 80001-2-8:2016, Application of risk management for IT-networks incorporating medical devices – Part 2-8: Application
guidance – Guidance on standards for establishing the security capabilities identified in IEC 80001-2-2
 IEC 82304-1:2016, Health software – Part 1: General requirements for product
REFERENCES
 www.fda.gov.in
Cybersecurity in Medical Devices

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Cybersecurity in Medical Devices

  • 1. CYBERSECURITY IN MEDICAL DEVICES PRESENTED BY : SHEERSHA PRAMANIK (NIPERA1719MD10) COURSE INSTRUCTOR : DR. MUKTY SINHA
  • 2. FLOW OF PRESENTATION  INTRODUCTION  TECHNOGICAL ADVANCEMENT IN MEDICAL DEVICES  REASON FOR FOCUSING CYBERSECURITY  ROLE OF FDA  MED ISAO  PRINCIPLES OF MEDICAL DEVICES SECURITY  TYPES OF ATTACKS  EXAMPLES OF SOME NETWORKED DEVICES  EXAMPLES OF SOME ATTACKS  PREVENTION STEPS  STANDARDS
  • 3. INTRODUCTION  What is a medical device?  “An instrument, apparatus, implement, machine,contrivance, implant … which is intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease”– Food, Drug and Cosmetic Act  What is Cybersecurity?  Unauthorized access to data (either resident in or exchanged between systems)  Attacks on system resources (i.e. computer hardware, operating system and application software) by malicious computer programs.
  • 4. TECHNOGICAL ADVANCEMENT IN MEDICAL DEVICES BEFORE AFTER Data obtained from devices are stored on paper or locally Data obtained from devices are stored in the cloud Devices are physical products Devices include software and even databases of health Information Devices are connected to patients physically Devices are connected wirelessly to patients and other devices Physical access is needed to view health data Health data can be accessed anywhere on earth Care is hand-administered at a health care location Care is available to patients in the palm of their hand through apps
  • 5. WHY CYBERSECURITY IS NOW BEING FOCUSED MORE ? THE DRIVER THE IMPACT TOTAL BUSINESS CONNECTED A business’ payroll, sales and products might all be connected to the Internet—and vulnerable SYSTEMIC RISKS A new vulnerability could leave a once-secure business open to major problems immediately RISK TO PHYSICAL ASSETS Internet-connected products are vulnerable to physical problems, including failure
  • 6. FDA’s GUIDANCE  Cybersecurity for Networked Medical Devices containing OTS Software - Jan 14, 2005  Content of Premarket Submissions for Management of Cybersecurity in Medical Devices - Oct 2, 2014  Post Market Management of Cybersecurity in Medical Devices - Jan 22, 2016 PURCHASING DESIGN POST MARKET MONITORING
  • 7. PRE MARKET SUBMISSIONS  This guidance has been developed by the FDA to assist industry by identifying issues related to cybersecurity that manufacturers should consider in the design and development of their medical devices as well as in preparing premarket submissions for those devices.  The guidance document consists of : Premarket Notification (510(k)) including Traditional, Special, and Abbreviated 1.· De novo submissions ·2. Premarket Approval Applications (PMA) ·3. Product Development Protocols (PDP) · 4. Humanitarian Device Exemption (HDE) submissions.
  • 8. CONTD.  Manufacturers should address cybersecurity during the design and development of the medical device.  Manufacturers should establish design inputs for their device related to cybersecurity, and establish a cybersecurity vulnerability and management approach as part of the software validation and risk analysis that is required by 21 CFR 820.30(g).  The approach should appropriately address the following elements: 1. Identification of assets, threats, and vulnerabilities; 2. Assessment of the impact of threats and vulnerabilities on device functionality . 3. Assessment of the likelihood of a threat and of a vulnerability being exploited; 4. Determination of risk levels and suitable mitigation strategies. 5. Assessment of residual risk and risk acceptance criteria.
  • 9. MAIN TAKEAWAYS FROM FDA’S GUIDANCE
  • 10. POST MARKET GUIDANCE  Manufacturers are responsible for remaining vigilant about identifying risks and hazards associated with their medical devices, including risks related to cybersecurity.  Monitoring cybersecurity information sources for identification and detection of cybersecurity vulnerabilities and risk;  Understanding, assessing and detecting presence and impact of a vulnerability;  Establishing and communicating processes for vulnerability intake and handling;  Clearly defining essential clinical performance to develop mitigations that protect, respond and recover from the cybersecurity risk;  Adopting a coordinated vulnerability disclosure policy and practice; and  Deploying mitigations that address cybersecurity risk early and prior to exploitation.
  • 11. CONTD.  Manufacturers should report these vulnerabilities to the FDA according to 21 CFR part 806, unless reported under 21 CFR parts 803 or 1004.  However, the FDA does not intend to enforce reporting requirements under 21 CFR part 806 if all of the following circumstances are met:  There are no known serious adverse events or deaths associated with the vulnerability,  Within 30 days of learning of the vulnerability, the manufacturer identifies and implements device changes and/or compensating controls to bring the residual risk to an acceptable level and notifies users, and  The manufacturer is a participating member of an ISAO, such as NH-ISAC(National Health Information Sharing and Analysis Center). *(ISAO : Information Sharing and Analysis Organisation)
  • 12. MED ISAO  A medical device “Information Sharing and Analysis Organization”.  Provides ongoing cybersecurity information tailored to the medical device industry.  Alerts members of potential threats  Geared towards smaller manufacturers and startups.  ISAOs protect privacy of individuals and preserve business confidentiality, safeguarding information being shared.  FDA considers participation in an ISAO a critical component of medical device manufacturers’ comprehensive proactive approach to management of postmarket cybersecurity threats.  To improve the Nation’s cybersecurity posture by identifying standards and guidelines for robust and effective information sharing and analysis related to cybersecurity risks, incidents, and best practices.
  • 13. ADVANTAGE OF ISAO MEMBERSHIP  From the guidance:  “Participants in an ISAO can request that their information be treated as Protected Critical Infrastructure Information. Such information is shielded from any release otherwise required by the Freedom of Information Act or State Sunshine Laws and is exempt from regulatory use and civil litigation if the information satisfies the requirements of the Critical Infrastructure Information Act of 2002”
  • 14. PRINCIPLES FOR MEDICAL DEVICE SECURITY Security risk management plan Security risk analysis Security risk evaluation Security risk control Evaluation of overall residual security risk acceptability Security risk management report Production and post-production information From TIR57: Principles for medical device security – Risk management © 2016 by the Association for the Advancement of Medical Instrumentation
  • 15. TYPES OF ATTACKS  Carrier Based Methods  Man in the middle (MiTM) attacks which can steal data Hijack wireless transmission.  Endpoints based methods . Inject code to tamper with web application or web services  Stealing user sensitive phone contents using Malwares  Wireless interfaces based methods  Stealing data when its in-transit using wireless channel . Exploit access and authentication access  An adversary steals sensitive data by reading SD Card based stored content
  • 16.
  • 17. ACCIDENTS  1. PACEMAKER :  Small device placed in the chest or abdomen to help control abnormal heart rhythms.  Uses electrical pulses to prompt the heart to beat at a normal rate  Have wireless transmitters to allow them to be programmed without an invasive procedure
  • 18. PACEMAKERS- THE DANGER  Due to the convenience of wireless transmitters, security vulnerabilities of remote attacks on the body are now possible  Allows for hacking through not only a laptop, but also Malware installed on a hospital or company computer that may briefly interact with an implant  Could infect, reprogram, or command the device to perform a more lethal Function  BARNABY JACK - Discovered a way to hack into a pacemaker via its wireless transmitter and make the device send an 830-volt shock through a person’s body  Can be done with a laptop from 30 to 50 feet away
  • 19. INSULIN PUMPS  Device used for administration of insulin in the treatment of diabetes • Many insulin pumps are now wireless • Allows the patient to check on the pump’s status and activity • Allows for control of the dosage administered INSULIN PUMPS – THE DANGER  Wireless transmitters once again can cause problems, and cause the pump to deliver a deadly dose of the hormone  Currently there are patents for insulin pumps that can hook up to WiFi and be controlled via a web browser  Huge potential for exploits, especially since exploits to compromise web interfaces are developed daily
  • 20. Manufacturer Disclosure Statement for Medical Device Security (MDS2) v2  Developed by HIMSS (Healthcare Information and Management Systems Society) and the National Electrical Manufacturers Association (NEMA)  Since 2013 Medical device manufacturers have to disclose the cybersecurity features of medical devices they sell to healthcare providers.  A hospital risk assessment tool to assess the vulnerabilities and risks of the medical devices.  Allows easy comparison of security features across different devices and different manufacturers
  • 21.
  • 22. WHAT TO DO TO SAVE THE DEVICE? • Product design must protect the information& the device against any threats posed by external circumstances or by other connected devices. Protect information and maintain device integrity • Product design must be equipped with handling patient sensitive information to meet both HIPAA and FDA regulations.Imbed data privacy management • Product design must enable identification and management of risk through the product development life cycleEnable risk identification and mitigation • Product design must incorporate safety features that meet the regulatory requirements such as alarm systems to protect users and patients from unanticipated adverse situation Incorporate product safety
  • 23. Applicable standards, technical specifications and reports  PAS 277:2015, Health and wellness apps – Quality criteria across the life cycle – Code of practice  EN ISO 13485:2016, Medical devices – Quality management systems – Requirements for regulatory purposes  EN ISO 14971:2012, Medical devices. Application of risk management to medical devices  PD ISO/TR 24971:2013, Medical devices. Guidance on the application of ISO 14971  EN IEC 62304:2006, Medical device software – Software life cycle processes  EN ISO IEC 62366-1:2015, Medical devices – Part 1: Application of usability engineering to medical devices  IEC ISA 62443 series, Industrial communication networks – Network and system security  ISO IEC 27005:2011, Information technology – Security techniques – Information security risk management  ISO IEC 27032:2012, Information technology – Security techniques  ISO IEC 80001 series, Application of risk management for IT-networks incorporating medical devices  EN IEC TR 80002-1:2009, Medical device software – Part 1: Guidance on the application of ISO 14971 to medical device software  ISO DTR 80002-2, Medical device software – Part 2: Validation of software for medical device quality systems  IEC TR 80002-3:2014, Medical device software – Part 3: Process reference model of medical device software life cycle processes (IEC 62304)  EN IEC TR 80001-2-8:2016, Application of risk management for IT-networks incorporating medical devices – Part 2-8: Application guidance – Guidance on standards for establishing the security capabilities identified in IEC 80001-2-2  IEC 82304-1:2016, Health software – Part 1: General requirements for product