National Institute of Standards and Technology

Implementation Guidance for
FIPS PUB 140-1 and the Cryptographic Module Validation Program

Table of Contents

Overview

This document is intended to provide clarifications of the CMVP, and in particular, clarifications and guidance pertaining to the Derived Test Requirements (DTR), which is used by CMT laboratories to test for a cryptomodule's conformance to FIPS PUB 140-1. Guidance presented in this document is based on responses issued by NIST and CSE to questions posed by the CMT labs, vendors, and other interested parties. However, information in this document is subject to change by NIST and CSE.

Each section of this document corresponds with a requirements section of FIPS PUB 140-1, with an additional first section containing general guidance that is not applicable to any particular requirements section. Within each section, the guidance is listed according to a subject phrase. For those subjects that may be applicable to multiple requirements areas, they are listed in the area that seems most appropriate. Under each subject there is a list, including the date of issue for that guidance, along relevant assertions, test requirements, and vendor requirements from the DTR. (Note: For each subject, there may be additional test and vendor requirements which apply.) Next, there is section containing a question or statement of a problem, along with a resolution and any additional comments with related information. This is the implementation guidance for the listed subject.

Below is a list of where the reader can find related documentation:

• FIPS PUB 140-1
• Announcement of the CMVP
• Derived Test Requirements for FIPS PUB 140-1
• Cryptographic Module Validation List

General Issues

G.1 Implementation guidance requests to NIST and CSE

Question/Problem

Resolution

• Programmatic Questions: Questions concerning the general operation of the CMV Program can be directed to either NIST or CSE. Here are the appropriate points of contact:
  • NIST
    Jim Foti
    (301) 975-5237

  • CSE
    (11/24/97)
    Tom Casar
    (613) 991-7202

• Test-specific Questions: If a vendor is under contract with a CMT lab for 140-1 or algorithm testing, then the vendor should contact the lab with any questions concerning the test requirements. This allows the lab representatives to use their expertise in 140-1 testing to answer those questions, and it acts as a filter for NIST and CSE.

  Agencies, departments, vendors not under contract with a CMT lab, and CMT labs themselves who have specific questions about a 140-1 test requirement should contact the appropriate NIST and CSE points of contact:

  • NIST
    Ray Snouffer
    (301) 975-4436

  • CSE
    (11/24/97)
    Tom Casar
    (613) 991-7202

  All test-specific questions asking for implementation guidance shall have the following form, in order for NIST and CSE to understand the question as clearly as possible, and to provide an appropriate response:

  1. Applicable statement(s) from FIPS 140-1,
  2. Applicable assertion(s) from the DTR,
  3. Applicable required test procedure(s) from the DTR,
  4. A concise statement of the problem, followed by a clear and unambiguous question regarding the problem, and
  5. A statement of the resolution that is being sought.

  (4/25/97)
  All questions should be presented in a detailed, implementation-specific format, rather than an academic or hypothetical format. This information should also include a brief description of the implementation and the FIPS 140-1 target level. All of this will enable a more efficient and timely resolution of 140-1 related questions by NIST and CSE. When appropriate, NIST and CSE will derive general guidance from the problem and response, and add that guidance to this document. Note that general questions may still be submitted, but these questions should be identified as not being associated with a particular validation effort.

Additional Comments

G.2 Completion of a validation - information that must be provided to NIST and CSE

Question/Problem

Resolution

1. A non-proprietary version of the VALIDATION REPORT, which shall include (at a minimum):
   1. Summary Report - a single page which lists the various requirements sections, their target level, the status of each area for that level (passed/failed/not applicable), and the overall level for which the module passed validation testing.

   2. Detailed Report with assessments (and notes, if applicable) - the information in the assessments and notes fields shall include remarks about the module, and briefly explain how the requirement is passed, failed, or not applicable. If specific guidance was issued by NIST and CSE for this cryptomodule during validation testing, then this guidance shall be addressed in the appropriate area(s) of the report.

2. A non-proprietary version of the cryptographic module's SECURITY POLICY. For an explanation of this, see the guidance "Cryptomodule security policy" in Section 1 of this document.

3. (IF APPLICABLE) A non-proprietary version of the laboratory's physical testing report, for cryptomodules with physical security at level 2 and above.

4. In addition to items 1-3 above, the lab has the option to provide proprietary versions of those items, but this is not required by NIST and CSE.

Additional Comments

G.3 Partial validations

Question/Problem

Resolution

Additional Comments

G.4 Design and testing of cryptographic modules

Question/Problem

Resolution

1. A CMT Laboratory may not perform validation testing on a module for which the laboratory has:
   1. designed any part of the module,
   2. developed original documentation for any part of the module,
   3. built, coded or implemented any part of the module, or
   4. any ownership or vested interest in the module.

2. Provided that a CMT Laboratory has met the above requirements, the laboratory may perform validation testing on modules produced by a company when:
   1. the laboratory has no ownership in the company,
   2. the laboratory has a completely separate management from the company, and
   3. business between the CMT Laboratory and the company is performed under contractual agreements, as done with other clients.

3. A CMT Laboratory may perform consulting services to provide clarification of FIPS 140-1, the Derived Test Requirements, and other associated documents at any time during the life cycle of the module.

Additional Comments

G.5 Maintaining validation compliance of software cryptographic modules

Question/Problem

Resolution

1. The tested/validated configuration is stated on the validation certificate. The certificate serves as the benchmark for the module-compliant configuration.

2. For level 1 Operating System Security, the software cryptomodule will remain compliant with the FIPS 140-1 validation when operating on any general purpose computer (GPC) provided that:
   1. the GPC uses the specified single user operating system/mode specified on the valiation certificate, or another compatible single user operating system, and

   2. the software of the cryptomodule does not require modification when ported (platform specific configuration modifications are excluded).

3. For level 2 Operating System Security the software cryptographic module will remain compliant with the FIPS 140-1 validation when operating on any GPC provided that:
   1. the GPC incorporates the specified evaluated C2 (or equivalent) operating system/mode/operational settings or another compatible evaluated C2 (or equivalent) operating system with like mode and operational settings, and

   2. the software of the cryptographic module does not require modification when ported (platform-specific configuration settings are excluded).

Additional Comments

G.6 Modules with both a FIPS mode and a non-FIPS mode

Applicable Levels:	ALL
Effective Dates:	3/11/98-
Last Modified:	4/2/98
Relevant Assertions:	General
Relevant Test Requirements:
Relevant Vendor Requirements:

Question/Problem

Resolution

The FIPS 140-1 validation certificate will identify the cryptomodule's "FIPS mode" of operation.

The selection of "FIPS mode" does not have to be restricted to any particular operator of the module. However, each operator of the module must be able to determine whether or not the "FIPS mode" is selected.

There is no requirement that the selection of a "FIPS mode" be permanent.

Additional Comments

G.7 Relationships Among Vendors, Laboratories, and NIST/CSE

Applicable Levels:	ALL
Effective Dates:	4/14/98-
Last Modified:
Relevant Assertions:	General
Relevant Test Requirements:
Relevant Vendor Requirements:

Question/Problem

Policy

In a situation where the vendor and laboratory are at an unresolvable impasse over a testing issue, the vendor may ask for clarification/resolution directly from NIST/CSE. The vendor should use the format required by Implementation Guidance G.1 and the point of contact at the laboratory must be carbon copied. All correspondence from NIST/CSE to the vendor on the issue will be issued through the laboratory point of contact.

Additional Comments

• Part 2: Sections 1-4
• Part 3: Sections 5-7
• Part 4: Sections 8-11
• Part 5: Expired Guidance