This is probably a topic for a much longer essay, but after two design reviews this week with medical device vendor clients on software security issues, I decided to put some thoughts in a blog post.
Almost 8 years ago, Dan Geer, Rebecca Bace, Peter Gutmann, Perry Metzger, Charles Pfleeger, John Quarterman and Bruce Schneier wrote a report titled: CyberInsecurity: The Cost of Monopoly How the Dominance of Microsoft’s Products Poses a Risk to Security.
The report from a stellar cast of information security experts and thought leaders shows that the complexity and dominance of Microsoft’s Windows operating system in US Federal agencies makes the US government prone to cyber attack – a national security threat.
This was in September 2003.
Now fast forward to a congressional hearing on May 25, 2011 by the Committee on Oversight and Government Reform on ”Cybersecurity: Assessing the Immediate Threat to the United States“ Listen to the YouTube video – you will note the concern on potential damage to citizens due to virus infecting government PCs breaching personal information.
So the US government is still running Microsoft Windows and is still vulnerable to data security breaches. It seems that the Microsoft lobbying machine has been “successful” over the past 8 years on the Beltway, if you call threats to national security a success.
One of the commonly used canards by Microsoft monoculture groupies is that all operating systems have vulnerabilities and Windows is no better nor worse than Linux or OS/X. If “you” patch properly everything will be hunky-dory. There are a number of reasons why this is fallacious, to quote the report:
- Microsoft is a near-monopoly controlling the overwhelming majority of systems. This means that the attack surface is big, on a US national level.
- Microsoft has a high level of user-level lock-in; there are strong disincentives to switching operating systems.
- This inability of consumers to find alternatives to Microsoft products is exacerbated by tight integration between applications and operating systems, and that integration is a long-standing practice.
- Microsoft’s operating systems are notable for their incredible complexity and complexity is the first enemy of security.
- The near universal deployment of Microsoft operating systems is highly conducive to cascade failure; these cascades have already been shown to disable critical infrastructure.
- After a threshold of complexity is exceeded, fixing one flaw will tend to create new flaws; Microsoft has crossed that threshold.
- Even non-Microsoft systems can and do suffer when Microsoft systems are infected.
- Security has become a strategic concern at Microsoft but security must not be permitted to become a tool of further monopolization.
As a medical device security and compliance expert, I am deeply concerned about medical devices that use Windows. If Windows is a threat to national security because it’s used in Federal government offices, Windows is really a bad idea when used in medical devices in hospitals.
I’m concerned about the devices themselves (the FDA classifies Web applications as medical devices also if the indications are medical-related) and the information management systems: the customer support, data collection, analysis management applications that are ubiquitous to networked medical devices.
There are two reasons why the FDA should outlaw Windows in medical devices and their information management systems.
Reason number 1 to ban Windows from medical devices is complexity. We know that the first sin of the 7 deadly sins of software development is making the software complex. Complexity is the enemy of security because with complex software, there are more design flaws, more software defects and more interfaces where vulnerabilities can arise.
Similar to the history of data security breaches of retail systems, the medical device software industry is (or may soon be) facing a steeply increasing curve of data security and patient safety events due to the Microsoft monoculture. We are not in Kansas anymore – not credit cards being breached, but entire hospital networks infected by Microsoft Windows viruses and patient monitoring devices that stop working because they got blue screens of death.
Since 300 million credit cards have been breached, it is a reasonable assumption that your card and mine is out there. The damage to your credit card being breached is minimal. But, if your child was on a patient monitor that went offline due to a Microsoft Windows virus and a critical condition was not detected in time; it’s the difference between life and death.
The complexity and vulnerabilities of Windows technologies are simply not appropriate in the medical device space when you look at the complexity and weight of the components, the SQL injection vulnerabilities provided courtesy of naive ASP.NET programmers and the ever present threat of Windows viruses and malware propagated by USB sticks and technician notebooks.
The Microsoft monoculture breeds a generation of programmers that are scared of the command line, unable to comprehend what happens behind the GUI and lured by the visual beauty of the development tools. When a programmer uses a component and doesn’t know it works (see Visual Studio ) and shleps around a load of piping in his project, then the energies go into implementing a cute GUI instead of thinking about code threats.
This is on a grander scale, a rerun of Microsoft Powerpoint, where you spend 80% of your time in the application’s GUI instead thinking about and then just stating your message.
Reason number 2 to ban Microsoft Windows from medical devices is more subtle and related to systems management. The Microsoft monoculture has bred a particular kind of thinking and system management best practices based on Windows servers and Windows PCs running in the office. This IT system management strategy assumes that PCs are just personal devices that someone has to patch and that they will eventually get infected and or breached and or get a BSOD.
Unlike an office, a hospital is a highly heterogeneous and hostile environment. The system management strategy for network medical devices must be different.
Medical device vendors need to assess their software security with the design objective being a device that runs forever and serves the mission of the doctors and patients.
Medical devices are real time embedded systems living on a hospital network. They should be fail safe, not vulnerable to viruses and should not have to rebooted every few days.
Yes – it’s a tall bill and a lot of people will have to learn how to write code in embedded Linux.
But, there is no alternative, if we want to prevent the medical device industry from suffering the ignominy of the credit card industry.
Cross-posted from Israeli Software