MP-6(3): Nondestructive Techniques

MP-6(3) requires you to apply nondestructive sanitization to portable storage devices before you connect them to your systems, in the specific situations your organization defines (the control’s “circumstances” parameter). Operationally, you need a documented trigger list, approved scanning/sanitization methods, enforced technical gates where possible, and repeatable evidence that every in-scope device was processed. ¹

Key takeaways:

• Define the exact “circumstances” that trigger nondestructive sanitization, then make them enforceable in procedure and tooling. ¹
• Treat “portable storage” broadly in your inventory and intake workflow, including third-party-provided media and field-returned media. ¹
• Keep auditor-ready proof: logs, tickets, intake records, exceptions, and tool output tied to device identifiers and outcomes. ¹

The mp-6(3): nondestructive techniques requirement exists to prevent a common and expensive failure mode: a portable storage device enters your environment and becomes a delivery mechanism for malware, unauthorized data, or policy-violating content. MP-6(3) narrows the focus to a practical constraint: you may need to “sanitize” media without destroying the data, because the business still needs the content.

For a Compliance Officer, CCO, or GRC lead, the fast path is to translate the control into three operator decisions: (1) what you count as “portable storage devices,” (2) which situations require nondestructive sanitization before connection, and (3) what “nondestructive sanitization techniques” mean in your environment (tools, settings, responsibilities, and evidence).

The key implementation challenge is that MP-6(3) includes an organization-defined parameter for the triggering “circumstances.” If you do not define those circumstances clearly, you cannot prove consistent enforcement, and you will struggle in assessment. Your goal is a workflow that is easy to follow, hard to bypass, and easy to evidence.

Regulatory text

Requirement (excerpt): “Apply nondestructive sanitization techniques to portable storage devices prior to connecting such devices to the system under the following circumstances: {{ insert: param, mp-06.03_odp }}.” ¹

What the operator must do

1. Decide and document the “circumstances” that trigger nondestructive sanitization (the organization-defined parameter). ¹
2. Before connection, ensure every in-scope portable storage device is processed using an approved nondestructive technique (for example, malware scanning and policy checks that preserve data). ¹
3. Prove it happened through repeatable records tied to the device, the request, and the outcome. ¹

Plain-English interpretation

MP-6(3) means: do not plug portable media into your environment until it has been checked and cleaned in a way that does not destroy the data, whenever your defined risk conditions apply. The control is about preventing introduction of malicious code and preventing uncontrolled ingestion of data through removable media pathways. ¹

“Nondestructive” is the practical hint: you are expected to use techniques that preserve the content where feasible, rather than wiping or physically destroying the device. If your risk decision is that destructive sanitization is required, that is a different operational choice and should be handled under your broader media sanitization approach, but MP-6(3) specifically calls out nondestructive techniques prior to connection under defined circumstances. ¹

Who it applies to

Entity scope

• Federal information systems and contractor systems handling federal data, where NIST SP 800-53 is the governing control baseline. ¹

Operational scope (where this shows up)

• End-user endpoints (laptops/desktops) that accept USB mass storage.
• Server and admin workstations that may read external media for maintenance.
• OT/ICS and lab environments where file transfer via removable media is common.
• Secure facilities and incident response workflows (e.g., receiving evidence media).
• Any third party interaction that includes file delivery on portable media (deliverables, patches, legal discovery, data migration). ¹

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

1) Define “portable storage device” for your environment

Write a definition that is testable in audits and actionable for operators. Include examples like:

• USB flash drives, USB external HDD/SSD
• SD/microSD cards
• Removable media delivered by a third party
• Devices returned from the field or recovered from decommissioned assets

Then map where these devices enter: mailroom, reception, IT service desk, engineering lab, incident response intake, and third-party onsite work.

Deliverable: “Portable Media Standard” section in policy + a one-page operator runbook.

2) Set the organization-defined “circumstances” (the control parameter)

This is the make-or-break decision for MP-6(3). Create a short trigger table that answers: when must the device be sanitized before connection? ¹

A practical trigger set often includes:

• Device is not organization-owned (personal device, third-party device, customer-provided device).
• Device has been outside controlled custody (travel, field work, conference, shared lab).
• Device is intended to connect to high-impact or restricted networks/hosts (admin workstations, production systems, enclaves).
• Device contains sensitive data that must be inspected for policy compliance before import.
• Device’s provenance is unknown (unlabeled media, “found” media, media from an unverified source).

Deliverable: A control parameter statement approved by Security/GRC and embedded into procedure.

3) Choose approved nondestructive techniques and tools

Define the techniques as specific actions with tool outputs, not generic “scan it.”

Common nondestructive techniques to standardize:

• Malware scanning with updated signatures and heuristics on a dedicated scanning host.
• File-type enforcement and blocking (e.g., disallowed executables, macro-enabled files) based on your policy.
• Read-only mounting and controlled copying into a quarantine area for inspection.
• Hashing and logging (to track what was introduced, by whom, and when).

Deliverable: A “Portable Media Intake Checklist” with exact tool names/settings your team approves.

4) Build an intake and approval workflow (with roles)

Assign ownership and separation of duties where it matters:

• Requestor submits a ticket/request stating source, purpose, target system, and data type.
• Service desk / security operations performs intake scanning and records results.
• System owner approves connection/import based on scan outcome and business need.
• GRC monitors exceptions and sampling for compliance.

Deliverable: Ticket template fields + RACI.

5) Add technical gates to reduce bypass risk

Procedures are fragile. Add enforceable controls where possible:

• Endpoint policy to block USB mass storage by default and allow by exception.
• A dedicated “media scanning kiosk” (standalone workstation) as the only permitted scanning point.
• Network segmentation: prohibit direct connection to sensitive segments.
• Logging/EDR alerts for new USB device mounts on high-value assets.

Deliverable: A configuration standard and an exception workflow for business-critical use cases.

6) Define exceptions, compensating controls, and break-glass

MP-6(3) will collide with emergencies (outage recovery, urgent patching, incident response). Write a narrow exception path:

• Who can authorize
• What compensating steps apply (e.g., isolate host, enhanced monitoring, post-connection scan)
• How you document and review exceptions

Deliverable: Exception form + after-action review requirement.

Required evidence and artifacts to retain

Auditors typically look for repeatability and traceability. Keep evidence that links device → trigger → technique → outcome.

Minimum evidence set:

• Policy/standard defining portable media, triggers (“circumstances”), and approved nondestructive techniques. ¹
• Procedure/runbook with step-by-step intake instructions.
• Tickets/requests showing business purpose, source, approver, and target system.
• Scan logs/reports from the scanning tool (timestamped, tied to device identifier or serial where feasible).
• Chain-of-custody records for third-party-provided or field-returned media (receipt, labeling, storage location).
• Exception register with approvals and compensating controls.
• Training/acknowledgment for staff who handle portable media intake.

Daydream (as a GRC workflow layer) becomes useful when you need to map MP-6(3) to an owner, a single authoritative procedure, and recurring evidence artifacts that are collected the same way every time. That mapping is also the fastest route to assessment readiness for this enhancement. ¹

Common exam/audit questions and hangups

Expect these:

• “Show me your defined ‘circumstances’ for MP-6(3). Where is it documented and approved?” ¹
• “How do you ensure portable media is sanitized before connection, not after?” ¹
• “Demonstrate the workflow: pick three recent devices and show ticket, scan output, and approval.”
• “How do you control third-party portable media used by onsite contractors?”
• “What prevents engineers/admins from plugging media directly into privileged systems?”
• “How are exceptions handled, and how do you detect bypass?”

Typical hangup: teams have an antivirus tool but no clear trigger definition and no evidence trail tying scans to specific devices and connection events.

Frequent implementation mistakes and how to avoid them

• Mistake: Leaving “circumstances” vague (“as needed,” “when risky”).
  Fix: Publish a trigger table with concrete criteria and examples; embed it in the ticket form. ¹

• Mistake: Scanning on the destination host.
  Fix: Require scanning on a dedicated kiosk or isolated host before any connection to sensitive systems.

• Mistake: No chain-of-custody for third-party media.
  Fix: Label on receipt, store in controlled location, document handler and timestamps.

• Mistake: Exceptions become the norm.
  Fix: Tight exception authority, time-bounded approvals, and periodic review by GRC.

• Mistake: Evidence is scattered across inboxes and chat.
  Fix: Centralize in a system of record (ticketing + GRC evidence library) with consistent naming and required fields.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific requirement, so you should treat MP-6(3) primarily as an assessment-driven control under NIST SP 800-53 rather than a control with a predictable enforcement “case pattern” in the provided materials. ¹

Risk-wise, MP-6(3) is a classic pathway control: removable media can bypass network-based protections and introduce malware or unapproved data directly onto endpoints and privileged systems. The compliance risk shows up as a control design gap (undefined circumstances) or an operating effectiveness gap (no proof that scanning happens prior to connection). ¹

Practical execution plan (30/60/90-day)

Day 0–30 (Immediate stabilization)

• Name the control owner and backup; publish a single procedure location. ¹
• Define portable storage device scope and the MP-6(3) “circumstances” trigger table; get Security approval.
• Stand up a basic intake ticket with mandatory fields and attach scan output.

Day 31–60 (Operationalize and reduce bypass)

• Deploy or formalize a scanning kiosk workflow and access controls.
• Implement endpoint restrictions for high-value systems (block USB storage by default, controlled exceptions).
• Train service desk, SOC, and engineering teams on the exact intake steps and exception path.

Day 61–90 (Evidence hardening and continuous control operation)

• Start a recurring sampling review: select recent tickets and verify scan logs + approvals are complete.
• Build an exception register review cadence and close stale exceptions.
• Automate evidence collection where possible (ticket templates, required attachments, centralized evidence repository in Daydream).

Frequently Asked Questions

What counts as “nondestructive sanitization” under MP-6(3)?

It’s a technique that reduces risk on the device without destroying the stored data, such as scanning and removing malware or enforcing file policy prior to connection. Your procedure must define the approved techniques and how you capture results. ¹

Do we have to sanitize every USB drive before use?

MP-6(3) applies under the “circumstances” you define for your organization. Define those triggers narrowly enough to be operational, but broad enough to cover high-risk intake paths like third-party media and unknown provenance. ¹

Can we meet MP-6(3) with antivirus on endpoints?

Endpoint antivirus helps, but MP-6(3) is explicitly “prior to connecting,” so you need a control that happens before the device touches the system, or a technical gate that prevents connection until the process is completed. ¹

How should we handle third-party contractors who bring portable media onsite?

Require contractors to submit media through the same intake workflow, or provide organization-controlled media and prohibit personal devices by policy. Document the requirement in third-party onboarding and enforce it at reception/service desk intake.

What evidence do auditors expect for MP-6(3)?

They typically want the documented “circumstances,” the procedure, and a traceable sample of real executions: tickets, scan outputs, approvals, and exceptions tied to specific devices and dates. ¹

What if a business unit says scanning delays operations?

Create a fast path that is still controlled: dedicated scanning stations, clear SLAs in the service desk, and a narrow break-glass exception with compensating controls and post-event review.

Footnotes

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