CA-8(3): Facility Penetration Testing

CA-8(3) requires you to run a documented physical penetration testing process that includes attempts to bypass or circumvent controls at facility physical access points, then track findings through remediation and retest. Operationalize it by scoping sites and access points, authorizing safe test methods, executing tests via qualified personnel, and retaining evidence that the testing occurred and drove fixes. ¹

Key takeaways:

• Test physical access points with real bypass attempts, not just walkthroughs or policy reviews. ¹
• Treat this like any other penetration test: scope, authorization, rules of engagement, results, remediation, and retest evidence.
• Auditors look for repeatability: defined frequency/triggers, consistent artifacts, and a closed-loop POA&M workflow.

The ca-8(3): facility penetration testing requirement is a targeted enhancement under NIST SP 800-53’s penetration testing control (CA-8). It expects a hands-on process that tries to defeat the physical protections that control entry to your facility, specifically at physical access points. The intent is straightforward: validate that badge readers, guards, visitor processes, doors, and related controls perform under realistic adversarial behavior, not just normal operations. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path to “audit-ready” is to treat facility penetration testing as a recurring, governed assessment activity with tight paperwork and disciplined remediation. You need a named control owner, a repeatable procedure, a qualified test party (internal or third party), and a place to store evidence. You also need to coordinate tightly with Physical Security, Facilities, IT/SecOps, and HR because physical tests can create safety issues, business disruption, or legal exposure if you run them without proper authorization and guardrails.

This page is written to help you implement CA-8(3) quickly: what it means in plain English, who it applies to, what to do step-by-step, and what evidence to keep so an assessor can re-perform your reasoning and see the control operating. ²

Regulatory text

Excerpt (CA-8(3)): “Employ a penetration testing process that includes {{ insert: param, ca-08.03_odp.01 }} {{ insert: param, ca-08.03_odp.02 }} attempts to bypass or circumvent controls associated with physical access points to the facility.” ¹

Operator interpretation (what you must do)

You must have a penetration testing process (planned, authorized, executed, reported, and tracked) that includes attempts to get past physical controls at facility entry points. “Attempts to bypass or circumvent” means the test should simulate real-world tactics (within approved rules of engagement) rather than confirming the presence of a control. Your goal is to generate evidence that controls resist bypass attempts, and when they do not, that weaknesses are remediated and retested. ¹

Because the text includes placeholders (the {{ insert: param … }} fragments), do not guess what those parameters are. Keep your implementation aligned to the non-parameterized requirement: demonstrate a process that includes bypass/circumvention attempts against facility access points. ¹

Plain-English requirement summary

Run physical penetration tests of your facilities where testers try to enter through doors, gates, loading docks, reception areas, or other access points by defeating or tricking the controls (badges, locks, guards, turnstiles, visitor processes). Document the scope, authorization, methods, results, and remediation. ¹

Who it applies to

Entity scope

• Federal information systems and the organizations operating them. ¹
• Contractor systems handling federal data, including regulated environments where NIST SP 800-53 is flowed down via contract or program requirements. ¹

Operational context (when you should expect to implement it)

Implement CA-8(3) when:

• Your system boundary depends on facility-based protections (on-prem data centers, network rooms, labs, manufacturing, secure office floors).
• You rely on people/process controls like reception screening, guard checks, escorting, or visitor badging.
• You have restricted areas where unauthorized physical entry could lead to compromise of federal data or mission-essential services.

If your environment is fully cloud-based but you maintain offices with endpoints, paper records, or secure areas, you may still need facility penetration testing for those locations if they are in scope for your system boundary or safeguarding requirements.

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

1) Assign ownership and define the process (document first)

• Control owner: usually Physical Security lead with GRC oversight; in some orgs Security Engineering owns testing and Physical Security owns remediation.
• Process document: a short SOP that covers planning, authorization, execution, reporting, and remediation tracking mapped to CA-8(3).
• RACI: Physical Security, Facilities, IT/SecOps, HR, Legal, site leadership.

Practical tip: build the SOP so a new site can be added without rewriting the program; make “site scope sheet” an appendix.

2) Define scope: facilities, access points, and objectives

Create a scope register for:

• Sites in scope (HQ, branch offices, data centers, warehouses).
• Physical access points per site: main entrance, side doors, badge-controlled doors, garage doors, loading docks, stairwells, mantraps, emergency exits, shared lobbies, after-hours entrances.
• Control types at each point: badge reader, biometric, PIN, guard, turnstile, camera coverage, door contact sensors, anti-tailgating.

Define objectives as testable statements, for example:

• “Attempt unauthorized entry without a valid badge.”
• “Attempt tailgating through controlled entry.”
• “Attempt entry through a non-public access point during business hours and after hours.”

3) Establish written authorization and Rules of Engagement (RoE)

Your RoE should include:

• Permitted methods and explicit prohibitions (no force, no property damage, no weapons, no disruption of critical operations).
• Safety controls (stop conditions, escalation contacts, site safety briefing).
• Legal/HR guardrails (handling of employee interaction, photography rules, evidence handling).
• Communications plan (who knows the test is happening, who is on a “need-to-know” list, and how to prevent accidental law enforcement escalation).

Keep authorization crisp: a signed “test authorization memo” from an accountable executive (often CSO/CISO or Facilities/Operations leadership) plus site manager acknowledgement.

4) Select qualified testers (internal or third party)

You need testers who can run physical intrusion tests safely and professionally. If you use a third party, treat them as a third party with appropriate due diligence (contract terms, liability, insurance, background screening expectations, confidentiality, chain-of-custody for evidence). If you use internal staff, confirm independence from the site’s day-to-day security operations to avoid “marking your own homework.”

5) Execute tests that include bypass/circumvention attempts

Design scenarios per access point. Examples of bypass/circumvention attempts (choose those consistent with your RoE and local laws):

• Tailgating/piggybacking attempts at badge-controlled doors.
• Social engineering at reception to obtain a visitor badge without proper verification.
• Attempts to access loading docks or shipping/receiving areas.
• Attempts to enter through doors that should be locked (after-hours checks).
• Testing escort enforcement (attempt to wander into restricted areas after sign-in).
• Testing whether deactivated badges still function (with pre-coordination so you don’t create a real access gap).

Record: timestamps, location, method used, whether access was achieved, detection/response behavior (guard challenge, alarm triggers, escort intervention), and supporting evidence (photos where allowed, badge logs, visitor logs, CCTV review notes).

6) Report results in a way auditors can follow

A good report includes:

• Executive summary (sites tested, high-level outcomes).
• Detailed findings per access point/test case.
• Root cause analysis (process gap vs hardware vs training).
• Risk statement tied to business/system impact.
• Recommended remediation with owners and due dates.
• Retest plan.

7) Track remediation to closure and retest

CA-8(3) is weak if you only test and file a report. Put findings into your corrective action workflow (often a POA&M). Track:

• Fix implemented (door hardware replaced, visitor policy updated, guard post orders updated, badge system configuration changed).
• Evidence of fix (change tickets, updated procedures, training records).
• Retest result confirming the bypass path is closed.

8) Define cadence and triggers (so it’s repeatable)

NIST’s excerpt does not specify a frequency for CA-8(3). Set a cadence based on risk and operational change. Common triggers:

• New facility opening or major remodel
• Badge system change
• Guard vendor change (third party)
• Material security incident (tailgating incident, theft, unauthorized access)

Document the rationale so an assessor sees why your schedule is credible.

Required evidence and artifacts to retain (audit-ready checklist)

Keep artifacts in a single control evidence folder (GRC tool or structured repository):

• Facility penetration testing SOP mapped to CA-8(3). ¹
• Test scope documents: site list, access point inventory, scenario list.
• Signed authorization memo and Rules of Engagement.
• Tester qualifications/engagement documentation (SOW/contract for third party, NDAs, background screening attestations if applicable).
• Test execution logs/field notes and evidence (photos where permitted, timestamped notes).
• Final report with findings and severity rationale.
• Remediation tracking (tickets/POA&M entries), closure evidence, and retest results.
• Lessons learned and program updates (procedure revisions after the test).

Common exam/audit questions and hangups

Assessors and auditors commonly ask:

1. “Show me the process.” They want a documented, repeatable penetration testing process that explicitly includes physical access point bypass attempts. ¹
2. “What access points were tested, and why those?” Missing coverage for loading docks, stairwells, or shared building entrances is a frequent gap.
3. “Was it authorized?” If you cannot show written authorization and RoE, the test can be treated as ad hoc or unsafe.
4. “Did you remediate and retest?” A report without closure evidence reads like a paper exercise.
5. “How do you manage the third party?” Expect questions on selection, scope control, and evidence handling when testers are external.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Confusing a physical security inspection with a penetration test. A checklist walkthrough does not satisfy “attempts to bypass or circumvent.” Include realistic bypass attempts aligned to RoE. ¹
• Mistake: Testing only the front door. Attackers pick side doors, loading docks, or shared lobbies. Inventory access points and test a representative set per site.
• Mistake: No remediation workflow. Fix ownership often falls between Facilities, Physical Security, and IT badge admins. Pre-assign owners in a RACI and require closure evidence.
• Mistake: Over-collecting sensitive evidence. Photos of access controls, guard stations, and camera placements can become sensitive. Define evidence handling and retention rules in the RoE.
• Mistake: Running tests without HR/legal guardrails. Social engineering tests can trigger employee relations issues. Set boundaries, ensure leadership authorization, and plan debriefs.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite enforcement actions. Practically, failure in facility access controls increases the chance of physical theft, tampering, or unauthorized access to systems and media, which then cascades into incident response, reporting, and contractual noncompliance exposure for federal programs. ²

Practical 30/60/90-day execution plan

No timeline is mandated in the requirement text. Use the phases below as an execution pattern you can adapt to your operating cadence. ¹

First 30 days (stand up the program)

• Assign control owner and backups; publish CA-8(3) SOP and RACI.
• Build facility/access-point inventory template and collect data for top sites.
• Draft Rules of Engagement and authorization memo templates.
• Decide tester model: internal, third party, or hybrid; start procurement if third party.

Days 31–60 (run the first test cycle)

• Select initial sites (risk-based) and finalize scope per site.
• Brief site leadership, Physical Security, and any guard force supervisors.
• Execute facility penetration tests with documented bypass/circumvention attempts.
• Produce formal report and enter findings into remediation tracking.

Days 61–90 (close findings and prove operational control)

• Drive remediation to closure with accountable owners and evidence.
• Retest the most critical findings and document outcomes.
• Update SOP/RoE based on lessons learned (scope gaps, safety issues, evidence handling).
• Establish steady-state schedule and triggers, and load recurring tasks into your GRC calendar.

Where Daydream fits (without adding process overhead)

If you manage multiple sites or need consistent assessor-ready evidence, Daydream can help you map CA-8(3) to a control owner, a standard implementation procedure, and a recurring evidence checklist so the same artifacts exist every cycle and every facility. That reduces the “we did the test but can’t prove it” failure mode that shows up in real assessments. ¹

Frequently Asked Questions

Does CA-8(3) require a third-party physical pentest firm?

No. The requirement is to employ a penetration testing process that includes attempts to bypass or circumvent physical access point controls. ¹ You can use internal testers if you can show competence, authorization, safe execution, and objective reporting.

What counts as a “physical access point”?

Any controlled entry path into the facility or restricted areas, including doors, gates, loading docks, shared lobby transitions, and after-hours entrances. The key is that your test targets controls associated with those points. ¹

Are social engineering attempts required?

The text requires bypass/circumvention attempts but does not enumerate methods. ¹ Social engineering is a common way to test visitor and guard processes, but you should only include it if your Rules of Engagement and legal/HR guardrails allow it.

How do we show auditors that we “attempted to bypass” controls without keeping sensitive details?

Keep enough detail to prove the attempt occurred (scenario description, time, location, outcome, detection/response, and evidence references), and store sensitive specifics in a restricted annex. Your RoE should define evidence handling and access controls.

If we’re in a leased building with shared security, are we still responsible?

If your system’s protection depends on that facility access control layer, you still need a process to test relevant access points and document what you can and cannot control. Where building management or a third party provides controls, capture that dependency and coordinate testing within contractual and safety limits. ¹

What is the minimum “pass” evidence for CA-8(3)?

A documented process plus artifacts from an executed test cycle: approved scope and RoE, execution records showing bypass/circumvention attempts at access points, a report, and remediation/closure with retest where needed. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5