Difference between revisions of "User:Shawndouglas/sandbox/sublevel3"

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====IR-1 Incident response policy and procedures====
This control recommends the organization develop, document, disseminate, review, and update incident response policies and procedures. It asks organizations to not only address the purpose, scope, roles, responsibilities, and enforcement of incident response action but also to address how those policies and procedures will be implemented, reviewed, and updated.


'''Additional resources''':
==The laws themselves==
* [https://csrc.nist.gov/publications/detail/sp/800-12/rev-1/final NIST Special Publications 800-12, Rev. 1], page 64
* [https://csrc.nist.gov/publications/detail/sp/800-61/rev-2/final NIST Special Publications 800-61, Rev. 2]
* [https://csrc.nist.gov/publications/detail/sp/800-83/rev-1/final NIST Special Publications 800-83, Rev. 1]
* [https://csrc.nist.gov/publications/detail/sp/800-100/final NIST Special Publications 800-100] 124–30
* [https://www.limswiki.org/index.php/LII:LIMSpec/Maintaining_Laboratory_Workflow_and_Operations#7._Document_management LIMSpec 7.1, 7.2]


====IR-2 Incident response training====
===1. Federal Telecommunications Act of 1996, Section 255 ([https://www.law.cornell.edu/uscode/text/47/255 47 U.S.C. § 255 - Access by persons with disabilities])===
This control recommends the organization provide incident response training to those system users with roles and responsibilities tied to incident response and, more broadly, business continuity planning. That training should occur initially, within an organization-defined period of time upon taking on a related role or responsibility, and when required by major changes to the system. Follow-up training should be conducted at a defined frequency afterwards.


'''Additional resources''':
<blockquote>'''(b) Manufacturing'''
* [https://csrc.nist.gov/publications/detail/sp/800-16/final NIST Special Publications 800-16]
A manufacturer of telecommunications equipment or customer premises equipment shall ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable.
* [https://csrc.nist.gov/publications/detail/sp/800-50/final NIST Special Publications 800-50]
* [https://www.limswiki.org/index.php/LII:LIMSpec/Maintaining_Laboratory_Workflow_and_Operations#8._Resource_management LIMSpec 8.3, 8.5, and 8.7]


====IR-4 Incident handling====
'''(c) Telecommunications services'''
This control recommends the organization, as part of their incident response planning (see IR-8), address how it will engage in preparation, detection and analysis, containment, eradication, and recovery from a security incident. That organization will also link its incident handling with its contingency planning activities and update its incident and business continuity plans, as well as affected training regiments, with "lessons learned" from internal and external events.


'''Additional resources''':
A provider of telecommunications service shall ensure that the service is accessible to and usable by individuals with disabilities, if readily achievable.
* [https://csrc.nist.gov/publications/detail/sp/800-61/rev-2/final NIST Special Publications 800-61, Rev. 2]
* No LIMSpec comp (organizational policy rather than system specification)


====IR-4 (1) Incident handling: Automated incident handling processes====
'''(d) Compatibility'''
This control enhancement recommends the organization employ automated mechanisms to better handle incident response initiatives. NIST gives the example of online incident management systems as a possible automated tool to use.
Whenever the requirements of subsections (b) and (c) are not readily achievable, such a manufacturer or provider shall ensure that the equipment or service is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.</blockquote>


'''Additional resources''':
The term '''disability''' is [https://www.law.cornell.edu/uscode/text/42/12102 defined here]. You can read the full entry, but the basics are:
* [https://www.limswiki.org/index.php/LII:LIMSpec/Maintaining_Laboratory_Workflow_and_Operations#16._Investigation_management LIMSpec 16.7]


====IR-5 Incident monitoring====
<blockquote>'''(1) Disability''' The term “disability” means, with respect to an individual—
This control recommends the organization track and document security incidents affecting the system. For these purposes, the organization may consider pulling information from "incident reports, incident response teams, audit monitoring, network monitoring, physical access monitoring, and user/administrator reports."
:'''(A)''' a physical or mental impairment that substantially limits one or more major life activities of such individual;


'''Additional resources''':
:'''(B)''' a record of such an impairment; or
* [https://csrc.nist.gov/publications/detail/sp/800-61/rev-2/final NIST Special Publications 800-61, Rev. 2]
* [https://www.limswiki.org/index.php/LII:LIMSpec/Maintaining_Laboratory_Workflow_and_Operations#16._Investigation_management LIMSpec 16.6 and 16.7]


====IR-6 Incident reporting====
:'''(C)''' being regarded as having such an impairment (as described in paragraph (3)).</blockquote>
This control recommends the organization require security incidents, suspected and real, and any relevant information to be reported to the appropriate organizational personnel within a certain period of time.


'''Additional resources''':
The term '''readily achievable''' is [https://www.law.cornell.edu/uscode/text/42/12181 defined here]. It is defines as:
* [https://csrc.nist.gov/publications/detail/sp/800-61/rev-2/final NIST Special Publications 800-61, Rev. 2]
* [https://www.limswiki.org/index.php/LII:LIMSpec/Primary_Laboratory_Workflow#6._Reporting LIMSpec 6.8]


====IR-6 (1) Incident reporting: Automated reporting====
<blockquote>'''(9) Readily achievable''' The term “readily achievable” means easily accomplishable and able to be carried out without much difficulty or expense. In determining whether an action is readily achievable, factors to be considered include—
This control enhancement recommends the the organization employ automated mechanisms to better handle reporting of security incidents. These automated mechanisms would likely be tied to existing monitoring controls.


'''Additional resources''':
:'''(A)''' the nature and cost of the action needed under this chapter;
* [https://www.limswiki.org/index.php/LII:LIMSpec/Primary_Laboratory_Workflow#6._Reporting LIMSpec 6.8]
:'''(B)''' the overall financial resources of the facility or facilities involved in the action; the number of persons employed at such facility; the effect on expenses and resources, or the impact otherwise of such action upon the operation of the facility;
:'''(C)''' the overall financial resources of the covered entity; the overall size of the business of a covered entity with respect to the number of its employees; the number, type, and location of its facilities; and
:'''(D)''' the type of operation or operations of the covered entity, including the composition, structure, and functions of the workforce of such entity; the geographic separateness, administrative or fiscal relationship of the facility or facilities in question to the covered entity.</blockquote>


====IR-7 Incident response assistance====
===2. Rehabilitation Act of 1973, Section 508, amended ([https://www.law.cornell.edu/uscode/text/29/794d 29 U.S.C. 794d] - Electronic and information technology)===
This control recommends the organization provide support resources that offer advice and assistance to system users confronted with handling and reporting security incidents. Those support resources could come in the form of help desk, a responsible individual designated in the incident response plan, ot in-house or third-party forensic services.


'''Additional resources''':
There's a government website dedicated to Section 508: [https://www.section508.gov/ https://www.section508.gov/] The related laws and polices can be [https://www.section508.gov/manage/laws-and-policies/ found here]. The intro states (italics emphasis mine):
* No LIMSpec comp (organizational policy rather than system specification)


====IR-8 Incident response plan====
<blockquote>In 1998, Congress amended the Rehabilitation Act of 1973 to require Federal agencies to make their electronic and information technology (EIT) accessible to people with disabilities. The law (29 U.S.C § 794 (d)) ''applies to all Federal agencies when they develop, procure, maintain, or use electronic and information technology''. Under Section 508, agencies must give ''disabled employees and members of the public'' access to information comparable to the access available to others.
This control recommends the organization develop, document, disseminate, review, update, and protect an organizational incident response plan. That plan should be sophisticated enough to contain an incident response roadmap for implementing the developed plan, which should include how the overall plan meshes with business and cybersecurity goals, the resources and responsible individuals that are part of the plan, what should be reportable, and what the associated metrics will be for measuring incident response and its aftermath. The plan should be reviewed and approved by one or more designated personnel, usually leadership or management. Any changes to the plan should be communicated to appropriate personnel, and any affected training should be updated.


'''Additional resources''':
The [https://www.access-board.gov/ U.S. Access Board] is responsible for developing Information and Communication Technology (ICT) accessibility ''standards'' to ''incorporate into regulations that govern Federal procurement practices.'' On January 18, 2017, the Access Board issued a final rule that updated accessibility requirements covered by Section 508, and refreshed guidelines for telecommunications equipment subject to Section 255 of the Communications Act. The final rule went into effect on January 18, 2018.
* [https://csrc.nist.gov/publications/detail/sp/800-61/rev-2/final NIST Special Publications 800-61, Rev. 2]
 
* No LIMSpec comp (organizational policy rather than system specification)
The rule updated and reorganized the Section 508 Standards and Section 255 Guidelines ''in response to market trends and innovations in technology.'' The refresh also harmonized these requirements with other guidelines and standards both in the U.S. and abroad, including standards issued by the European Commission, ''and with the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG 2.0), a globally recognized voluntary consensus standard for web content and ICT.''</blockquote>
 
In discussing ICT, the U.S. Access Board [https://www.access-board.gov/ict/#b-summary-of-key-provisions summarized the key provisions] as such:
 
<blockquote>The Revised 508 Standards and 255 Guidelines replace the current product-based regulatory approach with an approach based on ICT functions. The revised technical requirements, which are organized along the lines of ICT functionality, provide requirements to ensure that covered hardware, software, electronic content, and support documentation and services are accessible to people with disabilities. In addition, the revised requirements include functional performance criteria, which are outcome-based provisions that apply in two limited instances: when the technical requirements do not address one or more features of ICT or when evaluation of an alternative design or technology is needed under equivalent facilitation.</blockquote>
 
The full (lengthy) information about the ICT Accessibility 508 Standards and 255 Guidelines is found here: [https://www.access-board.gov/ict/ https://www.access-board.gov/ict/]
 
The specific software requirements that LabLynx will likely need to consider under Section 508 appear to be found in [https://www.access-board.gov/ict/#chapter-5-software Chapter 5: Software] and [https://www.access-board.gov/ict/#chapter-6-support-documentation-and-services Chapter 6: Support Documentation and Services]. (If for some reason LLX is in the hardware domain, they'll want to also consider[https://www.access-board.gov/ict/#chapter-4-hardware Chapter 4: Hardware] If you're curious about the underlying standards, you can find them in [https://www.access-board.gov/ict/#chapter-7-%C2%A0-referenced-standards Chapter 7: Referenced Standards].
 
Finally, the Section 508 government website has a full Design & Develop section that may be applicable to development process: [https://www.section508.gov/develop/ https://www.section508.gov/develop/]
 
==Additional information==
 
1. The Section 508 website and its glossary mention LIMS under "[https://www.section508.gov/art/glossary/#S scientific instrument]," though only secondarily. At the end: "If a scientific instrument is integrated with a computer or a monitor, the computer (and associated operating system) and the monitor would be separate EIT deliverables, requiring their own Government Product Accessibility Templates (GPAT). If the computer included application software, this software would be another EIT deliverable requiring its own GPAT."
2. It appears some software can qualify for "a legally-defined Exception (Back Office)," as found in this example with STARLIMS and the VA: [https://www.oit.va.gov/Services/TRM/ToolPage.aspx?tid=7502 https://www.oit.va.gov/Services/TRM/ToolPage.aspx?tid=7502]
 
3. Some additional posts and guides that may be revealing:
* [https://www.levelaccess.com/how-do-i-determine-if-my-web-site-or-application-is-section-508-compliant/ How do I determine if my website or application is Section 508 compliant?]
* [https://ftp.cdc.gov/pub/Software/RegistryPlus/508%20Compliance/508softwareandos.doc GSA Guide For Making Software Applications and Operating Systems Accessible] (.doc file; NOTE: No date, so not sure if incorporates amended material, so be careful)
* [https://www.dhs.gov/publication/dhs-section-508-compliance-test-processes DHS Section 508 Compliance Test Processes]

Latest revision as of 21:23, 28 February 2022

The laws themselves

1. Federal Telecommunications Act of 1996, Section 255 (47 U.S.C. § 255 - Access by persons with disabilities)

(b) Manufacturing

A manufacturer of telecommunications equipment or customer premises equipment shall ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable.

(c) Telecommunications services

A provider of telecommunications service shall ensure that the service is accessible to and usable by individuals with disabilities, if readily achievable.

(d) Compatibility

Whenever the requirements of subsections (b) and (c) are not readily achievable, such a manufacturer or provider shall ensure that the equipment or service is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.

The term disability is defined here. You can read the full entry, but the basics are:

(1) Disability The term “disability” means, with respect to an individual—

(A) a physical or mental impairment that substantially limits one or more major life activities of such individual;
(B) a record of such an impairment; or
(C) being regarded as having such an impairment (as described in paragraph (3)).

The term readily achievable is defined here. It is defines as:

(9) Readily achievable The term “readily achievable” means easily accomplishable and able to be carried out without much difficulty or expense. In determining whether an action is readily achievable, factors to be considered include—

(A) the nature and cost of the action needed under this chapter;
(B) the overall financial resources of the facility or facilities involved in the action; the number of persons employed at such facility; the effect on expenses and resources, or the impact otherwise of such action upon the operation of the facility;
(C) the overall financial resources of the covered entity; the overall size of the business of a covered entity with respect to the number of its employees; the number, type, and location of its facilities; and
(D) the type of operation or operations of the covered entity, including the composition, structure, and functions of the workforce of such entity; the geographic separateness, administrative or fiscal relationship of the facility or facilities in question to the covered entity.

2. Rehabilitation Act of 1973, Section 508, amended (29 U.S.C. 794d - Electronic and information technology)

There's a government website dedicated to Section 508: https://www.section508.gov/ The related laws and polices can be found here. The intro states (italics emphasis mine):

In 1998, Congress amended the Rehabilitation Act of 1973 to require Federal agencies to make their electronic and information technology (EIT) accessible to people with disabilities. The law (29 U.S.C § 794 (d)) applies to all Federal agencies when they develop, procure, maintain, or use electronic and information technology. Under Section 508, agencies must give disabled employees and members of the public access to information comparable to the access available to others.

The U.S. Access Board is responsible for developing Information and Communication Technology (ICT) accessibility standards to incorporate into regulations that govern Federal procurement practices. On January 18, 2017, the Access Board issued a final rule that updated accessibility requirements covered by Section 508, and refreshed guidelines for telecommunications equipment subject to Section 255 of the Communications Act. The final rule went into effect on January 18, 2018.

The rule updated and reorganized the Section 508 Standards and Section 255 Guidelines in response to market trends and innovations in technology. The refresh also harmonized these requirements with other guidelines and standards both in the U.S. and abroad, including standards issued by the European Commission, and with the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG 2.0), a globally recognized voluntary consensus standard for web content and ICT.

In discussing ICT, the U.S. Access Board summarized the key provisions as such:

The Revised 508 Standards and 255 Guidelines replace the current product-based regulatory approach with an approach based on ICT functions. The revised technical requirements, which are organized along the lines of ICT functionality, provide requirements to ensure that covered hardware, software, electronic content, and support documentation and services are accessible to people with disabilities. In addition, the revised requirements include functional performance criteria, which are outcome-based provisions that apply in two limited instances: when the technical requirements do not address one or more features of ICT or when evaluation of an alternative design or technology is needed under equivalent facilitation.

The full (lengthy) information about the ICT Accessibility 508 Standards and 255 Guidelines is found here: https://www.access-board.gov/ict/

The specific software requirements that LabLynx will likely need to consider under Section 508 appear to be found in Chapter 5: Software and Chapter 6: Support Documentation and Services. (If for some reason LLX is in the hardware domain, they'll want to also considerChapter 4: Hardware If you're curious about the underlying standards, you can find them in Chapter 7: Referenced Standards.

Finally, the Section 508 government website has a full Design & Develop section that may be applicable to development process: https://www.section508.gov/develop/

Additional information

1. The Section 508 website and its glossary mention LIMS under "scientific instrument," though only secondarily. At the end: "If a scientific instrument is integrated with a computer or a monitor, the computer (and associated operating system) and the monitor would be separate EIT deliverables, requiring their own Government Product Accessibility Templates (GPAT). If the computer included application software, this software would be another EIT deliverable requiring its own GPAT."

2. It appears some software can qualify for "a legally-defined Exception (Back Office)," as found in this example with STARLIMS and the VA: https://www.oit.va.gov/Services/TRM/ToolPage.aspx?tid=7502

3. Some additional posts and guides that may be revealing:

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