10 24 18 u s chamber comment letter draft nistir 8228 final


October 24, 2018


October 24, 2018

Via iotsecurity@nist.gov

Katerina Megas and Colleagues
Program Manager
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

If you have any questions or need more information, please do not hesitate to contact
Christopher Roberti (croberti@uschamber.com, 202-463-3100) or Matthew Eggers
(meggers@uschamber.com, 202-463-5619).


Christopher D. Roberti
Chief of Staff
Senior Vice President, Cyber, Intelligence, and Security

Matthew J. Eggers
Vice President, Cybersecurity Policy


1The 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

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
requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201...

8House Oversight and Government Reform Committee’s Information Technology Subcommittee hearing,
Cybersecurity of the Internet of Things, October 3, 2017.

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.