21 Code For Federal Regulation Parts 1305, 1311 Page 15
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67stress that once a supplier has validated a signature on an order, it is not necessary to re-validate
the signature prior to actually shipping the order to the purchaser.
Time period for reporting key compromise or loss of privilege. Commenters objected to
the requirement that they report loss, theft, or compromise of the key within 24 hours of such
loss, theft, or compromise, and that they report a certificate holder’s loss of signing privilege
within six hours. They also stated that they wanted to be able to report loss of signing privilege
in advance (e.g., when they learn an employee will be leaving the firm on a certain date). They
stated that the 24-hour and 6-hour time frames were unrealistic and could result in notifications
filed outside of business hours.
Registrants may notify the CA in advance of revocations. DEA agrees that the 24-hour
period should be within 24 hours of substantiation of key compromise, etc., and has changed the
rule. On the 6-hour notification, DEA disagrees with the commenters. DEA believes it is
important that the CA be notified as soon as someone’s signing privileges are revoked. The
digital certificate is the equivalent of a Form 222 – a former employee still in possession of their
digital certificate and keys would have all they needed to generate orders that would be
otherwise indistinguishable from legitimate orders. In the paper world, this concern does not
exist since a former employee would no longer have access to the order forms and, thus, could
not engage in any mischief. DEA notes that the CA will be staffed 24/7 so there is no need to
wait until the next business day. An e-mail to the CA that is digitally signed by the coordinator
or registrant will be sufficient notification.
Certification Authority. Commenters raised concerns about the DEA CA being run by a
contractor and asked about the safety of information. DEA emphasizes that although a
contractor may be used to carry out the day-to-day operations of the CA, the contractor will
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