MP-8(2): Equipment Testing

MP-8(2): Equipment Testing requires you to periodically test your media “downgrading” equipment and procedures to confirm they actually remove or reduce sensitive data markings and content to the intended level before reuse, transfer, or disposal. Operationalize it by defining downgrade scenarios, running documented test cases, capturing results, fixing failures, and keeping repeatable evidence for assessors. ¹

Key takeaways:

• Treat “downgrading” like a controlled technical process: defined inputs, expected outputs, test cases, and pass/fail criteria. ¹
• Testing must cover both the equipment and the procedures people follow, not just tool functionality. ¹
• Your biggest audit risk is weak evidence: no test plan, no results, no remediation trail, and no re-test after fixes. ¹

If your environment handles federal data or supports a federal information system, “downgrading” can become a daily operational reality: media and components move between enclaves, classifications, tenants, or sensitivity tiers, and you need a defensible way to reduce data exposure risk. MP-8(2): Equipment Testing is the requirement that forces honesty: you do not get credit for having a degausser, sanitizer station, reimaging workflow, or other downgrading mechanism unless you test it and can prove the downgrade outcome is achieved. ¹

For a Compliance Officer, CCO, or GRC lead, the work is mostly governance and evidence design. You’re setting clear ownership, scoping what “downgrading” means in your environment, defining the test method, and ensuring the tests happen and are retained. The fastest path is to build a small, repeatable test program that aligns to your actual downgrade paths (for example, reuse within the same organization, return to a third party, disposal, or transfer to a lower-sensitivity system). ¹

This page focuses on requirement-level implementation: what to test, how to test it, what to keep, and what auditors typically challenge.

Regulatory text

NIST SP 800-53 Rev. 5 control enhancement MP-8(2) excerpt: “Test downgrading equipment and procedures {{ insert: param, mp-8.2_prm_1 }} to ensure that downgrading actions are being achieved.” ¹

What the operator must do:

• Identify any equipment and procedural workflows you rely on to downgrade media or components (reduce sensitivity, remove data, or change handling restrictions). ¹
• Test those mechanisms in a way that can demonstrate the downgrade result was achieved, not just that a job completed. ¹
• Keep test evidence and use failures to drive corrective action and re-testing. This is the practical reading implied by “to ensure that downgrading actions are being achieved.” ¹

Plain-English interpretation (what MP-8(2) really demands)

MP-8(2): equipment testing requirement is a verification control. If you claim you can downgrade media (for example, sanitize a drive for reuse in a lower-sensitivity context), you must validate the downgrading works under real conditions and that staff follow the procedure correctly. ¹

This is not a paper exercise. Assessors will look for proof that:

• Your defined downgrade method matches the risk (media type, storage tech, data sensitivity, and destination context).
• The process is repeatable and produces the intended post-downgrade state.
• Failures trigger containment and remediation, not silent acceptance.

Who it applies to (entity and operational context)

Entity scope: Federal information systems and contractor systems handling federal data. ¹

Operational scope (common real-world triggers):

• IT asset disposition (ITAD) and disposal workflows where media must be cleared before leaving custody.
• Reuse of endpoints, servers, removable media, or storage arrays across sensitivity tiers, programs, tenants, or environments.
• Repairs and RMA processes where components may leave facilities or be handled by a third party.
• Lab environments, staging areas, and “quarantine” rooms where data-bearing devices are processed before redeployment.

Control owners (typical):

• IT operations / endpoint team for imaging and reuse workflows
• Data center / infrastructure team for storage sanitization workflows
• Security engineering or ISSO for validation criteria
• GRC for evidence, cadence, and audit readiness
• Physical security / facilities if there is controlled equipment and access

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

1) Define “downgrading” in your environment

Create a short “Downgrade Scope Statement” that lists:

• Media types: HDD, SSD, NVMe, tapes, removable USB, mobile devices, embedded storage.
• Downgrade destinations: reuse internally (lower sensitivity), transfer to another system boundary, return to third party, disposal.
• Approved downgrade methods: degaussing, cryptographic erase, secure wipe, reimage, firmware reset, destruction (if you treat destruction as a terminal downgrade path for handling).
  This scoping prevents an audit argument that you tested one path but not the one you actually use.

2) Inventory downgrading equipment and procedural workflows

Build an inventory table with:

• Equipment/tool name, model, serial, location, custodian
• Procedure name and version
• Media types supported
• Preconditions (access controls, chain-of-custody steps, approvals)

If you run downgrading via a third party (ITAD, repair depot, managed service), include them as a third party in scope and map how you receive evidence and how you validate their claims.

3) Write a test plan with explicit pass/fail criteria

Your MP-8(2) test plan should be short but specific:

• Test objectives: prove downgrading actions are achieved. ¹
• Test cases: one per downgrade method and media type, plus “operator deviation” cases (wrong setting, wrong drive type, interrupted run).
• Success criteria: measurable outcomes (examples: inability to read prior data using standard tooling; logs show the correct algorithm; media is physically destroyed per procedure). Avoid vague “completed successfully.”

Practical tip: make test cases mirror your “top paths” (the workflows you perform most often or that carry the highest impact if wrong).

4) Execute tests with separation of duties where possible

Run the tests:

• Under normal operating conditions (same staff roles, same environment, same equipment).
• With documented chain of custody for test media.
• With a reviewer role that checks outputs and signs off.

If separation of duties is hard, require peer review or spot-checking. Auditors care that someone other than the operator can validate results.

5) Capture results and remediate failures

For each test case, record:

• Inputs (media type, identifier)
• Method and settings used
• Date/time, operator
• Output evidence (logs, screenshots, tool reports)
• Pass/fail and rationale
• Corrective actions for failures
• Retest results after remediation

A common operational stance: treat any failure as a potential security incident until you confirm no downgraded media was released under the failing condition. Document the containment decision either way.

6) Establish a recurring cadence and change triggers

Even without a prescribed frequency in the excerpt, you need a defensible schedule and event-based triggers. Use triggers such as:

• New equipment model or firmware
• Procedure change
• New media types introduced
• New third party used for ITAD/repairs
• Material process failures or anomalies

7) Make evidence retrieval audit-proof (Daydream-ready)

Most teams fail MP-8(2) during assessments because artifacts are scattered across tickets, shared drives, and tool consoles. In Daydream, treat MP-8(2) as a single requirement page with:

• One control owner
• A single test plan artifact
• A recurring evidence request (test results bundle)
• A remediation-and-retest bundle when issues occur

That mapping is the fastest route to clean auditor walkthroughs and consistent renewal evidence.

Required evidence and artifacts to retain

Use this as your evidence checklist:

• Downgrading equipment inventory (with ownership and location)
• Downgrading procedures/SOPs (version-controlled)
• MP-8(2) test plan (test cases + pass/fail criteria) ¹
• Test execution records (who/what/when/where)
• Tool output: logs, reports, screenshots, certificates generated by equipment
• Chain-of-custody records for test media and sampled production media
• Exception records (if a device cannot be downgraded and must be destroyed, or if alternate method used)
• Corrective action tickets and retest evidence (tie fix to retest outcome)

Common exam/audit questions and hangups

Assessors tend to probe in predictable ways:

• “Show me the last test results and how you determined pass/fail.”
• “Which downgrade paths exist, and which ones did you test?”
• “How do you know the procedure is followed on the floor, not just written?”
• “What happens when a downgrade fails? Show containment and retest.”
• “How do you validate third-party downgrading claims?”

Hangup to anticipate: teams confuse “we have a wiping tool” with “we tested that it achieves the downgrade outcome.” MP-8(2) is explicitly about testing for achieved outcomes. ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	How to avoid it
Testing only once at install	Doesn’t show ongoing assurance as conditions change	Add recurring tests and change-triggered tests tied to procedure/equipment changes
Testing only equipment, not procedures	Requirement includes “equipment and procedures”	Include operator steps, approvals, custody, and documentation checks in test cases 1
Pass criteria is “job completed”	Completion ≠ downgrade achieved	Define outcome-based validation and have a reviewer confirm results
No retest after remediation	Leaves assurance gap	Require retest evidence as closure criteria for corrective action tickets
Third party does downgrading, you keep no proof	You still own the risk	Contract for evidence, sample-verify outputs, and retain artifacts in your GRC system

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the source catalog. Practically, MP-8(2) failures raise exposure in incident response, contractual compliance, and audit findings because an untested downgrading process can lead to unintended data disclosure during reuse, repair, transfer, or disposal. ¹

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable program)

• Assign a single accountable owner for MP-8(2) and name backups.
• Build the downgrading equipment + workflow inventory.
• Collect current SOPs and reconcile “paper process” vs actual practice.
• Draft the MP-8(2) test plan with test cases and pass/fail criteria. ¹

By 60 days (run tests and close gaps)

• Execute tests for each in-scope downgrade method and media type.
• Centralize evidence (plan, results, logs) in one place for assessor retrieval.
• Open corrective actions for failures, with containment notes.
• Retest after fixes and attach closure evidence to the corrective action.

By 90 days (make it repeatable and auditable)

• Add recurring test scheduling and change-trigger triggers.
• Train operators and reviewers; update SOPs where tests revealed ambiguity.
• Add third-party evidence requirements for any outsourced downgrading.
• In Daydream, map MP-8(2) to the owner, procedure, and recurring evidence request so quarterly/annual assessments become a pull, not a scramble. ¹

Frequently Asked Questions

What counts as “downgrading equipment” for MP-8(2)?

Any tool or device you rely on to reduce the sensitivity of media or components, such as degaussers, sanitization stations, imaging systems, or other mechanisms. If it supports a downgrade decision, treat it as in scope and test it. ¹

Do I have to test both the tool and the human procedure?

Yes. The requirement explicitly includes “equipment and procedures,” so tests must validate the technical action and the operational steps around it (custody, approvals, settings selection, documentation). ¹

How do I set pass/fail criteria without over-engineering it?

Tie pass criteria to the downgrade outcome you need to prove, then add a reviewer check. Keep criteria consistent per media type and downgrade method so results are comparable over time.

We outsource ITAD. How do we meet MP-8(2) if a third party does the downgrading?

Contract for testable evidence (certificates, logs, chain-of-custody) and run your own sample verification where feasible. Your audit file should show you can validate the third party’s downgrading actions were achieved. ¹

What evidence is most likely to satisfy an assessor quickly?

A single test plan, recent test execution records with tool outputs, and a closed-loop remediation-and-retest trail for any failures. Put them in a single evidence package mapped to MP-8(2). ¹

What is the fastest way to operationalize this in a GRC workflow?

Create one control record for MP-8(2) with a named owner, a recurring evidence task for test results, and a required attachment list (plan, results, logs, remediation tickets). Daydream supports this mapping so evidence stays current between assessments. ¹

Footnotes

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