Office of Inspector General

U.S. Environmental Protection Agency

At a Glance

23-E-0016
May 2, 2023

Contractor-Produced Report: The CSB Is at Increased Risk of Losing
Significant Data as Vulnerabilities Are Not Identified and Remediated
Timely

Why This Evaluation Was Done
To accomplish this objective:

This evaluation was performed to assess
the U.S. Chemical Safety and Hazard
Investigation Board's compliance with
the U.S. Department of Homeland
Security's Fiscal Year 2022 Inspector
General Federal Information Security
Modernization Act of 2014 Reporting
Metrics.

SB & Company LLC was contracted to
perform this evaluation under the
direction and oversight of the
U.S. Environmental Protection Agency
Office of Inspector General.

The reporting instructions outline
five security function areas and
nine corresponding domains to help
federal agencies manage cybersecurity
risks. The document also outlines five
maturity levels by which inspectors
general should rate their agencies'
information security programs:

•	Level 1 (Ad-Hoc).

•	Level 2 (Defined).

•	Level 3 (Consistently
Implemented).

•	Level 4 (Managed and
Measurable).

•	Level 5 (Optimized).

To support this CSB mission-related
effort:

• Drive chemical safety change
through independent investigations
to protect people and the
environment.

Address inquiries to our public affairs

office at (202) 566-2391 or

OIG WEBCOMMENTS@epa.gov.

The lack of vulnerability
scans increases the risk
that vulnerabilities are not
identified and remediated
in a timely manner and
could result in data loss
or disruption to Agency
operations.

What SB & Company Found

SB & Company concluded that the CSB
achieved an overall maturity level of Level 1 (Ad-
Hoc). This means that the CSB policies,
procedures, and strategies are not formalized
and activities are performed in an ad-hoc,
reactive manner. While SB & Company
assessed the effectiveness of the CSB's
information security program at Level 2
(Defined), the FY2022 Core IG Metrics

Implementation Analysis and Guidelines directs OIGs to consider specific core
metrics when assigning the calculated maturity level for the CyberScope
scoring. Because the core questions of the FY 2022 metrics were rated Level 1,
the CSB's overall calculated maturity level resulted in a Level 1 CyberScope
rating.

SB & Company also noted that the CSB discontinued the monthly vulnerability
scans. This increases the risk that vulnerabilities are not identified and
remediated timely and could result in data loss and disrupt the CSB's
operations. This issue was previously identified in OIG Report No. 22-N-0058,
Management Alert: Data Vulnerabilities Could Impact the CSB's Ability to Carry
Out Its Obligations Under the Federal Information Security Modernization Act of
2014 (Contractor-Produced Report), issued September 22, 2022. The report
summarized deficiencies SB & Company identified during the FY 2022 FISMA
evaluation that required management's immediate attention, some of which
were outside of the CyberScope questions. At the time of the evaluation, the
CSB did not have a chief information officer or proper management oversight
and, due to limited resources and staffing issues, the monthly vulnerability
scans were discontinued. As a result, if the vulnerabilities are exploited in a
cyberattack, the data could be permanently lost and impact the CSB's ability to
fulfill its mission.

Recommendations and Planned Agency Corrective Actions

SB & Company made one recommendation to the CSB, and the OIG agrees
with and adopts this recommendation. The CSB agreed with the
recommendation and provided acceptable corrective actions. The OIG
considers the corrective actions completed.

List of OIG reports.


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