PE-3(5): Tamper Protection

PE-3(5): Tamper Protection requires you to deploy physical tamper-protection measures that prevent, detect, or make evident any unauthorized physical tampering or alteration of system components. To operationalize it quickly, define which components need protection, select approved tamper controls (for facilities, racks, devices, and ports), and retain evidence that protections are installed, monitored, and responded to. ¹

Key takeaways:

• Scope first: identify which system components require tamper protection, including third-party hosted and on-prem assets.
• Controls must be operational: installed protections plus inspection/monitoring and incident response handling.
• Evidence wins audits: installation records, inspection logs, exceptions, and corrective actions tied to assets.

The pe-3(5): tamper protection requirement is a physical security control enhancement in NIST SP 800-53 Rev. 5 that focuses on preventing or detecting unauthorized physical tampering with system components. This shows up in audits when assessors ask a simple question: “How do you know nobody has physically altered the equipment that runs your system?”

Most programs fail PE-3(5) for predictable reasons: the control is described in policy language, but the organization cannot show which assets are in scope, what tamper protections are present, who checks them, and what happens when something looks off. Another common gap is treating co-located data centers or third-party managed environments as “out of scope,” even though the system still relies on those components.

This page gives requirement-level implementation guidance you can hand to facilities, IT operations, and security operations. The goal is a repeatable control: a documented standard for tamper protection, consistent deployment across in-scope environments, inspection and response workflows, and a clean evidence bundle that stands up to federal customer diligence.

Regulatory text

NIST SP 800-53 Rev. 5 PE-3(5) excerpt: “Employ {{ insert: param, pe-03.05_odp.01 }} to {{ insert: param, pe-03.05_odp.02 }} physical tampering or alteration of {{ insert: param, pe-03.05_odp.03 }} within the system.” ¹

What the operator must do

You must implement physical measures that (a) prevent tampering, (b) detect tampering, and/or (c) make tampering evident, for the system’s components. The open parameters in the excerpt are organization-defined, meaning you must decide:

• which types of tamper protection you will use,
• what actions they must achieve (prevent/detect/evident),
• which components they apply to.

Treat this as an engineering-and-operations requirement, not a policy requirement. Auditors will look for deployed controls and operating records, not a narrative statement.

Plain-English interpretation (what “good” looks like)

If someone opens a rack, swaps a drive, adds a rogue device, unplugs a sensor, or connects to an unattended port, your environment should either stop it or leave clear signs that trigger investigation. “Tamper protection” can be mechanical (locks, sealed enclosures), procedural (two-person access, escorted access), or technical (cameras, alarms, access logs), but PE-3(5) expects you to use controls that directly address physical tampering or alteration of components that support the system.

Who it applies to

Entity types

• Federal information systems
• Contractor systems handling federal data ¹

Operational contexts where PE-3(5) commonly applies

• On-prem data centers and server rooms (racks, patch panels, KVMs, storage arrays)
• Branch offices and wiring closets (network gear in less-controlled spaces)
• Co-location facilities (you control your cage/racks; the facility controls the perimeter)
• Cloud/hosted environments (you may not control the physical layer, but you still need assurance artifacts and contract terms from the third party)
• End-user equipment supporting the system (kiosks, hardened workstations, specialized devices)

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

Step 1: Define in-scope components (asset-backed scope)

Create an inventory slice for “tamper-protection required” components. Minimum categories:

• Compute (servers, appliances)
• Network (switches, routers, firewalls, wireless controllers)
• Storage (SAN/NAS, removable media storage locations)
• Management interfaces (console ports, OOB management devices)
• Critical cabling/patching areas (patch panels, cross-connects)
• Any device in publicly accessible or low-supervision areas

Deliverable: Scope statement + asset list/report tied to your CMDB or inventory source.

Step 2: Choose your tamper protection methods (standard catalog)

Build a small standards catalog with approved methods per environment type. Example control families to include:

• Physical barriers: locked racks, locked rooms, cages, secured enclosures
• Tamper-evident controls: tamper seals/tape on chassis or ports, serialized seals with logs
• Detection/monitoring: access control logs, door sensors, alarms, cameras covering ingress/egress
• Port and interface control: port blockers for unused ports, locked patch panels, covered/secured console ports
• Chain-of-custody procedures: receiving, staging, repairs/RMA, disposal, and technician escort rules

Avoid a “pick anything” approach. Auditors want consistency and rationale. Where you cannot deploy a method (example: cloud physical servers), you need an assurance alternative (see Step 6).

Deliverable: Tamper Protection Standard (1–3 pages) mapping component types to required protections.

Step 3: Assign ownership and run cadence (make it operable)

Create a control card (runbook) that answers:

• Control owner (Facilities, IT Ops, Security, or shared)
• Trigger events: new site, new rack, hardware refresh, incident, access exception
• Operating cadence: inspections, seal checks, camera review sampling, access log review
• Escalation: what constitutes suspected tampering, who investigates, and who approves return-to-service

This addresses a common audit failure: teams cannot show who runs the control, how often, and what evidence proves operation. ¹

Deliverable: Control card/runbook with RACI and workflow.

Step 4: Implement controls in each environment (deployment checklist)

Use a checklist per site or room:

• Rooms with controlled access (badge + visitor logs where applicable)
• Racks locked; keys controlled; access tracked
• Tamper-evident seals applied to defined components; seal IDs recorded
• Cameras positioned and retention aligned to your security monitoring approach
• Console ports and unused network ports blocked or secured
• “No lone access” or escort rules applied where risk is higher (example: shared facilities)

Deliverable: Site implementation checklist signed by implementer and reviewer.

Step 5: Add inspection, monitoring, and response (prove detection works)

Define what “normal” looks like and what you will review:

• Seal integrity checks and reconciliation of seal IDs
• Rack/room access logs review for anomalies (after-hours, unusual frequency, unauthorized roles)
• Camera review workflow (event-driven or sampling)
• Incident workflow: quarantine device, preserve evidence, re-image/rebuild, credential rotation if warranted, and root-cause analysis

Deliverable: Inspection logs + incident tickets tied to assets.

Step 6: Cover third-party environments (contracts + assurance)

If a third party controls the physical facility (cloud provider, co-lo, managed hosting), PE-3(5) still requires tamper protection for system components. Your implementation becomes assurance-driven:

• Contract/SOW language requiring physical security and tamper controls appropriate to the service
• Independent assurance artifacts (for example, third-party audit reports provided under NDA) and documented review
• A shared responsibility statement: what they do, what you do, and what you verify

Deliverable: Third-party assurance packet and documented review notes.

Step 7: Manage exceptions with compensating controls

Common exceptions: legacy racks without locks, remote sites without cameras, lab environments, field devices. Define:

• Time-bound exception approval
• Compensating controls (increased inspections, restricted hours, additional logging)
• Remediation plan with an accountable owner

Deliverable: Exception register with approvals and closure evidence.

Required evidence and artifacts to retain

Use an “evidence bundle” approach so audits don’t turn into a scavenger hunt.

Evidence	What it proves	Where it usually lives
Tamper Protection Standard	You defined organization-approved tamper methods and scope	GRC repository / policy system
Asset scope list for PE-3(5)	Which components are protected	CMDB export / inventory report
Site/rack deployment checklists	Protections are installed	Facilities ticketing, change records
Seal logs (serialized IDs)	Tamper-evident controls are controlled and tracked	Spreadsheet with access control, ticket attachment
Access control logs / visitor logs	Physical access is controlled and reviewable	Physical access system, facility portal
Inspection records	Ongoing operation of the control	GRC evidence system, ticketing
Incident tickets for suspected tampering	You respond and remediate	IR platform, SIEM case management
Exceptions register	Deviations are approved and managed	GRC system

Common exam/audit questions and hangups

Expect these, and pre-answer them in your evidence bundle:

1. “Which components are in scope for tamper protection?”
   Hangup: you provide a policy statement with no asset list.

2. “Show me tamper protection on these specific assets.”
   Hangup: seals exist but are not tracked; racks are locked but key control is informal.

3. “How do you detect tampering, not just prevent it?”
   Hangup: locks exist, but no inspections, no log review, no defined response criteria.

4. “How does this work in a cloud or third-party facility?”
   Hangup: you say “the provider handles it” without documented assurance review.

5. “Who owns the control and how do you know it’s operating?”
   Hangup: unclear RACI; evidence is ad hoc. This is a known risk factor for audits and diligence. ¹

Frequent implementation mistakes (and how to avoid them)

• Mistake: treating tamper seals as a one-time install.
  Fix: require seal ID logging, periodic integrity checks, and a resealing procedure after approved maintenance.

• Mistake: forgetting ports and patching infrastructure.
  Fix: include console ports, patch panels, and exposed network jacks in the standard. Tampering often happens at the easiest physical touchpoint.

• Mistake: no defined “suspected tampering” playbook.
  Fix: write a short decision tree: isolate device, preserve logs, notify security, rebuild or validate hardware integrity before returning to service.

• Mistake: third-party physical controls are assumed, not verified.
  Fix: require assurance artifacts and document your review results and follow-ups.

• Mistake: exceptions become permanent.
  Fix: time-bound approvals and recurring review of open exceptions; tie to remediation work orders.

Enforcement context and risk implications

NIST SP 800-53 is a control framework, not a penalty schedule. The risk is practical: physical tampering can bypass logical controls, implant hardware or intercept traffic, and undermine integrity of systems handling federal data. The compliance impact shows up as audit findings, delayed authorizations, customer trust erosion, and expensive incident response when physical access is poorly controlled. Your best defense is a clean chain from scope → deployed protections → ongoing checks → response evidence. ²

Practical execution plan (30/60/90)

You asked for speed. Use this phased plan and keep deliverables tight.

First 30 days (establish scope + minimum viable control)

• Publish the PE-3(5) control card: owner, triggers, workflow, evidence list.
• Produce the in-scope component list and prioritize high-risk locations (shared spaces, remote sites, public-facing areas).
• Approve a short Tamper Protection Standard with required methods by environment type.
• Start an exceptions register immediately so gaps are documented rather than hidden.

By 60 days (deploy + start operating cadence)

• Implement locks/seals/port blockers for prioritized assets and sites; attach deployment checklists to change tickets.
• Turn on recurring inspections and access-log review; ensure findings produce tickets with owners and due dates.
• For third-party hosted environments, collect assurance artifacts and document your review and any follow-up questions.

By 90 days (prove sustained operation + close the loop)

• Run a control health check: pick a sample of assets and trace end-to-end evidence (inventory → deployment → inspection → issues closed).
• Test the suspected-tampering workflow with a tabletop exercise and capture outputs.
• Review exceptions for closure, compensating controls, or risk acceptance renewals.

Daydream note (earned, not forced): if you struggle to keep the control card, evidence bundle, and recurring health checks consistent across sites and third parties, Daydream’s GRC workflows help standardize the runbook, automate evidence collection requests, and track remediation to validated closure.

Frequently Asked Questions

Do tamper-evident seals alone satisfy PE-3(5)?

Seals help, but auditors usually expect an operating process: seal tracking, inspection, and response when a seal is broken. Pair seals with access controls and a documented investigation workflow. ¹

How do we handle PE-3(5) in a public cloud where we don’t control the data center?

Treat it as an assurance requirement: contract terms plus independent assurance artifacts and documented review. Keep a shared-responsibility write-up showing what the provider does and what you verify. ²

What counts as “system components” for tamper protection?

Focus on components whose physical alteration could affect confidentiality, integrity, or availability: servers, network gear, storage, and management interfaces. Include patching areas and exposed ports when they are part of your system boundary. ¹

We have locked server rooms, but no inspection logs. Is that a problem?

Yes in many audits, because PE-3(5) expects measures to detect or make tampering evident, not only restrict access. Add periodic checks (seals, rack condition) and retain inspection records tied to assets.

How strict should key control be for rack locks?

Define who can access keys, how issuance is tracked, and what happens when staff leave or keys are lost. Auditors look for a controlled process, not informal “everyone knows where the key is.”

What evidence is most persuasive during an assessment?

Asset-scoped deployment records plus recurring inspection/log review records, with a few examples of findings remediated to closure. A clean evidence bundle reduces follow-up questions and shortens fieldwork.

Footnotes

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

2. NIST SP 800-53 Rev. 5