Blue Goat CyberBlue Goat CyberSMMedical Device Cybersecurity
    K
    FAQ

    Medical device cybersecurity, answered.

    Straight answers about FDA expectations, SBOMs, threat modeling, pen testing, postmarket obligations, and how Blue Goat Cyber engagements work.

    About Blue Goat Cyber

    What does Blue Goat Cyber specialize in?

    Blue Goat Cyber specializes in medical device cybersecurity, offering tailored solutions for premarket and postmarket compliance, vulnerability mitigation, and patient safety.

    Why is the company called Blue Goat Cyber?

    Founder Christian Espinosa named the company after his experiences as an avid mountain climber. Mountain goats represent resilience, focus, and determination. Blue symbolizes trust, clarity, and limitless potential.

    Who are your services designed for?

    We exclusively serve medical device manufacturers - startups, mid-sized companies, and global leaders - across the full product lifecycle.

    What is your guarantee?

    We stand by our work with a 100% success guarantee. If your submission is delayed due to a cybersecurity deficiency, we resolve it at no additional cost until approved.

    What sets you apart?

    Unlike general cybersecurity firms, we focus solely on medical devices. Deep fluency with the FDA's 2026 premarket cybersecurity guidance, ANSI/AAMI SW96, ISO 13485, and ISO 14971 drives every engagement.

    What types of devices do you work with?

    IVD and diagnostics, wearables, implantables, robotic surgical systems, SaMD, and legacy devices requiring updated cybersecurity measures.

    What certifications does your team hold?

    CISSP, CSSLP, OSCP, CRTE, CARTP, and others - with experience spanning medical device cybersecurity, military cyber operations, and government red team testing.

    How many FDA submissions has your team supported?

    Our team has contributed cybersecurity documentation, threat models, SBOMs, and pen test reports to 250+ FDA submissions across 510(k), De Novo, and PMA pathways. See the /proof page for the breakdown.

    Do you sign NDAs and BAAs before engaging?

    Yes. We routinely sign mutual NDAs, MSAs, and BAAs prior to receiving any device, source code, or PHI. Most NDAs are turned around in under 48 hours.

    FDA Section 524B & 2026 Premarket Guidance

    What is FDA Section 524B and who does it apply to?

    Section 524B of the FD&C Act (added by the Omnibus 2023 act) requires premarket submissions for 'cyber devices' to include a Secure Product Development Framework (SPDF), a Software Bill of Materials (SBOM), and evidence of vulnerability monitoring and patching. It applies to any device with software that can connect to the internet or another device.

    What changed with the FDA's February 3, 2026 final guidance?

    The 2026 final guidance replaces the 2023 version and clarifies expectations around SPDF artifacts, threat modeling rigor, SBOM machine-readability (SPDX or CycloneDX), and the level of evidence reviewers expect for security risk management. Submissions filed after that date are reviewed against the new bar.

    What is a Secure Product Development Framework (SPDF)?

    An SPDF is a documented set of processes that integrates security across the product lifecycle - design inputs, threat modeling, secure coding, verification, release, and postmarket monitoring. The FDA expects evidence that the SPDF is followed, not just that it exists.

    Do I need a separate cybersecurity submission for an eSTAR 510(k)?

    No - cybersecurity artifacts are embedded inside the eSTAR template. We deliver SBOM, threat model, security risk assessment, architecture views, and pen test report in formats that drop directly into the relevant eSTAR sections.

    SBOMs & Supply Chain

    What SBOM format does the FDA accept?

    The FDA accepts machine-readable SBOMs in SPDX 2.3+ or CycloneDX 1.4+ formats. We typically deliver CycloneDX 1.5 with VEX statements so reviewers can see which CVEs are exploitable in your device's context.

    Do you generate SBOMs for firmware and embedded devices?

    Yes. For embedded and RTOS-based devices we combine binary analysis (e.g., Binwalk, Ghidra-assisted extraction) with build-time SCA to produce a complete SBOM, including third-party libraries, bootloaders, and OS components.

    How do you handle CVEs that show up after submission?

    We issue VEX (Vulnerability Exploitability eXchange) statements indicating whether each CVE is exploitable, under investigation, or not affected. This is the FDA-preferred way to manage the noise from continuous vulnerability scanning.

    Threat Modeling & Pen Testing

    What threat modeling methodology do you use?

    We default to STRIDE-per-element with attack trees for high-risk flows, aligned to AAMI TIR57 and the FDA's 2026 guidance. For complex SaMD or connected ecosystems we layer in PASTA or LINDDUN (privacy) where appropriate.

    What does a medical device penetration test actually cover?

    Manual exploitation against the device interfaces (USB, serial, JTAG, BLE, Wi-Fi, cellular), companion apps (iOS/Android), cloud APIs and back-end, firmware extraction and reverse engineering, and the surrounding infrastructure - mapped to your threat model.

    Is automated scanning enough for FDA submissions?

    No. The FDA explicitly expects manual, exploit-driven testing by qualified humans. Automated scans (Nessus, Burp Active Scan, etc.) are part of our toolkit but never the deliverable on their own.

    Do you offer free retesting after we fix findings?

    Yes. Every premarket pen test includes one round of remediation retest at no additional cost so your final report shows resolved findings - what reviewers want to see.

    Postmarket, Legacy & Global

    What does an FDA-aligned postmarket program look like?

    Continuous SBOM/CVE monitoring with VEX, a coordinated vulnerability disclosure (CVD) policy, a defined patch validation cadence, and pre-built templates for FDA reportable event communications and customer advisories.

    Can you bring a legacy device into compliance?

    Yes. We perform a gap assessment against current FDA expectations, build a remediation roadmap, generate the missing artifacts (SBOM, threat model, security risk assessment), and harden the device or compensate via mitigations where redesign isn't feasible.

    How do you handle EU MDR and the Cyber Resilience Act?

    Our deliverables map to EU MDR Annex I GSPR 17.2, MDCG 2019-16, IEC 81001-5-1, and the upcoming EU Cyber Resilience Act essential requirements. One engagement typically satisfies FDA, EU, Health Canada, TGA, and PMDA expectations.

    Do you support AI/ML-enabled SaMD specifically?

    Yes. We address model-specific risks (data poisoning, model inversion, adversarial inputs, prompt injection for LLM-based features) alongside traditional device security, aligned with the FDA's PCCP and AI/ML guidance.

    Premarket Services

    What premarket services do you offer?

    Penetration testing, SBOM management, threat tree development, SAST, secure design consulting, and FDA deficiency response.

    Why is penetration testing critical?

    It identifies vulnerabilities in software, hardware, and networks, ensuring your device meets FDA cybersecurity requirements and is resilient to real threats.

    What is SBOM management?

    SBOM management tracks vulnerabilities in third-party and open-source software, aligning with the FDA's 2026 premarket guidance and ANSI/AAMI SW96 supply chain expectations.

    How do you handle FDA deficiencies?

    Rapid analysis, targeted remediation, updated documentation, and resubmission strategy - most deficiencies closed on first resubmission.

    How fast can you respond to an FDA deficiency letter?

    We typically deliver a complete deficiency response package within 2–4 weeks of receiving the letter and source materials, depending on scope. Rush engagements (under 2 weeks) are available.

    Postmarket Services

    What postmarket services do you provide?

    Real-time threat monitoring, patch management, incident response, and legacy device security to keep your devices compliant after approval.

    Why is postmarket cybersecurity important?

    Threats evolve after FDA clearance. Postmarket cybersecurity ensures ongoing compliance, protects patient safety, and safeguards your devices throughout their lifecycle.

    Can you secure devices used globally?

    Yes - we align with international standards including ISO 13485, ISO 14971, ANSI/AAMI SW96, IEC 81001-5-1, EU MDR, Health Canada, TGA, PMDA, and IMDRF guidance.

    Working with Us

    How do I get started?

    Schedule a free 30-minute Discovery Session. We assess your needs and create a tailored strategy.

    How much do your services cost?

    Transparent, fixed-fee pricing based on device complexity and scope. No surprises - you can budget confidently.

    How long do projects take?

    Most premarket projects (penetration testing, documentation) complete within 4–8 weeks.

    How quickly can you start?

    We typically begin engagements within 1–2 weeks of contract signature, depending on scope.

    Who actually does the work - employees or subcontractors?

    All testing and documentation is performed by Blue Goat Cyber W-2 employees and vetted long-term partners under our direct supervision. We never offshore deliverables to anonymous contractors.

    How do you protect our IP and source code?

    Source code, firmware, and devices are handled in isolated, encrypted environments with access limited to the named engineers on your engagement. All artifacts are destroyed or returned at project close per your data handling requirements.

    Can you work under our quality management system?

    Yes. We routinely operate as an external supplier under ISO 13485 QMS arrangements, complete supplier qualification questionnaires, and provide objective evidence for audits.

    Keep exploring

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    Ready when you are

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    30-minute strategy session. No cost, no commitment - just answers from people who've shipped 250+ submissions.