'Shall' ought to have been changed to 'should'.
On 2024-08-23 22:45, Scott Aldous wrote:
Hi Lauren,
Digging a bit, it looks like this was originally proposed as a hard
requirement. See PI 22 in this doc
<https://docinfofiles.nfpa.org/files/AboutTheCodes/79/79_F2023_EEI_AAA_FD_PIResponses.pdf>
(you can search on "cybersecurity" to find it). This was proposed by
Keith Waters from Schneider Electric, and at the time included "shall"
rather than "shall be permitted".The committee statement was that "the
proposed language is overly broad and restrictive."
If you search on "cybersecurity" in this doc
<https://docinfofiles.nfpa.org/files/AboutTheCodes/79/79_F2023_EEI_AAA_SD_PCResponses.pdf>,
you can find a subsequent public comment where the same submitter
revised the proposal, this time modifying the language that would have
made it mandatory. The submitter's comment there states:
"In reviewing the response to the original PI, I still feel that
cybersecurity is essential to properly protecting industrial machinery
and a consensus standard is the best way to protect these systems in
lieu of 51 different requirements from the federal government and the
individual states. *However, I understand that we need to create a
starting point to learn the best methods before setting full
requirements. The change to the PI to make the requirement “shall be
permitted” vs “shall” is a good first step into creating the safety
and reliability protections*."
Even though this second comment was rejected, it references a
subsequent revision with much the same language that can be found here
<https://docinfofiles.nfpa.org/files/AboutTheCodes/79/79_F2023_EEI_AAA_SD_SRStatements.pdf>.
On Fri, Aug 23, 2024 at 2:20 PM Ralph McDiarmid
<[email protected]> wrote:
Sounds optional to me too. You’re allowed to do it, but you’re
not required to do it.
It’s Friday in Canada and Mexico too, but the way ;>)
Ralph
*From:*Lauren Crane
<[email protected]>
*Sent:* Friday, August 23, 2024 1:34 PM
*To:* [email protected]
*Subject:* [PSES] NFPA cybersecurity "shall be permitted"?
Hello All,
Happy Friday (US)….
There is a new section in NFPA 79 - 2024 edition – “4.10
*Cybersecurity.* Industrial machinery that is connected to a
communication network and permitted to control any part of the
machinery _shall be permitted_ to comply with the following: (1) A
cybersecurity assessment conducted on the connected system to
determine vulnerabilities to cyberattacks; (2) A cybersecurity
commissioning certification conducted on the connected system to
ensure it is designed against cyberattacks and known
vulnerabilities; (3) Documentation of the assessment and
certification provided to those authorized to inspect, operate,
and maintain the system”
My best take at this is the whole thing is optional given the
underlined “shall be permitted”. That phrase seems to mean (as it
is used throughout NFPA 79) “is allowed”. But if I read it that
way, it means the whole section 4.10 was added just to say one is
allowed to do 3 things and it has no obligation to actually do
anything, which seems off - because it is rather silly –
Particularly since doing what is listed would not reasonably be
questioned, so it doesn’t really need to be clarified that one is
allowed to do it.
Do any of you have a different take on this?
Best Regards,
-Lauren
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