IPC-1791, Cybersecurity Maturity Model Certification (CMMC), and the Printed Circuit Board Design, Fabrication, and Assembly Industry
This paper presents the concerns on trustworthiness for printed circuit board (PrCB) design, fabrication, and assembly sources for national defense systems, specifically products on the United States Munitions List (USML) that are vulnerable to theft, tampering, and supply disruption.
Trustworthiness is defined and the implementation of a new industry standard, IPC-1791 Trusted Electronic Designer, Fabricator and Assembler Requirements, is presented. The flaws of DFARS 252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting are also outlined, including the lack of oversight, the absence of third-party certification, and the use of a System Security Plan (SSP) and a Plan of Action and Milestones (POA&M) in lieu of full compliance.
In light of these concerns, this paper illustrates how the Cybersecurity Maturity Model Certification (CMMC) can solve these problems, specifically focusing on CMMC Level 3 as this level is required for contractors handling Controlled Unclassified Information (CUI). The parallels between CMMC Level 3 and NIST SP 800-171 Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations requirements are also discussed.
While focusing on the positive attributes of CMMC, this paper also examines the challenges that CMMC may cause. Studies have found that even without the added costs of CMMC, many small companies struggle to absorb the cost of some NIST SP 800-171 requirements. The additional financial challenge of CMMC for smaller companies could result in DoD and primes loosing critical suppliers who choose not to be certified. Prime contractors have the benefit of a cost allowance, but this does not flow down to the small companies who are competitively bidding on PrCBs or assemblies at a fixed unit price.