Why: Default-deny with permit-by-exception is the traffic policy strict OT segmentation enforces at the IT/OT boundary and between zones — the practice's mature state is exactly this requirement's posture, applied to the plant.
What this does not claim: May partially address the requirement, and only for OT components within the assessed CUI boundary — organizational scoping determines applicability. The requirement covers the whole system's network communications, including the IT estate the practice never touches, and deny-by-default on a live control network is reached incrementally: learn the real traffic in permit-and-log mode first, then tighten in planned windows with the process owner, because a missed permit rule can stop production or sever a safety-relevant flow.
- Move the IT/OT boundary and inter-zone conduits to default-deny with a documented exception list
- Learn legitimate traffic in permit-and-log mode before enforcing
- Review every broad permit rule on a cadence, with expiry dates on exceptions
- Boundary and conduit rule exports showing deny-by-default with justified exceptions
- The dated exception list with owners and expiry dates
- Change records for tightening steps, with process-owner sign-off
Where this holds: Holds for OT zones and conduits inside the assessed boundary; the requirement's IT-side scope needs separate treatment.
Review status: Technical review complete · Reviewed by External source-validation review, 2026-08-06 — directed remapping of OT segmentation from 3.13.5 to 3.13.1/3.13.6 · updated 2026-08-06