MA-5(1): Individuals Without Appropriate Access

MA-5(1): Individuals Without Appropriate Access requires you to put strict procedures around any maintenance work performed by personnel who lack appropriate clearances or are not U.S. citizens, so they cannot gain unauthorized logical or physical access during maintenance. Operationally, this means pre-approval, escorted/supervised access, tightly scoped credentials, and auditable records for each maintenance event ¹.

Key takeaways:

• Treat maintenance by uncleared/non‑U.S. personnel as an exception path with extra controls, not business-as-usual ¹.
• Control the session: restrict access, supervise activity, and capture logs and sign-offs tied to specific work orders ¹.
• Evidence is the control: without repeatable artifacts per maintenance event, MA-5(1) will fail in assessment.

MA-5(1) sits in the NIST SP 800-53 Maintenance (MA) family and targets a real operational weakness: maintenance is a privileged pathway into systems. Troubleshooting often requires elevated access, physical presence, removable media, or remote sessions. If the people performing that maintenance do not have appropriate clearances, or are not U.S. citizens, you must manage that work in a way that prevents unauthorized exposure to federal systems and data ¹.

For a Compliance Officer, CCO, or GRC lead, the fastest way to operationalize MA-5(1) is to define a controlled “maintenance under restricted personnel” workflow. That workflow should answer three questions auditors will ask immediately: (1) How do you identify when MA-5(1) applies? (2) What compensating controls do you impose before and during maintenance? (3) What evidence proves you followed the procedure each time?

This page gives requirement-level implementation guidance you can hand to operations, IT, facilities, and third-party risk teams. The goal is simple: maintenance happens, systems stay protected, and you can prove it with clean, recurring artifacts aligned to MA-5(1): individuals without appropriate access requirement ².

Regulatory text

Excerpt (requirement): “Implement procedures for the use of maintenance personnel that lack appropriate security clearances or are not U.S. citizens, that include the following requirements:” ¹

Operator interpretation of the text: You must have documented, implemented procedures for maintenance work when the maintenance person is in one of two categories:

1. lacks appropriate security clearances, or
2. is not a U.S. citizen
   and those procedures must impose additional safeguards so maintenance does not create an unauthorized access path ¹.

What an assessor will look for: a defined procedure, a clear decision point for when MA-5(1) triggers, and consistent execution evidence tied to actual maintenance events.

Plain-English interpretation (what this really means)

Maintenance is privileged by nature. MA-5(1) requires you to treat maintenance performed by individuals without appropriate access as a controlled exception: narrowly scoped access, supervised/escorted work, and documentation that shows what was done, by whom, when, and under what constraints ¹.

In practice, the requirement usually shows up in:

• Break/fix hardware repairs and component swaps
• Data center “smart hands” or facilities work near racks and consoles
• Manufacturer field service
• Third-party remote troubleshooting sessions
• Any scenario where you would otherwise grant broad admin access “just to get it done”

Who it applies to (entity and operational context)

Entities: Federal information systems and contractor systems handling federal data ¹.

Operational contexts where it triggers:

• You use third-party maintenance providers (manufacturers, MSPs, integrators, facilities contractors).
• You have internal maintenance staff but sometimes rely on personnel who do not meet your clearance expectations for the system boundary in scope.
• You allow remote maintenance connections into the environment (even if “temporary”).
• You have colocations or shared facilities where maintenance staff may be present near sensitive assets.

If your system boundary includes regulated federal data, assume assessors will ask how you handle non-standard maintenance personnel access paths.

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

Use this as a build sheet for your MA-5(1) procedure. Keep it short enough that operations will follow it.

Step 1: Define the MA-5(1) trigger and decision owner

• Define “appropriate security clearances” for your environment in a way your organization can apply consistently (for example: “meets contract/program access requirements for this system boundary”).
• Define how you identify non‑U.S. citizens for purposes of this procedure (often through the third party engagement intake; do not over-collect).
• Assign an accountable owner for approving “restricted personnel maintenance” (typically IT Security, the System Owner, or the AO delegate depending on your governance model).

Artifact: MA-5(1) maintenance procedure + RACI with named role owners.

Step 2: Inventory maintenance channels and assets in scope

Create a list of:

• Systems/components requiring maintenance (servers, network devices, endpoints, OT/IoT, secure rooms).
• Approved maintenance methods (onsite, remote, depot repair).
• Remote access tools allowed for maintenance and how they are controlled.

Artifact: Maintenance asset/channel register mapped to the system boundary.

Step 3: Build a “pre-approved maintenance work order” workflow

For any MA-5(1)-triggered event, require a work order/ticket that captures:

• Identity of maintenance personnel and associated third party
• Scope of work (device IDs, locations, configuration items)
• Start/end window
• Access method (console, remote session, escorted physical access)
• Required controls (escort, monitoring, temporary account, removable media rules)
• Approval(s) before access is granted

Artifact: Ticket template fields (or form) that force MA-5(1) data capture.

Step 4: Enforce least-privilege and time-bounded access

Your procedure should require one or more of the following, depending on the maintenance type:

• Temporary accounts with expiration
• Role-based access limited to the system/component being serviced
• Just-in-time elevation with documented approval
• Break-glass controls with after-action review

Make the controls operational: the ticket should drive account provisioning and deprovisioning, not an informal request.

Artifacts: Access request/approval record, account provisioning evidence, deprovisioning proof.

Step 5: Supervise and monitor the maintenance session

For MA-5(1) events, require supervision appropriate to the access path:

• Onsite physical maintenance: escort requirement, controlled spaces, sign-in/out, device custody rules.
• Remote maintenance: monitored sessions (recording where permitted), command/log capture, and a company operator present to terminate access.

Your objective is to prevent unsupervised exploration outside the approved scope.

Artifacts: Escort logs or visitor logs, session logs, remote access logs, screen recordings where policy allows.

Step 6: Control tools, media, and data exposure during maintenance

Maintenance often involves drivers, firmware, diagnostics, or removable media. Your procedure should require:

• Approved source for tools/software
• Malware scanning of files/media before introduction
• Prohibition or strict control of data copies during troubleshooting
• Clear rules for what can leave the facility (failed drives, logs, components)

Artifacts: Media handling checklist, malware scan logs, chain-of-custody forms for removed components.

Step 7: Post-maintenance validation and closure

Require post-maintenance steps tied to the same ticket:

• Confirm the work performed matches the approved scope.
• Review logs for anomalous activity during the window.
• Restore baseline configurations if changed.
• Close out temporary access and document closure.

Artifacts: Ticket closure checklist, log review sign-off, configuration/baseline verification evidence.

Step 8: Operationalize with recurring evidence and sampling

Assessments rarely require every ticket. They require a defensible method. Define:

• How you tag MA-5(1) tickets in your ITSM tool.
• How you sample completed tickets for internal review.
• Who reviews and how findings are tracked.

Daydream tip (where it fits naturally): use Daydream to map MA-5(1) to a control owner, a single operating procedure, and a recurring evidence list so you can produce the same artifact set every audit cycle without re-creating it from scratch ¹.

Required evidence and artifacts to retain

Use this as your audit-ready checklist. You want artifacts that show design and operation.

Policy/procedure (design evidence)

• MA-5(1) maintenance procedure covering restricted personnel scenarios ¹
• RACI for approvals, escorts, monitoring, and ticket closure
• Standard ticket/work order template with required MA-5(1) fields

Operational records (operating evidence)

• List of MA-5(1)-tagged maintenance tickets for the period
• Per-ticket approvals and scope
• Access provisioning/deprovisioning records (temporary accounts, time bounds)
• Physical access logs or visitor logs for onsite maintenance
• Remote access logs and session monitoring evidence
• Media handling and chain-of-custody records (when components or media are involved)
• Post-maintenance validation and closure sign-off

Common exam/audit questions and hangups

Expect assessors to push on these points:

1. “How do you determine who ‘lacks appropriate access’?”
   Have a written decision rule and show it is applied in the ticket intake.

2. “Show me three maintenance events involving third-party personnel and the evidence for each.”
   If you cannot quickly produce ticket + access logs + closure sign-off, your process is not operational.

3. “Can those personnel access production data during maintenance?”
   Your answer should be “only if explicitly approved, supervised, and logged,” and you should show the safeguards.

4. “How do you prevent persistent remote access?”
   They will look for time-boxing, account disablement, and remote tool configuration evidence.

Frequent implementation mistakes (and how to avoid them)

• Mistake: The procedure exists but tickets don’t capture MA-5(1) triggers.
  Fix: add mandatory ticket fields and a routing rule that flags MA-5(1) events.

• Mistake: “Escorted” is written, but nobody logs the escort.
  Fix: require a named escort in the ticket and keep a visitor/escort log tied to the event.

• Mistake: Temporary access is granted but not removed.
  Fix: automate expiration where possible and require closure steps that include access removal proof.

• Mistake: Remote maintenance uses ad hoc tools.
  Fix: restrict to approved tools with central logging; block inbound paths that bypass your monitoring.

• Mistake: Evidence is scattered.
  Fix: define one evidence folder structure per maintenance event (ticket ID as the folder key), or use a GRC workflow that binds artifacts to the control.

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the supplied sources. Practically, MA-5(1) is still high consequence because it governs a common intrusion and data exposure pathway: privileged maintenance access can bypass normal user controls and monitoring. The risk you are managing is unauthorized disclosure, tampering, or persistence introduced during maintenance activity ².

A practical 30/60/90-day execution plan

Use phased execution goals rather than trying to perfect the program before rollout.

First 30 days (stabilize and define)

• Publish the MA-5(1) procedure and RACI.
• Add MA-5(1) trigger fields to ITSM tickets and require approvals.
• Identify all approved remote maintenance tools and disable unmanaged paths.
• Start collecting evidence for every MA-5(1)-tagged event in one location.

Next 60 days (make it repeatable)

• Train IT operations, facilities, and third-party managers on the workflow.
• Implement time-bounded access patterns for maintenance accounts.
• Put escort and visitor logging into a standard checklist for onsite work.
• Pilot an internal review of completed MA-5(1) tickets and document remediations.

By 90 days (make it assessable)

• Run a tabletop: simulate a third-party emergency maintenance event and confirm approvals, monitoring, and closure steps work end-to-end.
• Produce an “assessment packet” from a sample of MA-5(1) tickets: ticket, approvals, logs, closure.
• Map MA-5(1) to a single control owner and recurring evidence expectations in Daydream so evidence collection stays consistent across audit periods ¹.

Frequently Asked Questions

Does MA-5(1) apply to internal employees, or only third parties?

It applies to “maintenance personnel” broadly, which can include internal staff and third-party personnel if they lack appropriate clearances or are not U.S. citizens ¹. Operationally, most organizations implement it as an exception workflow most often used for third parties.

What counts as “maintenance” for MA-5(1)?

Treat maintenance as any activity to repair, troubleshoot, upgrade, or service system components, including remote troubleshooting and onsite hardware work. If the activity requires privileged access or proximity to sensitive components, route it through the MA-5(1) procedure ¹.

Can we allow remote vendor maintenance if we monitor the session?

Yes, if your procedure requires pre-approval, least-privilege access, supervision/monitoring, and auditable logs tied to a work order. Make remote access time-bounded and ensure access is removed at ticket closure.

How do we evidence “supervision” during remote maintenance?

Keep remote access logs and a record that an internal operator attended the session and approved the scope. Where policy allows, retain session recordings or transcripts and tie them to the ticket ID.

What if the manufacturer insists on depot repair where the device leaves our site?

Treat it as a chain-of-custody and data exposure problem. Document approvals, sanitize or encrypt storage where feasible, and retain custody records that show who had the device and when, linked to the maintenance ticket.

We rarely have MA-5(1) events. How do we avoid failing an audit due to lack of samples?

Keep the procedure current, show the ticket workflow is configured, and retain evidence from the events you do have. If events are truly rare, run a controlled test or tabletop and keep the resulting artifacts to show the process works in practice.

Footnotes

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

2. NIST SP 800-53 Rev. 5