On Tue, 2009-09-01 at 11:20 -0400, Steve Marquess wrote:
> Mark Phalan wrote:
> >  ...
> >
> > > As you noted the incorporation of fipscanister.o in a FIPS capable
> > > OpenSSL displaces the corresponding FIPS allowed algorithms of the
> > > latter.  While we retain functional equivalence (goal 1 above) any
> > > platform optimizations or other improvements of the newer
> > > implementations are lost.  The nature of this interface is such
> > > that we can't easily avoid this displacement within the constraints
> > >  of the existing fipscanister.o interface and 0.9.8 versioning
> > > rules.
> >
> >  Do you think delivering two versions of libcrypto in this case is a
> >  reasonable workaround?
> 
> It's the simplest solution in your case, even though it's the outcome 
> our design hoped to avoid.

Ok.

> 
> > > I should also note that developments in FIPS 140-2 testing
> > > requirements for 2010 mean that even the existing v1.2 module will
> > > no longer be compliant.  The commercial vendors who have been
> > > obtaining "private label" validations based on v1.2 will find that
> > > those validations will no longer be rubber stamp formalities as is
> > > the case today.
> >
> >  Can you point me to more information about this? Does this mean that
> >  delivering a FIPS Capable OpenSSL (v1.2) as part of an OS will be
> >  essentially worthless to users of that OS in 2010?
> 
> Well, I have a mixed track record in forecasting future CMVP actions so 
> take my speculations accordingly.
> 
> The CMVP typically does not revoke or invalidate extant validations 
> simply because the criteria for new validations have changed (though I 
> should note past OpenSSL FIPS Object Module validations have been 
> effectively revoked).  So presumably the current #1051 validation will 
> remain in effect through 2010 for those electing to use it directly.  
> Emphasis on presumably, as the OpenSSL open source based validations are 
> *not* typical.  So assuming you base your deliverables on already 
> awarded validated products you *should* be OK.
> 
> However, it has been common practice for vendors to take the same v1.2 
> source code and documentation and obtain their own copy-cat or "private 
> label" validation.  There are a number of practical and marketing 
> reasons why such duplicate validations are desirable (minimizing the 
> risk of exposure to the fate of validations #642 and #733 being first 
> and foremost).  Those copy-cat validations will no longer be possible 
> with the as-is v1.2 source.
> 
> At one point in time we thought that we would have, though sponsorships 
> brokered by the Open Source Software Institute, long term funding for an 
> ongoing series of periodic (annual or semi-annual) "rolling" 
> validations.  That would have maintained availability of a reasonably 
> current product for direct use or as a model for private label use, and 
> would also have allowed us to work in the desired architectural changes 
> over several validations.  Unfortunately that prospect fell through and 
> at this point we have no plans for any future validations.
> 
> Private label validations will continue but will require increasing 
> amounts of modification to the v1.2 source code and documentation as the 
> validation requirements are extended.  We could merge those changes back 
> into the shared baseline code and docs, but to date we have received 
> very few contributions of that sort.  So what is currently a community 
> resource will gradually revert back to a roll-your-own situation, same 
> as it was before the first open source based validation.

Ok.

Thanks for all the information.

-M

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