PE-6: Monitoring Physical Access

To meet the pe-6: monitoring physical access requirement, you must actively monitor physical entry and activity at the facility where your system resides, then detect, triage, and respond to physical security incidents based on defined procedures and retained evidence ¹. Operationalize it by assigning an owner, standardizing monitoring methods (logs/video/guards), and proving ongoing review and incident response.

Key takeaways:

• PE-6 expects continuous or routine monitoring plus documented response, not just locks and badges ¹.
• Your pass/fail hinges on evidence: monitored events, review records, incident tickets, and follow-up actions.
• Scope is the facility where the system resides, including data centers, comm rooms, and any colocation space in your boundary ¹.

PE-6 sits in the Physical and Environmental Protection (PE) family and is easy to under-implement because many teams confuse “access control” with “access monitoring.” Access control answers: “Who can get in?” Monitoring answers: “What happened, how do we know, and what did we do about it?” Auditors usually focus on the second question because it tests whether your physical security program can detect misuse, tailgating, forced entry, off-hours access, or unauthorized presence near sensitive systems.

The control statement is short, but execution requires alignment across Facilities/Security, IT/Cloud, and the system owner. You need clear boundaries (which rooms and cages count), reliable sources of monitoring data (badge logs, visitor logs, camera coverage, guard rounds, intrusion alarms), and a repeatable review/response workflow that produces artifacts.

This page is written for a Compliance Officer, CCO, or GRC lead who needs to implement PE-6 quickly, stand up durable evidence, and be ready for assessor questions without turning physical security into an endless project.

Regulatory text

Requirement (PE-6): “Monitor physical access to the facility where the system resides to detect and respond to physical security incidents;” ¹

Operator meaning: You must (1) monitor physical access events in the facility environment that houses the system, (2) detect potentially suspicious or unauthorized physical activity, and (3) respond through an established incident process. “Monitor” implies you have telemetry (logs/feeds/checks), you review it on a defined cadence, and you can show what happens when anomalies occur ².

Plain-English interpretation (what PE-6 is really asking)

Implement PE-6 as an operational loop:

1. Collect physical access signals (badge events, visitor sign-ins, camera footage, alarm events, guard logs).
2. Review those signals to identify anomalies or policy violations (after-hours entry, repeated denied attempts, unescorted visitors, door forced open).
3. Respond with documented actions (investigation, escalation, corrective actions, and where needed, security incident handling).
4. Retain evidence that the loop runs consistently and produces outcomes.

If you cannot show regular monitoring plus responsive action, PE-6 will read as “designed but not operating.”

Who it applies to (entity + operational context)

Entities:

• Federal information systems and contractors handling federal data commonly map to NIST SP 800-53 controls, including PE-6 ².

Operational contexts in scope:

• On-prem facilities you control (HQ, branch offices, data centers, labs).
• Shared buildings where you control a suite/floor but not the lobby. Your monitoring scope starts at your controlled perimeter and extends to system rooms.
• Colocation where the “facility where the system resides” may be a cage, cabinet row, or meet-me room you contract for. You still need monitoring evidence, even if it’s provided by the third party.
• Dedicated system spaces: server rooms, network closets, media storage rooms, and any space housing system components in your authorization boundary.

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

Step 1: Define “the facility where the system resides”

Create a short, assessor-readable scope statement:

• Name the sites and rooms/areas in scope (e.g., “Data Center A cage C12, Network Closet 4B, Media Safe Room”).
• Identify physical perimeters and controlled access points (doors, turnstiles, mantraps, cage doors).
• Map each area to the system boundary in your SSP or equivalent system documentation.

Output: Physical security scope for the system, aligned to PE-6 ².

Step 2: Assign ownership and RACI

PE-6 fails most often because “Facilities owns doors” but “Security owns incidents” and “IT owns systems,” and nobody owns the control end-to-end.

Minimum assignments:

• Control owner: accountable for PE-6 operation and evidence readiness.
• Operators: Facilities/security team or managed security provider who reviews logs/feeds.
• System owner: confirms scope and ensures monitoring covers system-resident areas.
• GRC: validates artifacts and testing.

Tip: Put the owner and evidence list into your control library. Daydream is useful here because it lets you map PE-6 to an owner, a procedure, and recurring evidence so the control stays audit-ready instead of living in email threads.

Step 3: Select monitoring mechanisms (choose at least two, then document coverage)

Use mechanisms appropriate to the site risk and constraints. Common options:

• Electronic access control system (PACS) badge logs for doors/cages.
• Visitor management logs (sign-in/out, escort requirement, badge issuance).
• Video surveillance coverage at entrances and sensitive rooms, with retrieval procedures.
• Intrusion detection/alarms (forced door, propped door).
• Guard force/roving patrol logs and after-hours checks.

Document:

• What each mechanism covers (which doors/areas).
• How long records are retained.
• Who can retrieve records and under what authorization.

Step 4: Define what counts as a “physical security incident”

Write a tight incident taxonomy for physical access, with examples assessors recognize:

• Unauthorized entry or attempted entry (multiple denies, door forced).
• Tailgating/piggybacking (detected via guard/camera review).
• Unescorted visitor in restricted areas.
• Door held/propped open.
• Missing/compromised keys or badges.
• Evidence of tampering with racks, cages, network gear, or media storage.

Then map each to:

• Severity level
• Escalation path (Facilities → Security → IT → Legal/HR as needed)
• Required ticket fields and evidence capture

Step 5: Implement a monitoring and review cadence (and prove it happened)

PE-6 does not require a specific frequency in the provided text, so pick a cadence that matches site sensitivity and can be sustained.

Define:

• Daily/shift checks for high-sensitivity areas (data centers, media rooms) if feasible.
• Routine review of badge exceptions and after-hours activity.
• Monthly trend review for denied attempts, repeated alarms, or door issues.

Evidence must show:

• Review occurred (date/time, reviewer, source reviewed).
• Findings (including “no exceptions”).
• Follow-ups (tickets, maintenance, access revocations).

Step 6: Build the response workflow (detect → triage → contain → correct)

Your procedure should specify:

1. Trigger: what event starts the workflow (alarm, anomalous badge event, visitor violation).
2. Triage: validate event (cross-check badge log + visitor log + camera footage where available).
3. Containment: dispatch guard, lock down area, disable badge, escort out, preserve footage.
4. Investigation: root cause (policy violation, system issue, malicious attempt).
5. Corrective actions: door repair, policy retraining, access list cleanup, third-party corrective action.
6. Closure: approve closure, document lessons learned.

Tie the workflow to your broader incident handling program where appropriate. PE-6 is physical, but the response must still be trackable and auditable ².

Step 7: Extend monitoring to third-party facilities (colocation, managed data centers)

If the system resides in a third-party site:

• Contractually require access monitoring, logging, and incident notification.
• Obtain recurring evidence (samples of access logs, SOC reports, visitor logs, incident summaries).
• Confirm your rights to retrieve footage/logs for investigations.
• Document your review of third-party deliverables and how you action issues.

This is where third-party risk management meets PE-6. Your assessor will still expect you to show monitoring and response, even if the telemetry is produced by a provider.

Required evidence and artifacts to retain

Keep evidence in a format that is easy to sample and hard to dispute.

Evidence artifact	What it proves	Owner
Physical access monitoring procedure (PE-6)	Defined monitoring + response method 1	Security/GRC
Scope statement + facility/room list	What “facility where the system resides” means for this system	System owner
Door/cage inventory and monitoring coverage map	Monitoring mechanisms cover all scoped access points	Facilities/Security
Badge/access logs (samples)	Access events are recorded	Facilities/Security
Visitor logs and escort records	Visitor activity is tracked	Reception/Security
Review attestations / exception reports	Monitoring is actually performed	Security
Incident tickets for physical events	Detection-to-response is working	Security/IT
Corrective action records	Issues are fixed and tracked	Facilities/Security
Third-party reports/records (if applicable)	Colocation/third party monitoring exists + you review it	TPRM/GRC

Practical retention tip: Align retention to your internal security logging and investigation needs. PE-6’s text does not specify a retention period, so your policy should state one and your artifacts should match it ¹.

Common exam/audit questions and hangups

Assessors tend to ask for proof that monitoring is real, consistent, and covers the right places.

Expect these:

• “Show me the doors and areas in scope for this system. How do you know you didn’t miss a closet or cage?”
• “Who reviews badge exceptions, and where is that documented?”
• “Show me two examples of investigations from monitoring signals (alarm, denied entry, off-hours entry).”
• “How do you monitor visitor access and enforce escorts?”
• “For colocation, what evidence do you receive, and how do you validate it?”
• “Can you retrieve camera footage for a specific time window, and who authorizes that?”

Hangups:

• Monitoring exists but no one can show review records.
• Camera coverage exists but retrieval is ad hoc and not tied to incidents.
• Scope mismatch: system SSP says “Data Center A,” but monitoring artifacts are for “HQ lobby.”

Frequent implementation mistakes (and how to avoid them)

1. Treating badging as sufficient. Badge systems control access, but PE-6 asks you to monitor to detect and respond ¹.
   Avoidance: Create exception reports and a documented review trail.

2. No defined incident threshold. Teams collect logs but can’t say what constitutes a physical incident.
   Avoidance: Publish a small set of triggers and map them to ticket workflows.

3. No coverage map. You have cameras, but you cannot prove every sensitive door is monitored.
   Avoidance: Maintain a door/cage inventory with “monitoring method” and “evidence source.”

4. Third-party blind spot. Colocation provider “handles security,” but you have no artifacts.
   Avoidance: Add contract clauses and recurring evidence requests; track review in your GRC system.

5. Evidence is scattered. Facilities has logs, security has footage, GRC has a policy, and nothing ties together.
   Avoidance: Centralize PE-6 in a control record with owner, procedure, and recurring evidence tasks. Daydream can keep the owner/evidence mapping stable as teams change.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite enforcement actions.

Operational risk still matters: weak monitoring increases the chance that unauthorized physical access goes undetected long enough to enable device tampering, theft of media, or insertion of rogue equipment. PE-6 reduces dwell time by forcing detection and documented response ².

A practical 30/60/90-day execution plan

First 30 days (baseline and scope)

• Confirm the system-resident facilities and controlled areas; publish the scoped door/room list.
• Assign a PE-6 control owner and identify operators for logs, cameras, and visitor management.
• Inventory monitoring sources (PACS, VMS, visitor system, alarms) and confirm access to retrieve records.
• Draft the PE-6 procedure: monitoring inputs, review steps, incident triggers, escalation, and evidence.

Next 60 days (operationalize and create evidence)

• Stand up exception reporting (denied attempts, after-hours access, door forced/propped events).
• Start routine reviews and store the review outputs in a single repository.
• Run a tabletop for a physical access incident (tailgating, forced door, unescorted visitor) and test ticketing, escalation, and evidence capture.
• For colocation/third parties: request sample logs and incident notifications; document your review.

By 90 days (stabilize and audit-ready)

• Validate full coverage: every scoped door/area has a monitoring method and an artifact trail.
• Close gaps: camera blind spots, missing visitor logs, inconsistent after-hours reviews.
• Perform an internal control test: select a time window, trace badge events to review records, then to tickets (if any), and confirm corrective actions.
• Put PE-6 on a recurring compliance calendar (reviews, access audits, evidence sampling).

Frequently Asked Questions

Does PE-6 require video cameras?

The text requires monitoring to detect and respond to physical security incidents, but it does not mandate a specific technology ¹. Cameras are common evidence, but badge logs, visitor logs, alarms, and guard logs can also support monitoring.

What facilities are “where the system resides” for a hybrid environment?

Scope any facility space that houses system components within your boundary, such as on-prem server rooms and colocation cages ¹. Document the boundary clearly so the monitoring evidence maps to the right places.

How do I show “respond” for PE-6 if we haven’t had incidents?

Maintain a defined procedure and show operational monitoring reviews with “no exceptions” findings, plus a tested response workflow (tabletop or drill) recorded as an exercise artifact ². If you do have minor issues (e.g., door propped), tickets and corrective actions are strong evidence.

What’s the minimum evidence an auditor will accept?

Expect to provide the procedure, a scope/coverage map, monitoring records (logs or reports), proof of periodic review, and at least one example of investigation or corrective action if available ¹. If monitoring is outsourced, add third-party deliverables and your review notes.

How do we handle employee privacy concerns with access monitoring?

Document who can access badge logs and footage, for what purposes (security and investigations), and require approvals for retrieval. Keep access restricted and logged, and align the process with HR/legal guidance for your jurisdiction.

We’re in a shared office building. Are we responsible for lobby monitoring?

You are responsible for monitoring physical access to the facility where the system resides, which usually means your controlled perimeter and restricted areas ¹. If building access is a dependency, document it as a third-party control and retain the building’s relevant assurances where possible.

Footnotes

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

2. NIST SP 800-53 Rev. 5