EAC Decision on Request for Interpretation 2010-04 

(Functional Requirements with respect to Security) 

2002 VSS Volume I: 2.2.1 Security 

2005 VVSG Volume I: 2.1.1 Security 

Date: 

June 24, 2010 

Question: 

Does the first sentence in the Functional Requirements Section with respect to Security allow the 

security requirements, a through f, in that section to be adhered to solely by administrative 

practices/procedural safeguards? 

Section of Standards or Guidelines: 

2002 VSS VI: 2.2.1 

2.2.1 Security 

System security is achieved through a combination of technical capabilities and sound administrative 

practices. To ensure security, all systems shall: 

a. Provide security access controls that limit or detect access to critical system components to guard 

against loss of system integrity, availability, confidentiality, and accountability. 

b. Provide system functions that are executable only in the intended manner and order, and only under the 

intended conditions. 

c. Use the system's control logic to prevent a system function from executing if any preconditions to the 

function have not been met. 
d. Provide safeguards to protect against tampering during system repair, or interventions in system 

operations, in response to system failure. 

e. Provide security provisions that are compatible with the procedures and administrative tasks involved 

in equipment preparation, testing, and operation. 

f. If access to a system function is to be restricted or controlled, the system shall incorporate a means of 

implementing this capability. 

g. Provide documentation of mandatory administrative procedures for effective system security.

2005 VVSG VI: 2.1.1 

2.1.1 Security 

System security is achieved through a combination of technical capabilities and sound 

administrative practices. To ensure security, all systems shall: 

a. Provide security access controls that limit or detect access to critical system components to 

guard against loss of system integrity, availability, confidentiality, and accountability 

b. Provide system functions that are executable only in the intended manner and order, and only 

under the intended conditions 

c. Use the system's control logic to prevent a system function from executing if any 

preconditions to the function have not been met 

d. Provide safeguards in response to system failure to protect against tampering during system 

repair or interventions in system operations 

e. Provide security provisions that are compatible with the procedures and administrative tasks 

involved in equipment preparation, testing, and operation 

f. Incorporate a means of implementing a capability if access to a system function is to be 

restricted or controlled 

g. Provide documentation of mandatory administrative procedures for effective system security 

Discussion: 

The posed question centers on the meaning and impact of the statement “System security is 

achieved through a combination of technical capabilities and sound administrative practices.” 

The above statement is a statement of fact and contains no normative language. On the other 

hand, statements a through g (within Section 2.2.1 of the 2002 VSS and Section 2.1.1 of the 2005 

VVSG) are preceded by the keyword SHALL and are, in fact, normative. Administrative 

practices are used to ensure that technical/system capabilities that provide security are 
implemented properly. It is considered poor security practice to use policy and procedures in lieu 

of system capabilities/functions that can prevent, deter, or detect security violations. 

Conclusion: 

“System security is achieved through a combination of technical capabilities and sound 

administrative practices” is not normative and shall not be used to justify using policy and/or 

administrative procedures, in lieu of voting system capabilities/functions, to meet requirements 

in a through f above. In conforming to all requirements in the VSS/VVSG, including the 

requirements cited above, voting systems, through system capabilities/functions, or (only for 

documentation requirements) via its associated documentation (TDP), shall be capable of 

meeting the specific requirements in the applicable standard. These system 

capabilities/functions may be supported with administrative procedures or procedural safeguards 

that are, or are planned to be, in place, as required by requirement g. However, administrative 

practices/procedural safeguards are not solely sufficient to fulfill the normative requirements a 

through f. It is only with both system security features and administrative procedures that 

effective system security can be achieved. 

Applicability:

This is effective for all Test Plans approved after this date.