SR-10: Inspection of Systems or Components

SR-10 sits in the NIST SP 800-53 Supply Chain Risk Management (SR) family and focuses on a simple outcome: find tampering before tampering finds you. For a CCO, GRC lead, or Compliance Officer, the practical challenge is that “inspection” can become vague fast. Auditors will not accept “we visually check things sometimes” or “our data center has cameras.” They will look for a defined scope, repeatable methods, and evidence that inspections actually detect tampering indicators and drive response actions.

This requirement is easiest to implement if you treat it like an operations control rather than a paper policy. You need (1) a scoped list of systems/components that matter for your mission and threat model, (2) an inspection method appropriate to the asset type (physical, firmware, configuration, supply chain custody), and (3) documented results with remediation workflows. If you rely on third parties (cloud, colocation, OEMs, managed service providers), SR-10 also becomes a contract and assurance problem: you still need inspection coverage, even if execution is delegated.

Regulatory text

Requirement (excerpt): “Inspect the following systems or system components [organization-defined frequency/parameters] to detect tampering: [organization-defined systems/components].” ¹

Operator interpretation: You must (a) name the systems/components you will inspect, (b) perform inspections capable of detecting tampering, and (c) do it on a defined schedule or trigger. The “organization-defined” parts are not optional; they are the decision points you must document and then execute.

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Plain-English interpretation (what SR-10 is really asking)

SR-10 expects you to systematically check critical systems and components for signs of unauthorized modification. “Tampering” includes physical interference (opened chassis, swapped components), logical manipulation (unexpected firmware changes, unauthorized configuration changes), and supply chain interference (components arriving with broken seals, altered packaging, or unexplained provenance gaps).

A strong SR-10 implementation answers four questions clearly:

1. What is in scope? List systems and components where tampering would materially impact confidentiality, integrity, availability, safety, or mission outcomes.
2. What does inspection mean for that asset? Visual inspection, seal checks, configuration baselines, firmware attestation, inventory reconciliation, or chain-of-custody validation.
3. How often and when? Recurring cadence plus event-driven triggers (receipt, maintenance, incident, relocation, unexplained outage).
4. What happens if something is off? Quarantine, preserve evidence, investigate, notify stakeholders, and remediate.

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Who it applies to (entity and operational context)

SR-10 is typically applicable where you are expected to align to NIST SP 800-53, including:

• Federal information systems and the organizations operating them.
• Contractor systems handling federal data (including environments supporting federal programs) ².

Operationally, SR-10 applies most directly to:

• Data centers, network rooms, and wiring closets (physical components, racks, network gear).
• End-user fleets where device integrity matters (executive endpoints, privileged admin workstations).
• High-impact infrastructure (identity systems, key management/HSMs, logging pipelines).
• Build and deployment pipelines (where unauthorized changes can propagate quickly).
• Environments with significant third-party involvement (OEM hardware, MSP-managed networks, colocation, cloud-managed appliances).

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What you actually need to do (step-by-step)

1) Assign control ownership and RACI

• Control owner: usually Security Operations, IT Infrastructure, or Data Center Operations; GRC owns governance.
• Define who can perform inspections, who reviews results, and who approves exceptions.
• Map SR-10 to an operational procedure and recurring evidence artifacts ².

Deliverable: SR-10 control record (owner, scope, procedure, evidence list, exception path).

2) Define scope: “systems/components to inspect”

Create an SR-10 scope register. At minimum, include:

• Asset name/type (server, router, firewall, HSM, workstation class, IoT/OT component).
• Location/ownership (on-prem, colo, cloud-managed appliance, third party custody).
• Criticality (why tampering matters).
• Inspection method(s).
• Inspection cadence and triggers.

Practical scoping rule: Start with components that, if tampered with, would enable privilege escalation, data exfiltration, fraud, or persistent access.

3) Define “tampering indicators” per asset class

Write simple, testable indicators. Examples:

• Physical: broken seals, missing screws, tool marks, unexpected inline devices, cable rerouting, unknown USB devices.
• Hardware/firmware: serial number mismatch, unexpected firmware version, failure of attestation/secure boot indicators, unsigned modules.
• Configuration: drift from hardened baseline, unauthorized admin accounts, unexpected management interfaces exposed.
• Supply chain/custody: packaging anomalies, missing documentation, gaps in receiving logs.

Deliverable: Tamper indicator checklist by asset class.

4) Choose inspection methods that can actually detect tampering

Match method to risk:

• Receiving inspection for newly delivered components (packaging, serials, seals, documentation).
• Routine physical inspection for sensitive areas (racks, ports, cable paths).
• Logical inspection (configuration baseline checks, firmware version checks, integrity verification where available).
• Inventory reconciliation (CMDB vs observed reality) to catch swaps.

If inspection is done by a third party (colocation staff, OEM field service), require inspection attestations and supporting evidence through contract terms and reporting.

5) Operationalize the schedule and triggers

Define:

• Recurring inspections (your chosen cadence).
• Triggered inspections after events: device repair, relocation, incident, unexplained reboot/outage, access control failure, third-party maintenance.

Exam expectation: You can explain why the cadence matches risk and show it is followed.

6) Train inspectors and control access to inspection records

• Train staff on what to look for and how to avoid contaminating evidence.
• Restrict inspection artifacts (photos, findings) because they can reveal sensitive layouts and controls.

7) Findings management: triage, quarantine, investigate, remediate

Define severity levels and actions:

• High confidence tampering: quarantine device, preserve logs, restrict access, start incident response.
• Suspicious anomaly: escalate for secondary validation (e.g., config diff, firmware check, physical re-check).
• False positive: document rationale and close with approvals.

Deliverable: Ticketing workflow with required fields (asset ID, indicator, evidence, disposition, approver).

8) Governance: exceptions and compensating controls

When you cannot inspect directly (cloud services, managed network appliances), document:

• The constraint.
• The alternative assurance method (third-party SOC reports, provider attestations, secure boot attestations, inventory reports, or monitored configuration drift).
• Approval, review cycle, and termination criteria.

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Required evidence and artifacts to retain

Auditors typically want evidence in three buckets: design, operation, and outcomes.

Design evidence (how you designed SR-10)

• SR-10 procedure (scope, methods, cadence, triggers, roles).
• SR-10 scope register (systems/components list).
• Tampering indicator checklists.
• Training materials and completion records for inspectors.

Operational evidence (proof inspections happened)

• Completed inspection checklists (dated, signed/approved).
• Photos where appropriate (with controlled storage).
• Configuration baseline reports or drift detection outputs.
• Firmware version/attestation outputs where available.
• Receiving logs: serial numbers, seal condition, chain-of-custody notes.

Outcome evidence (proof you acted on results)

• Tickets for findings, triage notes, and closure approvals.
• Incident records when tampering is suspected/confirmed.
• Exception approvals and periodic reviews.

A common gap is “we do the work, but we don’t retain artifacts in a retrievable way.” Fix that by defining an evidence folder structure and naming convention tied to asset IDs.

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Common exam/audit questions and hangups

1. “Which components are in scope, and why?” If your list looks arbitrary, you will get follow-ups.
2. “Show me the last completed inspection and the one before it.” Auditors test repeatability.
3. “How do you detect tampering in cloud-managed infrastructure?” “We can’t” is not acceptable without compensating controls and documented rationale.
4. “What happens when you find something suspicious?” Lack of a playbook turns SR-10 into a paper control.
5. “How do you prevent inspectors from pencil-whipping checklists?” Look for supervisor review, spot checks, and ticket linkage.

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Frequent implementation mistakes and how to avoid them

Mistake 1: Scoping only “hardware,” ignoring logical tampering

Avoidance: Define inspection methods for firmware/configuration integrity, not just physical checks.

Mistake 2: No event-driven triggers

Avoidance: Add triggers tied to maintenance, relocation, incidents, and custody changes.

Mistake 3: Third parties are treated as “out of scope”

Avoidance: Push inspection obligations into contracts and require attestations and artifacts. Treat third-party custody as higher risk, not lower.

Mistake 4: Evidence exists but cannot be produced quickly

Avoidance: Centralize SR-10 evidence, use consistent naming, and tie each inspection to a ticket or work order.

Mistake 5: “Inspection” is not designed to detect anything

Avoidance: Use explicit tamper indicators and require inspectors to record “pass/fail + notes,” not just “checked.”

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Enforcement context and risk implications

No public enforcement cases were provided in the supplied source catalog for SR-10, so you should treat this as a control assurance and assessment-readiness requirement rather than a penalty-citation-driven one. The practical risk is operational: undetected tampering can undermine every higher-level security control (identity, logging, encryption) because a compromised component can falsify outputs or provide persistent access. For regulated environments, the second-order risk is failing an assessment due to missing “organization-defined” scope/cadence choices and weak evidence.

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Practical 30/60/90-day execution plan

First 30 days (stand up the control)

• Assign SR-10 owner and approver; publish a one-page SR-10 procedure.
• Build the scope register for critical systems/components.
• Define tamper indicators and inspection checklists for the top asset classes.
• Decide where evidence will live and how it will be named and retrieved.

Days 31–60 (run it twice and fix friction)

• Execute initial inspections for in-scope assets; open tickets for anomalies.
• Validate that inspections are capable of detecting real issues (spot-checks, supervisor review).
• Add event-based triggers into change management and maintenance workflows.
• Document compensating controls for assets you cannot inspect directly (especially third-party hosted).

Days 61–90 (make it audit-proof and repeatable)

• Run a second inspection cycle to prove repeatability.
• Tighten reporting: coverage tracking (what was inspected, what was missed, why).
• Implement exception governance: approvals, expirations, periodic review.
• Prepare an “audit packet” that contains procedure, scope list, and last inspection artifacts.

Where Daydream fits (without adding process noise): Daydream is useful to map SR-10 to a named control owner, attach the inspection procedure, and define recurring evidence requests and collection so the control stays “on” between assessments ².

Frequently Asked Questions

What counts as “tampering” for SR-10?

Treat tampering as any unauthorized physical or logical modification that could change how a component behaves or what it reports. Define concrete indicators per asset class so inspectors know what “good” and “suspicious” look like.

Can a third party perform inspections on our behalf?

Yes, but you still own the requirement. Put inspection obligations, reporting, and evidence expectations into contracts or service terms, and retain the attestations and artifacts as your evidence set.

How do we handle cloud environments where we can’t physically inspect hardware?

Document the constraint and implement compensating controls such as provider attestations and logical integrity checks you control (for example, baseline drift detection for configurations). Keep the exception approval and the alternative evidence with SR-10 records.

Do we need photos for every inspection?

Not always. Photos help for high-risk assets or when you need to prove seal condition and physical integrity, but they also create sensitive artifacts that require access control and retention rules.

How do we set the inspection frequency?

Choose a cadence based on criticality and exposure, then document the rationale and follow it consistently. Add event-driven triggers so you inspect after custody changes, maintenance, or suspicious activity.

What’s the minimum evidence an auditor will accept?

A defined scope list, a written procedure with tamper indicators and schedule, and completed inspection records tied to findings management (tickets and closures). If you cannot produce recent examples quickly, expect deeper testing.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON; NIST SP 800-53 Rev. 5

2. NIST SP 800-53 Rev. 5 OSCAL JSON