Limit Physical Access
Limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals.
What an assessor scores, the objectives
PE.L2-3.10.1 is met only when every one of these 4 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.
- a.authorized individuals allowed physical access are identified
- b.physical access to organizational systems is limited to authorized individuals
- c.physical access to equipment is limited to authorized individuals
- d.physical access to operating environments is limited to authorized individuals
How a C3PAO checks it
NIST SP 800-171A defines three assessment methods. For PE.L2-3.10.1, an assessor uses these:
Physical and environmental protection policy; procedures addressing physical access authorizations; system security plan; authorized personnel access list; authorization credentials; physical access list reviews; physical access termination records and associated documentation; other relevant documents or records
Personnel with physical access authorization responsibilities; personnel with physical access to system facility; personnel with information security responsibilities
Organizational processes for physical access authorizations; mechanisms supporting or implementing physical access authorizations
What it means, in context
This requirement applies to employees, individuals with permanent physical access authorization credentials, and visitors. Authorized individuals have credentials that include badges, identification cards, and smart cards. Organizations determine the strength of authorization credentials needed consistent with applicable laws, directives, policies, regulations, standards, procedures, and guidelines. This requirement applies only to areas within facilities that have not been designated as publicly accessible. Limiting physical access to equipment may include placing equipment in locked rooms or other secured areas and allowing access to authorized individuals only , and placing equipment in locations that can be monitored by organizational personnel. Computing devices, external disk drives, networking devices, monitors, printers, copiers, scanners, facsimile machines, and audio devices are examples of equipment.
This addresses the company ’s physical space (e.g., office, testing environments, equipment rooms), technical assets, and non- technical assets that need to be protected from unauthorized physical access. Specific environments are limited to authorized employees , and access is controlled with badges, electronic locks, physical key locks, etc. Output devices, such as printers, are placed in areas where their use does not expose data to unauthorized individuals. Lists of personnel with authorized access are developed and maintained, and personnel are issued appropriate authorization credentials. Example You manage a DoD project that requires special equipment used only by project team members [b,c]. You work with the facilities manager to put locks on the doors to the areas where the equipment is stored and u sed [b,c,d]. Project team members are the only individuals issued with keys to the space. This restricts access to only those employees who work on the DoD project and require access to that equipment. Potential Assessment Considerations • Are lists of personnel with authorized access developed and maintained, and are appropriate authorization credentials issued [a]? • Has the facility/building manager designated building areas as “sensitive” and designed physical security protections (e.g., guards, locks, cameras, card readers) to limit physical access to the area to only authorized employees [b,c,d]? • Are output devices such as printers placed in areas where their use does not expose data to unauthorized individuals [c]?
What passing evidence looks like
The authorized people list per physical area where CUI lives or is visible, and the physical limit itself: locks, badge readers, or a controlled single entrance, photographed.
Common ways contractors fail PE.L2-3.10.1
- !Home offices count when CUI is worked there, the authorized list can be one name and the lock is the front door plus a locked office. Say it plainly rather than pretending an office you do not have.
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Prove PE.L2-3.10.1, and the other 109
The Level 2 Accelerator walks all 110 requirements with you, generates your SSP, POA&M, and Audit Room from real evidence, includes the full Level 1 platform, and puts a credentialed officer alongside you for 180 days. Filed in 180 days, or we work free until you are.
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PE.L2-3.10.1 questions, answered
How many points is CMMC requirement PE.L2-3.10.1 worth?+
PE.L2-3.10.1 is worth 5 points in the CMMC Level 2 score under 32 CFR 170.24. If it is not met, you lose 5 from your total of 110.
Can PE.L2-3.10.1 be placed on a POA&M?+
No. PE.L2-3.10.1 must be fully met before you can file. It cannot be deferred to a POA&M, so it is a gate on your assessment.
What family does PE.L2-3.10.1 belong to?+
PE.L2-3.10.1 is in the Physical Protection (PE) family, one of the 14 families of NIST SP 800-171 that make up CMMC Level 2.
- NIST SP 800-171 Rev. 2 3.10.1
- FAR Clause 52.204-21 b.1.viii