An ISSEP is leading a risk assessment for an Industrial Control System (ICS) that controls a water treatment facility. The system uses legacy Programmable Logic Controllers (PLCs) that cannot be patched. The ISSEP must recommend compensating controls to reduce risk. Which TWO of the following are the MOST effective compensating controls for this scenario? (Choose two.)
Trap 1: Replace all legacy PLCs with new models that support patching.
While replacement is a long-term solution, it is not a compensating control and may be cost-prohibitive or disruptive to operations. The question asks for compensating controls to reduce risk in the current state. Replacement is a risk avoidance strategy, not a compensating control, and may take years to implement.
Trap 2: Deploy host-based antivirus software directly on the PLCs.
Legacy PLCs typically run real-time operating systems that do not support host-based antivirus software. Installing such software could disrupt control processes and is often technically infeasible. Antivirus is not a viable compensating control for PLCs; instead, network-level protections are more appropriate.
Trap 3: Require all operators to use multi-factor authentication (MFA) when…
Legacy PLCs often lack support for MFA and may not have user authentication at all. Even if MFA could be added, it does not address network-based attacks or physical tampering. MFA is a good practice for human-machine interfaces (HMIs) but is not the most effective compensating control for the PLCs themselves.
- A
Replace all legacy PLCs with new models that support patching.
Why it fails: While replacement is a long-term solution, it is not a compensating control and may be cost-prohibitive or disruptive to operations. The question asks for compensating controls to reduce risk in the current state. Replacement is a risk avoidance strategy, not a compensating control, and may take years to implement.
- B
Implement network segmentation with industrial firewalls to isolate the PLCs from the corporate network and the internet.
Network segmentation with industrial firewalls limits lateral movement and blocks unauthorized access to legacy PLCs. Since patching is not possible, isolating the devices reduces exposure to external threats. This is a fundamental compensating control for unpatched ICS components, as it prevents attackers from reaching the PLCs directly.
- C
Deploy host-based antivirus software directly on the PLCs.
Why it fails: Legacy PLCs typically run real-time operating systems that do not support host-based antivirus software. Installing such software could disrupt control processes and is often technically infeasible. Antivirus is not a viable compensating control for PLCs; instead, network-level protections are more appropriate.
- D
Establish strict physical access controls and monitoring for the control room and PLC cabinets.
Physical access controls prevent unauthorized individuals from directly connecting to or tampering with PLCs. Since many ICS attacks require physical proximity, restricting access and monitoring entry points significantly reduces risk. This is a highly effective compensating control when patching is not possible.
- E
Require all operators to use multi-factor authentication (MFA) when logging into the PLCs.
Why it fails: Legacy PLCs often lack support for MFA and may not have user authentication at all. Even if MFA could be added, it does not address network-based attacks or physical tampering. MFA is a good practice for human-machine interfaces (HMIs) but is not the most effective compensating control for the PLCs themselves.