Until recently, developers and manufacturers of medical devices have not been required to consider security in their products. New guidance from the U.S. Food and Drug Administration (FDA) and expanded European Union requirements for personal data protection now make security design in medical devices a necessity. While IT network attacks get most of the press, it is important to remember that physical attacks, such as accessing a maintenance serial port, can be just as dangerous.
Medical Security in the News
Security experts have reported weaknesses in hospital and clinic networks for several years. Even though these networks contain extremely sensitive patient data and connect life critical equipment, they continue to be proven easy to infiltrate. While networking equipment, like routers, may be state of the art in terms of security, the medical equipment on the network often has little to no security protection. Breaching a device with malware can open a back door to allow remote hackers access to sensitive data across the network, and moreover, cause the device to operate in a dangerous manner.
Since 2015, there has been much regulatory activity on security that affects medical device design. In the EU, the recent adoption of the new General Device Protection Regulation, which applies to all devices, has strict requirements for the protection of personal data. Additional regulations are soon to be released specifically for medical and intravenous delivery devices.
For device designers, the more specific recommendations from FDA provide more useful guidance as to how to meet security requirements. FDA has issued formal guidance on both premarket submissions and postmarket management of security in medical devices. A key item in the premarket guidance states that security hazards should be part of the risk analysis, while the postmarket guidance clearly refers to the need for secure software update procedures. The new postmarket guidance states that FDA typically will not need to clear or approve medical device software changes that are made solely for updating cybersecurity features in the field. This latitude is to enable fast response to emerging threats. Going even further, FDA issued a Safety Communication that was triggered, for the first time, by cybersecurity vulnerabilities of one type of infusion pump. This communication recommended discontinuing the use of several previously approved devices solely based on their vulnerability to attack.
What to Do to Ensure Cybersecurity
While medical equipment developers are experienced at developing systems to meet functional safety requirements, cybersecurity adds another dimension to the design process. It is advisable to consult with experts to evaluate the different trade-offs to achieve an appropriate security level for the product. For example, INTEGRITY Security Services (ISS), a Green Hills Software company, helps clients address FDA and EU requirements with an end-to-end embedded security design. ISS supports medical device developers in the application of the following five rules of embedded security.
Rule 1: Communicate without trusting the network. An increasing percentage of medical devices are always connected, and many devices are required to be connected for maintenance or upgrades (see Figure 1). While protecting patient data is critical, a device’s fundamental operating parameters, such as maximum dose limits on infusion pumps, are also critical. Even without sensitive data, if connected on a hospital network, a device can be a target for hackers to penetrate the network.
To prevent a security breach, it is necessary to authenticate all endpoints, including the device itself, any human users interacting with the device, and any other connected systems. Secure designs should never assume users and control software are valid just because the received messages have the correct format. In the infusion pumps that were the target of FDA’s safety communication, a hacker was able to gain access to the network, reverse engineer the protocol, and send properly formed commands that would have allowed a lethal dose of medication to be administered to the patient. Authentication protects medical devices from executing commands originating from unknown sources.
Rule 2: Ensure that software is not tampered with. There are many ways for malware to be injected into a device, including:
- Using a hardware debug interface such as JTAG.
- Accessing test and debug interfaces, such as Telnet and FTP.
- Exploiting control protocols that were developed without considering security.
- Simulating a software update that assumes trustworthiness without verification.
System software should not be trusted until proven trustworthy. The point where authentication starts is called the root-of-trust, and for high-assurance systems, this point must be in either hardware or in immutable memory. A secure boot process starts at the root-of-trust and verifies the authenticity of each software layer before allowing it to execute (see Figure 2).
Secure boot verifies the source and integrity of software using digital signatures. Software is signed during release and verified each time it is loaded. This guarantees that a device is free of malware and operates to the quality it was developed. As a result, by preventing malware, secure boot prevents any targeting of the larger network — meeting new FDA guidelines that recommend that if a device has invalid software, it can detect and report it.
Rule 3: Protect critical data. Patient data, key operating parameters, and even software need to be protected not just in transit over the network, but also within the device. This is accomplished by a security design that incorporates separation and encryption to ensure that only authenticated software and users have access to stored data.
Protecting data in transit requires that data can only be viewed by the proper endpoint. Note that standard wireless encryption does not provide secure communication; it protects the data link only, but not the data. Any other system that can access the wireless network is also able to view the packets in decrypted form. Data protection is accomplished through network security protocols, such as TLS, which enables secure client/server communication through mutually authenticated and uniquely encrypted sessions.