(a) If supported, a system may utilize writable program storage technology to update interface element software if all of the following requirements are met:
(1)
- (A) Writable program storage functionality must be, at a minimum, password-protected, and should be at a supervisor level.
- (B) The system can continue to locate and verify versions currently running but it cannot load code that is not currently running on the system without user intervention;
(2)
- (A) A nonalterable audit log must record the time/date of a writable program storage download and some provision must be made to associate this log with which version or versions of code was downloaded, and the user who initiated the download.
- (B) A separate download audit log report would be ideal; and
(3)
- (A) All modifications to the download executable or other file or files must be submitted to the test laboratory for approval.
- (B) The laboratory will assign signatures to any relevant executable code and file or files that should be verified by a regulator in the field.
- (C) Additionally, all downloadable files must be available to a regulator to verify the signature; and
- (4) The system must have the ability to verify the program on demand for regulatory audit purposes.
(b)
- (1) The above refers to loading of new system executable code only.
- (2) Other program parameters may be updated as long as the process is securely controlled and subject to audit.
- (3) The parameters will have to be reviewed on an individual basis.