locations · irvine

Device makers now owe FDA a cybersecurity plan with each submission. Identity is a large part of it.

The Orange County Business Council ranks the county first in the US for medical device manufacturing. FDA now expects them to show how they will monitor, patch and control access to connected products. In Irvine that work sits beside hospital, car and game company systems with identity problems of their own.

in short·20-second read

Around Irvine we work with medical device makers, health systems and consumer companies such as automotive and game publishers.

For device makers that means identity for field service staff and connected devices, SBOM and vulnerability data pipelines, and evidence for FDA cybersecurity submissions. For providers it means governance across clinical and research staff. Cohash works from Frisco, Texas, serves Orange County remotely and flies in for workshops and launches.

Cohash has no Irvine or Orange County office. We're headquartered in Frisco, Texas, run these engagements remotely and travel to Orange County for design workshops, device lab sessions and launches.

Ask an engineer facts checked 2026-10-21 · 8 sources
rules
FD&C Act section 524B, cyber device requirementsCalifornia data breach law, Civil Code §1798.82Confidentiality of Medical Information ActCCPA, consumer accounts and connected products
who and what

Who we work with in Irvine, Orange County, and the rules they work under

industries
  1. Medical device manufacturers

    Connected devices, the service tools that program them and the cloud portals clinicians use all carry identities. We set up certificate-based device identity, named and time-limited access for field service engineers, and pipelines that feed SBOM and vulnerability data into the postmarket monitoring your section 524B plan describes.

  2. Health systems and academic medicine

    Faculty physicians, residents and researchers often hold clinical, teaching and research accounts at once. We merge those into one identity record with role-based access tied to credentialing and appointment status, so research data access ends when a protocol closes.

  3. Automotive and game companies

    Consumer brands in the county run large account systems for connected-car apps, dealer portals and player profiles. Credential stuffing and account takeover are a daily problem. We build customer identity with passkeys, bot detection and fraud signals that the support desk can act on.

regulations
  1. FD&C Act section 524B, cyber device requirements ↗

    In effect since 29 March 2023. Premarket submissions for cyber devices must include a plan to monitor and address postmarket vulnerabilities, processes that give reasonable assurance the device is secure, and a software bill of materials. FDA's final premarket cybersecurity guidance was reissued on 27 June 2025.

  2. California data breach law, Civil Code §1798.82 ↗

    A device maker, provider or retailer that loses Californians' personal data has 30 calendar days from discovery to notify them, a rule in force since 2026. Notices to more than 500 residents also need a sample filed with the Attorney General within 15 days after residents are told.

  3. Confidentiality of Medical Information Act ↗

    Covers providers and health plans, and also businesses offering software or hardware designed to maintain medical information, which can include connected health apps tied to a device. It restricts disclosure without the patient's authorization.

  4. CCPA, consumer accounts and connected products ↗

    Car, game and device companies collecting Orange County consumers' data must honor access, deletion and opt-out requests. Precise geolocation from connected vehicles counts as sensitive personal information, and the 2026 regulations add risk assessments for that kind of processing.

01What does FDA expect on access control for a connected device?

The premarket guidance asks manufacturers to describe authentication and authorization for device interfaces, including service and maintenance access. In practice that means no shared hard-coded passwords, unique credentials or certificates per device, and a way to revoke a technician's access. We design those controls and the documentation that explains them.

02Can you build the SBOM pipeline for our devices?

We build the data side. SBOMs generated in your build systems feed a store that matches components against vulnerability sources, and the results route to the product security team with device and version context. Decisions on patching and FDA reporting stay with your regulatory and quality teams.

03Our connected-car app gets hit with credential stuffing every weekend. What helps fastest?

Bot detection at the login edge and breached-password checks usually cut the volume within weeks. Passkeys take longer because customers adopt them gradually, but each enrollment removes a password that can be stuffed.

04Does the CMIA apply to a device company or only to hospitals?

It can apply to a device company that offers software or hardware designed to maintain medical information for consumers or providers. Whether your product qualifies is a question for counsel, and we can document what health data the product stores and who can reach it.

sources 8 sources linked last checked 2026-10-21 content fingerprint 39522dd4
  1. 01BLS, Santa Ana-Anaheim-Irvine economy at a glancebls.gov ↗
  2. 02Orange County Business Councilocbc.org ↗
  3. 03UC Irvine, facts and figuresuci.edu ↗
  4. 04FDA, cybersecurity in medical devicesfda.gov ↗
  5. 05California Civil Code §1798.82leginfo.legislature.ca.gov ↗
  6. 06Pillsbury, California SB 446 breach notification changespillsburylaw.com ↗
  7. 07California Civil Code §56.06 (CMIA)leginfo.legislature.ca.gov ↗
  8. 08California Privacy Protection Agency, regulationscppa.ca.gov ↗
Reviewed by the Cohash team Product names are trademarks of their owners. how we handle facts and data →
next step

Tell us what you're running. We'll tell you what we'd do first.

A 30-minute working session with a senior engineer. No slides.

useful to bring
  • The platform and the version you're on
  • Where you need to get to, and by when
  • What's custom: rules, plugins, integrations
  • Any audit finding or deadline driving it