PE-1: Policy and Procedures

The pe-1: policy and procedures requirement means you must create, document, and distribute a Physical and Environmental Protection (PE) policy and supporting procedures to defined audiences, then operate them with clear ownership and evidence. To operationalize it fast, assign a control owner, publish a PE policy, publish implementable procedures, and set up recurring proof that people received and followed them. ¹

Key takeaways:

• Write one PE policy plus implementable procedures, not a single “policy-only” document. ²
• Define recipients and dissemination method, then retain evidence that distribution occurred. ²
• Map PE-1 to an owner, a runbook, and recurring evidence artifacts so audits don’t stall on “show me.” ¹

PE-1 sits in the Physical and Environmental Protection control family and sets the baseline expectation for governance: you have a policy that states management intent and requirements, and you have procedures that translate that intent into repeatable operations. The regulatory text you are assessed against is short, which creates a common trap: teams publish a generic “physical security policy” and assume they are done, but assessors often test whether procedures exist, whether they were disseminated to the right audiences, and whether the organization can produce evidence on demand.

For federal information systems and contractor systems handling federal data, PE-1 is also a control that tends to expose program maturity. If your PE controls are real but undocumented, you fail on evidence. If they are documented but not deployed to the teams that execute them, you fail on dissemination and operational use. The quickest path is to treat PE-1 as a packaging and accountability requirement: assign ownership, define scope, publish policy and procedures, distribute them, and build an evidence cadence that proves they are current and in use. ¹

Regulatory text

Excerpt: “Develop, document, and disseminate to {{ insert: param, pe-1_prm_1 }}:” ²

Operator interpretation of the excerpt

• Develop: create a PE policy and PE procedures that cover the PE control family for your system boundary (or enterprise program, if that is how your authorization is structured). ¹
• Document: maintain them in a controlled repository with versioning, approvals, and change history so you can show “what was in effect” during a period under audit. ¹
• Disseminate to [defined audiences]: identify who must receive the policy and procedures (for example: facilities/security operations, IT ops, data center staff, SOC, HR for onboarding hooks, and relevant third parties), then prove distribution occurred. The parameter in the excerpt represents those defined recipients in your implementation. ²

Plain-English requirement (what PE-1 is asking for)

You need two layers of governance:

1. A PE policy that states rules and management expectations for physical and environmental protection.
2. Procedures that tell operators exactly how those rules are carried out (who does what, in which tools, with what approvals, and what logs are kept).

Then you must send these documents to the people who need them and keep evidence that you did.

Who it applies to

Entity types

• Federal information systems.
• Contractor systems handling federal data. ¹

Operational context

• Any system boundary where you rely on physical controls: offices, data centers, colocation, labs, warehouses, or cloud operations where physical responsibility is inherited but still governed through third parties.
• Organizations with third parties that can affect physical access or environmental controls (building management, colocation providers, managed service providers, hardware maintenance firms). Treat them as part of dissemination and procedure scope where they execute steps on your behalf.

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

Step 1: Assign ownership and define scope

• Name a PE-1 control owner (often Facilities Security, Corporate Security, or a Security Governance lead), and document a backup.
• Define the system boundary: which sites, rooms, racks, or managed facilities are in scope; list excluded sites and why.
• Decide policy tiering: enterprise PE policy plus system-specific PE procedures is usually easiest for audits because you can show consistent intent plus tailored execution. ¹

Practical tip: If you cannot clearly state “who owns the policy” and “who runs the procedure,” the audit will turn into interviews and guesswork.

Step 2: Draft the PE policy (management intent)

Your PE policy should include, at minimum:

• Purpose and scope (sites, systems, and third parties in scope).
• Roles and responsibilities (security, facilities, IT, HR, managers, reception, third parties).
• Required control topics you expect procedures to implement (for example: physical access authorization, visitor management, monitoring, environmental safeguards, and incident reporting).
• Exception process (who can approve, documentation required, expiry and review).
• Review and update rules (event-driven updates, plus a recurring review cadence you define).

Keep the policy short and enforceable. Put operational detail in procedures.

Step 3: Write implementable PE procedures (the “how”)

Create procedures that are executable by the people doing the work. Common PE procedure modules include:

• Access provisioning and deprovisioning for facilities and restricted areas (request, approval, identity verification, badge issuance, termination triggers).
• Visitor management (sign-in, escorts, temporary badges, visitor logs retention).
• Physical monitoring (CCTV coverage expectations, access logs review, alarm response).
• Key/lock management (if applicable) and secure storage.
• Environmental controls (HVAC monitoring, fire suppression oversight, water leak detection, UPS/generator responsibilities where applicable).
• Third-party coordination (how you validate a colocation provider’s controls, how you handle technician access, and how you document inherited controls).

Each procedure should have:

• Preconditions, step-by-step tasks, and completion criteria.
• Who performs each step and who approves.
• Required records produced (ticket, log entry, report, or vendor attestation).

Step 4: Define dissemination targets and methods

Build a dissemination matrix:

• Audience (by role/team, not by person).
• Document(s) (policy and specific procedures).
• Distribution channel (GRC tool, policy portal, HR onboarding system, LMS, email with read receipt, third-party portal).
• Frequency (on publish; on material change; on onboarding to role).

Retain proof per audience that dissemination occurred. ²

Step 5: Operationalize evidence collection (so PE-1 is always “audit-ready”)

Map PE-1 to:

• A control owner.
• The implementation procedure(s).
• Recurring evidence artifacts you can produce without scrambling. ¹

Many teams implement this mapping in Daydream as a control record that links:

• Policy + procedures (current versions),
• Dissemination evidence,
• Review/approval workflow,
• A calendar of recurring evidence requests to facilities/security and key third parties.

Step 6: Run a tabletop “audit pull” before the auditor does

Ask your internal audit/GRC analyst to request: “Show me PE-1 evidence for the last period.” Time how long it takes to produce artifacts and fix gaps.

Required evidence and artifacts to retain

Maintain a PE-1 evidence package that includes:

• Approved PE policy (version, approval date, approver identity).
• PE procedures (versioned, with owners).
• Dissemination records:
  • Policy portal/LMS completion export, or
  • Email distribution list plus acknowledgement tracking, or
  • HR onboarding workflow that assigns required reading by role.
• Review history and change log (what changed and why).
• Exceptions register entries (if any) tied to PE scope.
• Evidence of the “mapping” auditors expect: control owner, procedure references, and recurring evidence list. ¹

Common exam/audit questions and hangups

Auditors and assessors frequently ask:

• “Who are the recipients for dissemination, and how did you decide?” Expect scrutiny if you only distributed to “All Employees” but not to the teams with operational duties.
• “Show me procedures, not just policy.” A policy with no procedures often fails the intent of “develop, document” for operational execution. ¹
• “Show me what was in effect last quarter.” Versioning and effective dates matter.
• “How do third parties fit?” If a third party manages a data center, you still need procedures for oversight, access requests, and evidence intake.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: A generic physical security policy copied from a template.
   Fix: Tie statements to your actual sites, access paths, and ownership model. Include the exception process you really use.

2. Mistake: Procedures exist only as tribal knowledge.
   Fix: Convert “how we do it” into step-by-step runbooks with required records (tickets/logs) called out explicitly.

3. Mistake: Dissemination is assumed, not evidenced.
   Fix: Choose one system of record (LMS, policy portal, GRC) and make it the default for tracking distribution and acknowledgement. ²

4. Mistake: No control mapping, so evidence requests become manual archaeology.
   Fix: Maintain a single PE-1 control record that links owner, documents, systems, and evidence cadence. Daydream’s control mapping workflow is a clean way to keep this current without rebuilding spreadsheets every audit cycle. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so treat PE-1 primarily as an assessment and authorization risk: failure typically shows up as control deficiencies during audits, authorization reviews, or customer due diligence rather than as a cited enforcement action in the provided materials. ¹

Operational risk is still real: unclear physical access rules and undocumented procedures can lead to inconsistent access grants, weak visitor handling, and gaps in third-party oversight. PE-1 reduces that risk by making expectations explicit, assigned, and repeatable. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize governance)

• Assign PE-1 owner and backups; define in-scope sites and third parties.
• Inventory existing documents and actual practices (badge issuance, visitor logs, CCTV, environmental monitoring responsibilities).
• Draft PE policy and identify required procedures; start version control and approval workflow in your system of record. ¹

Days 31–60 (publish and disseminate)

• Finalize and approve the PE policy.
• Publish priority procedures: access provisioning/deprovisioning and visitor management first.
• Build and execute the dissemination plan by role; capture acknowledgements or training completion exports as evidence. ²

Days 61–90 (evidence hardening and audit pull)

• Add procedures for monitoring, incident reporting, and third-party coordination.
• Create the PE-1 evidence pack and run an internal “audit pull” test.
• In Daydream (or your GRC tool), map PE-1 to the control owner, procedure links, and recurring evidence artifacts so the next assessment is retrieval, not recreation. ¹

Frequently Asked Questions

Do I need both a policy and procedures for PE-1?

Yes. The requirement explicitly calls for developing, documenting, and disseminating policy and procedures as part of the control family governance expectation. Assessors commonly expect a policy document plus implementable runbooks. ¹

Who should receive PE policy and procedures?

Define recipients based on who approves, executes, or oversees physical and environmental controls, including relevant third parties where they perform steps for you. Then keep evidence that those audiences received the documents. ²

We use a cloud provider. Do PE procedures still apply?

Yes, but they shift toward oversight: how you control office access, how you authorize any physical handling of assets, and how you obtain and review third-party physical security assurances for inherited facilities controls. ¹

What evidence is “good enough” for dissemination?

Use a system report that shows the document, the audience, and the acknowledgement or assignment status (policy portal, LMS export, or tracked distribution). Store it with the policy version in effect. ²

How often do we have to review the PE policy?

NIST expects policies and procedures to be maintained; set a recurring review cadence and also update on material change (new site, new access system, major third-party change). Document the review and any resulting updates. ¹

What’s the fastest way to stop PE-1 from becoming a scramble every audit?

Maintain a single control record that maps PE-1 to the owner, the exact policy/procedure versions, and a standing list of recurring evidence artifacts. Many teams manage this cleanly in Daydream because the evidence links and assignments stay attached to the control. ¹

Footnotes

1. NIST SP 800-53 Rev. 5

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