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What should users have in the device labeling to allow them to manage risks associated with software components?
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known vulnerabilities, configuration specifications, and other relevant security and risk management considerations
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What does SBOM stand for?
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SBOM
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What does source code backup involve?
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storing (and updating as needed) a separate copy of the source code
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What does an SBOM help facilitate?
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risk management processes
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What should be maintained as part of the device’s configuration management?
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SBOM or an equivalent capability
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What should you demonstrate if you are considering data reuse in the evaluation of your CADe device?
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that reusing any part of the test data does not introduce unreasonable bias into estimates of CADe performance and that test data integrity is maintained
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What are also referred to as “baseline attributes”?
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minimum elements
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What is the acronym for the National Telecommunications and Information Administration (NTIA) Multistakeholder Process on Software Component Transparency document?
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“Framing Software Component Transparency: Establishing a Common Software Bill of Materials (SBOM)”
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What is the name of the process that is used to improve software transparency?
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Information Administration’s multi-stakeholder process
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What is the software level of support provided through monitoring and maintenance from the software component manufacturer?
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software is actively maintained, no longer maintained, abandoned
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What should a manufacturer provide a justification for if the information cannot be included in the premarket submission?
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why the information cannot be included in the premarket submission
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What should device manufacturers provide in premarket submissions for components with known vulnerabilities?
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• A safety and security risk assessment of each known vulnerability (including device and system impacts); and • Details of applicable safety and security risk controls to address the vulnerability.
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What may have security implications and may also be considered vulnerabilities?
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Some anomalies discovered during development or testing
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What is the CWE?
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Common Weakness Enumeration
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What might the impact of the anomaly occur sporadically and be assessed to be acceptable from a software risk perspective?
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the impact of the anomaly
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What may continue to be identified throughout the device’s TPLC?
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Cybersecurity risks
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What is a “firewall”?
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to ensure those outside of the regulatory assessment team (e.g., algorithm developers) are completely insulated from knowledge of the radiology images and radiological data
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What can be used to quickly identify vulnerability impacts once a device is released?
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threat modeling
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What is the most common type of device that is not marketed but still in use?
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marketed devices
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What is needed based on postmarket vulnerabilities and general postmarket cybersecurity risk management?
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a new premarket submission
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What is important to ensure that device design appropriately addresses cybersecurity in compliance with the QS regulation?
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device design
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What is the length from vulne?
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Duration
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What should be provided over multiple time frames based on volume or in response to process or procedure changes to increase efficiencies of these measures over time?
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Averages
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What are risks introduced by device reliance on hospital networks, cloud infrastructure, or “other functions” defined in?
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those introduced by device reliance on hospital networks, cloud infrastructure, or “other functions”
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What does A security architecture definition process55 demonstrate?
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that the risks considered during the risk management process are adequately controlled
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What must a manufacturer establish and maintain under 21 CFR 820.30(c)?
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procedures to ensure that the design requirements relating to a device are appropriate and address the intended use of the device
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What does 21 CFR 820.30(d) state?
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design output procedures shall contain or make reference to acceptance criteria and shall ensure that those design outputs that are essential for the proper functioning of the device are identified.
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What is the purpose of a "firewall"?
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to insulate personnel responsible for proposing interim protocol changes from knowledge of interim comparative results
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What does NIST 800-160 vol. 1 rev. 1 state?
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Engineering Trustworthy Secure Systems
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What does the process also ascertain?
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vulnerability and susceptibility to disruptions, hazards, and threats
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What does the details of the security context and trust-boundaries enable?
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the identification of the parts of the medical device system in or through which incidents might occur
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What should manufacturers analyze to understand the full environment and context in which the device is expected to operate?
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the entire system
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What do FDA recommend that architecture information take?
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the form of “views,” and that these views be provided during premarket submissions to demonstrate safety and effectiveness
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What is FDA's recommendation for security controls?
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ways to document the resultant security architecture
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What must a manufacturer establish and maintain under 21 CFR 820.30(c)?
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procedures
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What is the acronym for the Building Code for Medical Device Software Security?
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IEC 81001-5-1
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What allows manufacturers to achieve the security objectives outlined in Section IV?
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Security controls
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What is the name of the category where security controls should be applied across the system architecture?
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Appendix 1
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What do you do when you contemplate the reuse of any test data?
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randomly select the data from a larger database that grows over time
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What should manufacturers submit in their premarket submissions to demonstrate that the security controls for the categories above, and further detailed in the recommendations in Appendix 1 have (1) been implemented, and (2) been tested in order to validate that they were effectively implemented.?
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What is the FDA's nonbinding recommendation for cybersecurity risk management throughout the device lifecycle?
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22 Contains Nonbinding Recommendations
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What can these views be used to help identify?
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impacted fun
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What can architecture views contribute to the demonstration of safety and effectiveness in premarket submissions?
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demonstration of safety and effectiveness
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What is the most effective way to provide threat modeling information to FDA?
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These views can therefore be effective way to provide threat modeling information to FDA and will naturally scale the documentation provided with the cybersecurity risk of the device.
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What should security context, domains, boundaries, critical user roles, and external interfaces of the medical device system define?
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security context
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What should exist throughout the cybersecurity risk management documentation?
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traceability
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What should manufacturers provide if one of the views listed above is not appropriate?
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an explanation for why the view is not included in the premarket submission
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What should a global system view describe?
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the overall medical device system
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What do you maintain to track each time the data is accessed?
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a data access log
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What is the possibility of a multi-patient Harm view?
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When devices are capable of connecting (wired or wirelessly) to another medical or non-medical product, to a network, or to the Internet
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What can be hacked to perform a device function?
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a non-device function
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What can a multiple-device compromise have severe impacts for multiple patients?
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impact to the device itself and/or to healthcare facility operations
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What is the view that should include the information recommended in Appendix 2?
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multi-patient harm view
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What should describe the end-to-end process that permits software updates and patches to be provided (i.e., deployed) to the device?
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updateability and patchability view
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What should the device design provide for?
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the protection of the end-to-end path and take into account any additional cybersecurity risk created or posed by those non-manufacturer-controlled technologies
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What should security use cases cover?
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various operational states of elements in the medical device system (e.g., power on, standby, transition states) and assess clinical functionality states of the medical device system
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What should each view include?
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detailed information as recommended in Appendix 2
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What are closely related disciplines?
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software development and cybersecurity
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What must a manufacturer establish and maintain procedures for verifying?
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device design
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What did you do to ensure that the new CADe algorithm was fixed in advance?
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ensuring that you fixed the new CADe algorithm in advance (i.e., before application to the test set); and (3) providing information concerning the extent to which you used the same test set or a subset thereof for testing other CADe algorithms or designs, including results reported to the Agency as well as non-reported results
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What type of testing should be submitted in the premarket submission?
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Security testing
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What should Manufacturers provide evidence of in their submission?
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their boundary analysis and rationale for their boundary assumptions
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What should manufacturers ensure the adequacy of?
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cybersecurity risk control
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What is the name of the tool used for?
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Vulnerability chaining
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What may be necessary to use third parties to ensure an appropriate level of independence between the two groups?
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vulnerabilities or other issues revealed during testing are ap
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What should manufacturers provide for all testing?
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their assessment of any findings including rationales for not implementing or deferring any findings to future releases
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What may be small or unlikely in relation to a medical device system?
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impact on medical device system functionality
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What should the plans include the vulnerabilities that future software releases will address?
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anticipated timelines for release
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What can ensure that security issues are addressed prior to impacting release timelines?
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Security testing early in development
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What is the key to ensuring safe and effective use and integration of devices and systems?
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Cybersecurity Transparency
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What is the chance that you evaluate a new CADe algorithm in a subsequent study using the same test data set that you used for a prior CADe algorithm?
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substantially reduce the chance
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What is a medical device deemed misbranded if its labeling is false or misleading in any particular?
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section 502(a)(1)
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What does FDA believe informing users of security information through labeling may be an important part of?
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design and development activities
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What should be detailed and considered for inclusion as tasks during usability testing?
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Any risks transferred to the user
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What is the name of the part of the Guidance that FDA issued on applying Human Factors and Usability Engineering to Medical Devices?
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Part 4-1: Product security development life-cycle requirements
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What is the exact location in the labeling for specific types of information?
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operator’s manual, security implementation guide
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What should be understandable to the intended audience?
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Instructions to manage cybersecurity risks
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What is the name of the product specifications that are related to recommended cybersecurity controls?
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device instructions and product specifications
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What should users be able to do with ports in their device?
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indicate whether the ports are incoming, outgoing, or both, along with approved destination end-points
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What should users do upon detection of a cybersecurity vulnerability or incident?
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respond
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What should the SBOM be in?
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machine-readable format
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What are the subsets of test sets that you have never been used before?
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the portion of the test set that you have never been used before
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What could be security event types?
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configuration changes
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What is the name of the feature that disabling ports/communications?
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backup mode
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What is the name of the end point protections that Secure configurations may include?
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allow lists, deny lists
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What is the name of the security event management software?
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Security Information and Event Management
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What is the manufacturer unable to provide at the end of support?
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security patches or software updates
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What is the Manufacturer Disclosure Statement for Medical Device Security outlined in?
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MDS266
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What is the 21 CFR 820.100?
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vulnerabilities that are identified after releasing the device
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What is available at https://www.nema.org/standards/view/manufacturer-disclosure-statement-for-medical-device-security 67 Available at https://healthsectorcouncil.org/thejoint-security-plan/ 30 Contains Nonbinding Recommendations addressed how to maintain the safety and effectiveness of the device after marketing authorization is achieved.?
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What is Patching capability?
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rate at which update can be delivered to devices
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What is the name of the nonbinding recommendation appendix?
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Security Control Categories and Associated Recommendations
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What does the reference standard indicate for patient data?
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whether the disease/condition/abnormality is present
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What is Authentication of information69?
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where the device and the system in which it operates are able to prove that information originated at a known and trusted source, and that the information has not been altered in transit between the original source and the point at which authenticity is verified
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What is the purpose of authentication?
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to prove the identity of an endpoint (whether hardware and/or software) from which it is sending and/or receiving information, or authorized user/operator at that endpoint
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What should devices prove to prove the authenticity of information that they generate?
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the authenticity of information that they generate
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What is the state of currently running software?
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state
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What is the definition of information?
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software/firmware itself, as well as input and output data
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What is the main reason for weak schemes?
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an unauthorized user can easily emulate the correct behavior and appear to be authorized
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What is the purpose of cryptographic keys?
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the integrity of the devices that hold or otherwise leverage those keys
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