October 24, 2018
Katerina Megas and Colleagues
Cybersecurity for the Internet of Things (IoT) Program
National Institute of Standards and Technology
Gaithersburg, MD 20899
Subject: Draft NIST Interagency Report (NISTIR) 8228, Considerations for Managing
Internet of Things (IoT) Cybersecurity and Privacy Risks
Dear Ms. Megas and Colleagues:
The U.S. Chamber of Commerce generally supports the draft NISTIR 8228, Considerations
for Managing Internet of Things (IoT) Cybersecurity and Privacy Risks (NISTIR). We appreciate
the substantial effort that you and your colleagues put into developing it, including meeting with the
business community in multiple forums.
First, we agree with the National Institute of Standards and Technology’s (NIST’s) decision
to leave IoT undefined.1 Each sector has its own types of IoT devices (e.g., specialized medical
equipment in the health care sector and smart automobile technologies in the transportation sector).
Connected consumer devices are quickly proliferating (e.g., refrigerators, thermostats, and TVs).2
What’s especially important, the NISTIR says that organizations should mitigate risks to
connected devices’ cybersecurity and privacy throughout their life cycles—but it empowers
organizations to determine which considerations and challenges apply to particular IoT equipment.
Second, the NISTIR captures stakeholders’ interest in continued engagement on so-called
cybersecurity and privacy baselines for IoT devices.3 NIST is not reinventing the wheel, which is
key for policymakers to understand. The agency is, in part, leveraging extensive public and private
sector initiatives that are underway to enhance the security and privacy of IoT devices.4
- The Chamber generally supports the NISTIR, which stresses that organizations should mitigate cybersecurity and privacy risks to IoT devices. However, the report enables organizations to determine which considerations apply to certain connected devices.
- The Chamber urges the Department of Commerce to convene additional discussions with industry and other cyber stakeholders on nonregulatory baselines for IoT devices.We strongly agree with NIST’s view that stakeholders should establish IoT device security and privacy capabilities with humility.
- The Chamber wants device makers, service providers, and buyers to gain from the business community leading the development of state-of-the-art IoT components and risk management practices. Next steps include catalyzing a process in the market that generates increased security and value for buyers and sellers.
Public and/or private IoT cybersecurity and privacy initiatives (select examples)5
The Chamber urges the Department of Commerce to convene additional discussions with
industry and other cyber stakeholders on baselines. The Chamber believes that industry should drive
the security and resilience of the IoT ecosystem in collaboration with public entities, which need to
prioritize pushing back on malicious actors. NIST says that it intends to develop a future publication
“defining a high-level baseline and one or more publications defining baselines and other
recommendations for particular IoT device types.” The Chamber wants to engage such
The Chamber contends that NIST and industry need to collaborate to debate and possibly
determine baseline security and privacy recommendations that are recognized globally, rather than
defer decision making to regional bodies (e.g., the EU),6 Congress, or state legislatures.7 At the
same time, the Chamber strongly agrees with NIST’s view that stakeholders should set IoT device
security and privacy baselines with humility.8 Indeed, NIST notes that because IoT devices and
their uses and needs are so varied, “few recommendations can be made that apply to all IoT
Third, the Chamber wants device makers, service providers, and buyers to gain from the
business community leading the development of state-of-the-art IoT components and sound
risk management practices. Stakeholders are trying to solve a chicken-and-egg strategy problem.
Next steps include facilitating a process in the marketplace that generates both security and value
for buyers and sellers. Market and/or policy incentives may be needed to jumpstart this circle.10
The Chamber welcomes the opportunity to provide feedback on the NISTIR. We are
optimistic about the future of the IoT, which continues the decades-long trend of connecting
networks of objects through the internet. The IoT will significantly affect many aspects of the
economy, and the Chamber wants to constructively shape the breadth and nature of its eventual
impact. Many observers predict that the expansion of the IoT will bring positive benefits through
enhanced integration, efficiency, and productivity across many sectors of the U.S. and global
Meaningful aspects of the IoT, including guarding against botnets and other automated
threats, will also influence economic growth, infrastructure and cities, and individual consumers.11
The NISTIR tracks closely with fundamental cybersecurity principles that the Chamber extensively
advocates for to foster beneficial outcomes of the IoT.12
Christopher D. Roberti
Chief of Staff
Senior Vice President, Cyber, Intelligence, and Security
Matthew J. Eggers
Vice President, Cybersecurity Policy
1 The National Telecommunications and Information Administration’s (NTIA’s) January 2017 Green Paper: Fostering
the Advancement of the Internet of Things is a significant policy paper regarding the development of the IoT. Some
parties argue that strict definitions or labels could inadvertently narrow the scope of the IoT’s potential applications
(pg. 5). www.ntia.doc.gov/files/ntia/publications/iot_green_paper_01122017.pdf
2 Draft NISTIR 8228, Considerations for Managing Internet of Things (IoT) Cybersecurity and Privacy Risks (NISTIR),
September 24, 2018, pg. v. https://csrc.nist.gov/news/2018/nist-releases-draft-nistir-8228-for-comment
3 The NISTIR says, “The term ‘baseline’ has different meanings to different people and organizations. Some want flexible general recommendations; some want specific, prescriptive guidance; and the rest want something in between. In this publication, ‘baseline’ is used in the generic sense of a set of requirements or recommendations. It should not be confused with the low, moderate, and high control security baselines set forth in NIST Special Publication 800-53 to help federal agencies meet their obligations under the Federal Information Security Modernization Act (FISMA) and other federal policies” (pg. iv).
4 NISTIR, pg. 29.
5 Starting with the draft NISTIR 8200 and moving clockwise, see the following examples, which the Chamber does not necessarily endorse:
- Draft NISTIR 8200, Status of International Cybersecurity Standardization for Internet of Things (IoT). www.nist.gov/sites/default/files/documents/2018/04/19/4-18-18_uscc_lette...
- The NISTIR references guidance from the Broadband Internet Technical Advisory Group (BITAG), etc. (pg. 30).
- NIST and NTIA multistakeholder processes. www.ntia.doc.gov/IoTSecurity and
- “Statement from FDA Commissioner Scott Gottlieb, M.D. on FDA’s efforts to strengthen the agency’s medical device cybersecurity program as part of its mission to protect patients,” FDA, October 1, 2018. www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm622074.htm
- National Highway Traffic Safety Administration (NHTSA). www.nhtsa.gov/crash-avoidance/automotive-cybersecurity
- National Security Institute (NSI) policy paper, Cyber Imperative: Preserve and Strengthen Public-Private Partnerships, October 2018. See pg. 14 on public-private partnerships regarding IoT cybersecurity. https://nationalsecurity.gmu.edu/2018/10/nsi-policy-paper-cyber-imperative-preserve-and-strengthen-public-private-partnerships
- Council to Secure the Digital Economy (CSDE). www.ustelecom.org/news/press-release/ustelecom-and-iti-launch-council-secure-digital-economy
- National Security Telecommunications Advisory Committee (NSTAC) Report to the President on Internet and Communications Resilience,
November 2017. www.dhs.gov/sites/default/files/publications/NSTAC%20Report%20to%20the%20President%20on%20ICR%20FINAL%20%2810-12-17%29%20%281%29-%20508%20compliant_0.pdf
- UL 2900. https://industries.ul.com/cybersecurity/ul-2900-standards-process
- Charter of Trust. www.siemens.com/press/pool/de/feature/2018/corporate/2018-02-cybersecurity/charter-of-trust-e.pdf
- The Digital Standard. www.thedigitalstandard.org
- Security Star. www.publicknowledge.org/assets/uploads/documents/Securing_the_Modern_Economy--Transforming_Cybersecurity_Through_Sustainability_FINAL_4.18.18_PK.pdf
6 EU Cybersecurity Agency (ENISA) and information and communication technology cybersecurity certification
(Cybersecurity Act). 2017/0225(COD), September 2017.
In August 2017, the Chamber and six European organizations sent a letter to the European Commission regarding
“measures on cybersecurity standards, certification and labelling to make ICT-based systems, including connected
objects.” The industry groups argued that Europe, like the U.S., can expect to benefit from economic growth brought
about by the expanding IoT as long as policymakers cultivate a digital environment that avoids misguided regulations
and supports pioneering businesses. Underpinning the Chamber’s efforts at home and abroad is advocacy for smart
policies for smart devices. www.uschamber.com/iot%26cybersecurity
7 On January 1, 2020, California SB-327 will require a manufacturer of a connected device to equip the device with a
“reasonable security feature or features” that are appropriate to the nature and function of the device, among other
8 House Oversight and Government Reform Committee’s Information Technology Subcommittee hearing,
Cybersecurity of the Internet of Things, October 3, 2017.
9 NISTIR, pg. iv.
10 This graphic was inspired, in part, by the Strategic Toolkits webpage, “Chicken and Egg Strategy Problems.”
11 See, in particular, comments filed with the NTIA by the C_TEC in March 2017 and June 2016.
12 In July 2017, the Chamber submitted comments to the NTIA’s notice, Promoting Stakeholder Action Against Botnets
and Other Automated Threats.
See related Chamber comments submitted to NTIA concerning botnets and IoT on February 12, 2018.
See, too, The IoT Revolution and Our Digital Security: Principles for IoT Security, September 2017, written by the
Chamber and Wiley Rein LLP. www.uschamber.com/IoT-security
NIST IoT Cybersecurity Colloquium, October 18, 2017.