Statement:

The CM system is the procedures for managing the TOE. CM documentation describes the CM system. The intent of  RI-99 is agreed upon by the CCIMB, but not the specific approach.

The national interpretation identifies confusion between the terms "CM system", "CM documentation", and "configuration list". After intense discussion, the CCIMB agrees that these terms -- as well as others used throughout ACM -- are inconsistently used and therefore confusing. The CCIMB believes that all of the terms in ACM will have to be revisited and defined precisely, and the whole of ACM updated accordingly. However, rather than waiting for the opportunity to correct the whole of ACM, the CCIMB provides the following as an interim response:

Although the related discussions are still on-going, the CCIMB currently has the general opinion that a "CM system" is the set of procedures and technical means used to identify and maintain control over the TOE. (At its most basic level, a CM system may simply be the means used to identify the items comprising the TOE plus its associated identification method(s); at higher levels, a CM system may include automated tools to aid in the processing, with change control, and other tracking procedures.) The "CM documentation" describes this CM system. The "configuration list" identifies and describes the set of items that are controlled under the CM system. During its discussion, the CCIMB realised there is no unanimous opinion concerning whether the configuration list is part of the CM system (rather than its output), nor a unanimous view on the difference between a non-automated CM system and the CM documentation that describes it.