Medical-device cybersecurity risk management

Sytance · Updated

Medical-device cybersecurity risk management assesses how threats and vulnerabilities can affect safety, effectiveness and performance. A threat model, SBOM, vulnerability scan or penetration test can support the assessment, but none of them is the risk assessment by itself.

Risk management role

FDA treats security risk management as part of the quality system and device lifecycle. It is distinct from ISO 14971 safety risk management because security failures can be intentional, exploitability changes over time, and harm can be indirect through loss of availability, integrity, confidentiality or control. The two processes still have to interface because a security issue can create patient harm.

MDCG 2019-16 explains that a security measure can itself affect safety. For example, an access restriction may prevent unauthorised changes but also delay a legitimate operation. The manufacturer needs to assess both effects in the intended use environment.

Patient harm

FDA postmarket guidance defines the central patient-harm question around injury or damage to patient health, including death, rather than business impact alone.

Safety and performance

Assess whether the security issue changes the device’s intended operation and whether a control introduces a new safety or performance concern.

Threat modelling feeds the assessment

The threat model identifies how an attacker could use a device interface or external dependency to cause an unwanted result. Its attack conditions and possible consequences become inputs to the cybersecurity risk assessment.

  • The threat model identifies what can go wrong and where an attacker or accidental trigger can reach the system.
  • The cybersecurity risk assessment evaluates the risks, controls, residual risks and acceptance criteria.
  • The safety risk process receives security risks when exploitation can affect patient harm, clinical performance or safe operation.
  • The postmarket process updates the model when new vulnerabilities, changed deployments, new interfaces or new attack techniques change the risk picture.

Exploitability changes the analysis

Cybersecurity risk assessment cannot rely only on historical probability. FDA explains that security-risk assessment focuses on exploitability: the feasibility, ease and technical means by which a vulnerability can be exploited. That is why a vulnerability found in testing, a CISA Known Exploited Vulnerability, a changed network path or a new public exploit can change the assessment even if no patient incident has occurred.

SBOM is not the risk assessment

An SBOM identifies software components and dependency relationships. It helps the manufacturer find exposure to known component vulnerabilities, support status and affected versions. It does not show whether a vulnerable component is reachable, whether a control prevents exploitation, whether clinical performance changes, or whether residual patient-harm risk is acceptable.

An SBOM is a formal, machine-readable inventory of software components and dependencies, information about those components, and their hierarchical relationships.

NTIA, Framing Software Component Transparency, 2021 (original English)

SBOM contribution

Component identity, version, supplier, dependency and support data help identify exposure and support vulnerability management.

Risk contribution

Architecture, threat modelling, exploitability, control evidence and patient-harm analysis decide what the exposure means for the device.

Connected records

FDA recommends traceability between the threat model, risk assessment, SBOM and test records. A reviewer should be able to start with an affected component and find the resulting risk decision and verification result. For an EU technical file, explain how those records support the applicable MDR or IVDR requirements.

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