Are we ready for a cyber-UL?

Planning to duplicate what UL has done for the electronic industry, the newly formed CIS aims to implement rating system for security products. The idea smacks of a citadel approach and may not work well with current security environment.

Underwriters Laboratories (UL) is an independent testing organization that rates electrical equipment, safes, and a whole lot of other things. It all started in 1893, when William Henry Merrill was called in to find out why the Palace of Electricity at the Columbian Exposition in Chicago kept catching on fire (not the best way to tout the wonders of electricity).

After making the exhibit safe, Merrill realized he had a business model on his hands.

He approached insurance underwriters with the idea of an independent testing lab. They were all sick of paying for electricity fires, and took him up on the deal. Eventually, if your electrical equipment wasn't UL-certified, you couldn't get insurance.

Real-world testing

Today, Underwriters Laboratories rates all kinds of equipment, not just electrical. Safes, for example, are rated based on time and materials. A "TL-15" rating means that the safe is secure against a burglar limited to safecracking tools (and not torches or explosives) and 15 minutes' working time.

Other ratings certify the safe for longer periods of time or against burglars with blowtorches and explosives. These ratings are not theoretical; actual hotshot safecrackers, employed by UL, take actual safes and test them. If a company comes out with a new version of the safe, he has to get it retested -- the rating does not carry forward.

Applying this sort of thinking to computer networks -- firewalls, operating systems, Web servers -- is a natural idea. And the newly formed Center for Internet Security plans to implement it. I'll talk about the general idea first and then the specifics.

A moving target

I don't believe that this is a good idea, certainly not now and possibly not ever. First, network security is too much of a moving target. Safes are easy. Safecracking tools don't change much. Maybe someone invents a hotter torch, or someone else invents a more sensitive microphone. But most of the time, techniques of safecracking remain constant.

Not so with the Internet. There are always new vulnerabilities, new attacks, new countermeasures. There are a couple of dozen new vulnerabilities each week in major software products; any rating is likely to become obsolete within months, if not weeks.

Second, network security is much too hard to test. Again, safes are easy. Breaking into them requires skill but is reasonably straightforward. Modern software is obscenely complex: There's an enormous number of features, configurations, implementations. And then there are interactions between different products, different vendors, and different networks.

In the past, I've written extensively about complexity and the impossibility of testing security. For now, suffice it to say that testing any reasonably sized software product would cost millions of dollars and wouldn't guarantee anything at the end. And worse, if you updated the product you'd have to test it all over again.

Third, I'm not sure how to make security ratings meaningful. Intuitively, I know what it means to have a safe rated at 30 minutes and another rated at an hour. But computer attacks don't take time in the same way that safecracking does.

The Center for Internet Security talks about a rating from 1 to 10. What does a 9 mean? What does a 3 mean? How can ratings be anything other than binary: Either there is a vulnerability or there isn't?

The moving-target problem particularly exacerbates this issue. Imagine a server with a 10 rating; there are no known weaknesses. Someone publishes a vulnerability that allows an attacker to break in.

What is the server's rating now? Nine? One? How are users notified of this change? Is the manufacturer required to change his official rating on his Web site? On his packaging? How does the Center re-rate the server once it is updated? But then the rating only affects certain patch levels of the product; how do you explain that? And once you've solved that, how do you deal with vulnerabilities that only affect the product in some configurations?

Fourth, failures in network security are not always obvious. If a safe is broken into, the owner learns about it when he next opens his safe. If a network is broken into, the owner might never know. Data isn't stolen in the same way as diamonds or cash: It is copied, it is modified, or it is just examined.

Remember that Microsoft Corp.'s network was compromised for weeks before anyone knew about it. I believe that most network intrusions are never even noticed. A "secure" network product might fail completely, and no one would be the wiser.

Fifth, I don't see how a rating could take context into account. Safes are just as hard to crack in a bank as they are in a house; network security products are highly dependent on their environment.

A product rating cannot take into account the environment and interactions that a component will deal with. Network components would be certified in isolation but deployed in a complex interacting environment. It is common to have several individual "secure" components completely blow a security model when they are all forced to interact with each other.

Sixth, I don't see how to combine this concept with security practices. Today the biggest problem with firewalls is not how they're built but how the user configures them.

How does a security rating take that into account? How does a security rating take into account the people problem: users naively executing e-mail attachments, or resetting passwords when a stranger calls and asks them to? Simply prohibiting attachments will make a network more secure.

And seventh, this kind of thing could easily fall into the trap of bashing small products and protecting large products. A little-discussed fact of computer security is that minority products are more secure than popular products for the simple reason that there aren't as many exploits for them.

But the unpopularity of those products might make it difficult for them to pay for evaluation. And can major vendors be held to the same standards of everyone else? It will take a lot of organizational fortitude to fail Microsoft's security, for example.

This is not to say that there's no hope. I believe that the insurance industry will eventually drive network security, and that some sort of independent testing is inevitable. But I don't think that providing a rating or a seal of approval is possible anytime soon.

Even so, the Center for Internet Security is tackling the challenge. Unfortunately, I don't particularly like what I see so far (although admittedly, I haven't seen much). Looking at the group's Web site, it seems more like a marketing scheme than anything else. A security supplier or consulting organization can spend $25,000 to become a member. (Organizations that use security can join for only $7,000.)

Benefits include "your organization's name ... on Center brochures and benchmarks documents," "your organization's name included on the Center's Web site," and "the privilege of using the Center's logo on your Web site." The last time I checked, there were 71 charter members.

The group's initial push is to consolidate a bunch of the mediocre security requirements documents out there (such as BS7799) and come up with a "final set of minimum benchmarks to be used as a basis for demonstrating due care," and to create a suite of tests that can give computer owners some kind of security rating or feeling of confidence.

I see ideas like this as part of the Citadel model of security, as opposed to the Insurance model. The Citadel model basically says: "If you have this stuff and do these things, you'll be safe." The Insurance model says: "Inevitably things will go wrong, so you need to plan for what happens when they do."

In theory, the Citadel model is a much better model than the pessimistic, fatalistic Insurance model. But in practice, no one has ever built a citadel that is both functional and dependable.

My worry is that this group will become yet another "extort-a-standard" body that charges companies for a seal of approval. I belive that the people behind the Center for Internet Security have completely pure motives; you can be an ethical extortionist with completely honorable intentions. What makes it extortion is the detriment from not paying. If you don't have the "Security Seal of Approval," then -- tsk, tsk! -- you're just not concerned about security.

Security technologist and author Bruce Schneier is founder and chief technical officer of Counterpane Internet Security Inc., which provides monitoring and response for Internet sites; the author of " Secrets and Lies: Digital Security in a Networked World"; and the editor of Crypto-Gram, a free monthly e-mail newsletter on computer security and cryptography.

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