> From: openssl-users [mailto:[email protected]] On Behalf Of 
> Oleg Paikin
> Sent: Wednesday, June 20, 2018 01:01

> We would like to add to our product OpenSSL with FIPS 140-2 module. The 
> problem is that our OS and CPUs
> are not FIPS certified. We use vxWorks 5.5.1 with 3 types of CPUs in 
> different products.

Disclaimer: I've never had to shepherd anything through the FIPS validation 
process. The following is just my understanding from reading about it.


Nothing is "FIPS certified". FIPS 140-2 does not define a "certification". 
There is FIPS validation, which if successful results in a "validation 
certificate". There's also FIPS 140 "user affirmation", which basically 
involves you saying "hey, any crypto we have is FIPS 140-2 validated in some 
other context, just not here, cross our hearts". Some customers may accept 
that, and others may not.

There's also a "FIPS Inside" claim, where you say that even if the entire 
system is not FIPS-validated, all the actual crypto is. (I'm actually not sure 
that's officially endorsed by the NIST procurement procedures doc; I've heard 
people who should know claim that it is, but I haven't looked for chapter & 
verse myself.)

Also, note that what's validated is a combination of the cryptographic 
implementation itself; cryptographic things that are done (e.g. the self-tests) 
and not done (e.g. no forbidden algorithms are used); and the runtime platform 
(the "Operational Environment"). So what you'd be getting validated is not the 
OS and CPUs themselves, but the combination of OpenSSL (and any other crypto 
software or hardware you might have), OS, and CPU. From your description, it 
sounds like you need four validations, unless your customers will accept user 
affirmation.

That's assuming your customers aren't also requesting FIPS 140-2 hardware 
tamper-resistance or some other additional assurance.

> How can we get certification for these environments? OSF answered that they 
> do not do FIPS consulting
> work anymore. Can somebody explain what is the process and cost to get such 
> certification?

The process is you find a lab that will do FIPS 104-2 validation, pay them a 
lot of money, and wait a long time (months) while they do the testing and go 
back and forth with the CMVP. History shows that the CMVP can be rather 
arbitrary. The cost is generally considerable - I think tens of thousands of 
dollars is typical.

Now, all that said, you can use OpenSSL with the FIPS container and enable FIPS 
mode without claiming you're FIPS-validated. That doesn't fulfill NIST 
procurement rules, but you may have a customer who isn't subject to those rules 
but wants to tick some "FIPS" checkbox anyway. (There's no technical advantage 
to doing so, but cryptography is an esoteric subject and sometimes people come 
up with pointless requirements.) I've known people who don't need FIPS 
validation to ask for some FIPS claim anyway, even when that claim is 
essentially meaningless. If that's the case, just make it possible for the 
customer to enable FIPS mode and let them go their merry way.

--
Michael Wojcik
Distinguished Engineer, Micro Focus
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