PE-9: Power Equipment and Cabling

To meet the pe-9: power equipment and cabling requirement, you must protect all system-related power equipment and power cabling from damage or destruction through physical safeguards, controlled routing, and maintenance practices, then keep evidence that these protections exist and operate. Operationalize PE-9 by mapping scope, implementing facility standards, and collecting repeatable inspection and change records.

Key takeaways:

• PE-9 is a physical protection requirement for power paths (cabling, PDUs, UPS, generators, panels) that support your system.
• Auditors look for two things: real-world protection measures and reliable evidence (diagrams, inspections, work orders, photos).
• Treat power as a dependency with change control; most PE-9 failures happen during moves, adds, and changes.

PE-9 sits in the Physical and Environmental (PE) family of NIST SP 800-53 Rev. 5 and targets a common root cause of outages and evidence gaps: unmanaged power infrastructure. The control is short, but the implementation surface area is not. “Power equipment and cabling” includes the visible pieces (power strips, cords) and the upstream dependencies (panels, PDUs, UPS, generator feeds) that keep your system running.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat PE-9 like an operations-backed requirement with a clear owner (typically Facilities, Data Center Ops, or a cloud colocation provider) and a tight boundary definition. Your job is to convert “protect from damage and destruction” into enforceable standards: where cables can run, how they are labeled, how they are shielded, who can alter them, and how you prove all of that on demand.

This page gives you requirement-level implementation guidance you can hand to facilities and IT operations, plus an evidence checklist to pass assessments without scrambling.

Regulatory text

Requirement (PE-9): “Protect power equipment and power cabling for the system from damage and destruction.” ¹

What the operator must do: Implement physical and procedural controls that reduce the likelihood that power components supporting the system are cut, crushed, unplugged, overheated, exposed to water, tampered with, or otherwise damaged, and be able to demonstrate those controls operate in the real world. The control intent is resilience and safety for system availability, integrity, and incident prevention ².

Plain-English interpretation (what PE-9 really means)

PE-9 expects you to treat the system’s power path like critical infrastructure. That means:

• You know where power enters, how it is distributed, and which equipment and cables support in-scope systems.
• You protect that equipment and cabling from common physical risks (accidental, environmental, and malicious).
• You control changes so “temporary” power fixes do not become permanent risk.
• You can prove all of the above with records that align to how the environment actually looks today.

If you are in a cloud environment, you still own PE-9 at the governance level. The physical protections may be inherited from the cloud provider or colocation facility, but you must document the inheritance and keep current evidence.

Who it applies to

PE-9 applies wherever the system runs, including:

• Federal information systems and supporting facilities ².
• Contractor systems handling federal data, including on-prem data centers, colocation cages, network rooms, and edge closets ².

Operational contexts where PE-9 shows up in audits:

• Data centers and server rooms with PDUs/UPS.
• Network closets (IDFs/MDFs) where power cords are exposed and frequently touched.
• Lab environments where equipment moves often.
• Remote/branch locations where physical protections are weaker.
• Colocation or managed hosting where your evidence depends on third-party attestations and site procedures.

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

1) Define scope and ownership (make it auditable)

• Name a control owner (Facilities, Data Center Ops, or a designated third party relationship owner for colo/cloud).
• Define “system power infrastructure” for PE-9: UPS units, PDUs, rack power strips, power whips, breakers/panels feeding the room, generator interfaces if applicable, and all cabling from source to device.
• Document boundaries: which rooms, cages, racks, and upstream feeds are included.

Deliverable: a one-page PE-9 control statement in your SSP/control matrix that states what is in scope, who operates it, and which evidence is produced.

2) Inventory and map the power path (minimum viable mapping)

Build a practical map you can maintain:

• Room/rack-level power diagram: panel → UPS → PDU → rack → critical devices.
• Cable routing summary: overhead trays, underfloor, conduit, or within racks.
• Identify single points of failure where one damaged cable or PDU can drop multiple critical components.

You do not need perfect CAD drawings to start. You do need a traceable, current representation that matches how work orders are executed.

3) Implement physical protections for equipment

Set standards that reduce physical damage and tampering:

• Secure placement: UPS/PDUs/panels in locked rooms or locked cages; restrict access to authorized roles.
• Environmental protections: keep power equipment away from water sources, leaks, and high-traffic pathways where carts and ladders hit gear.
• Mechanical protection: use racks, enclosures, guards, or barriers where equipment is exposed (common in closets and shared spaces).
• Load management practices: prevent unsafe daisy-chaining, overloaded strips, and ad-hoc extensions that increase fire and outage risk.

Auditors will ask whether these are enforced standards or “tribal knowledge.” Put them in a facility standard and tie to change control.

4) Implement physical protections for cabling (where most findings occur)

Cabling is often the weak point because it is easy to change without tickets.

• Controlled routing: run cabling in trays, underfloor pathways, or conduit. Avoid floor runs in walkways and pinch points.
• Strain relief and retention: use rack cable management arms, ties/velcro, and retention clips to reduce accidental unplugging.
• Segregation and labeling: label both ends and separate critical power paths from non-critical where practical to avoid “wrong cord” events during maintenance.
• Tamper resistance: in shared spaces, protect accessible cords (locked racks, blanking panels, locked power distribution areas).

5) Add operational control: change management + maintenance

PE-9 breaks during “quick changes.”

• Require tickets for power work (adds/moves/changes) that affect in-scope racks or rooms.
• Maintain an inspection routine for cable condition (cuts, frays, heat discoloration), routing compliance, and unauthorized power devices.
• Ensure incident response or facilities procedures include “power integrity checks” after work in affected areas.

6) Third party dependency handling (colo/cloud)

If a third party operates the facility:

• Document which PE-9 elements are inherited and which you manage (for example, you may control within-rack cabling while the provider controls upstream feeds).
• Collect provider evidence (attestations, site procedures, facility diagrams as available) and pair it with your own rack-level practices.
• Include PE-9 expectations in contracts or operating procedures where you can, especially around access control, escort rules, and maintenance windows.

Daydream tip (practical, not theoretical): create a PE-9 evidence task in your compliance calendar that automatically requests the same provider artifacts on a schedule, and store them alongside your internal inspection records so audits do not turn into email archaeology.

Required evidence and artifacts to retain

Keep evidence that shows design + operation. A strong PE-9 package usually includes:

Design / configuration

• Power one-line or room/rack power diagrams (current version).
• Data center/closet layout showing protected routing zones (photos can supplement).
• Facility standard or SOP: acceptable cable routing, prohibited practices, and required protections.

Operational proof

• Work orders/tickets for power changes (adds/moves/repairs) affecting in-scope areas.
• Inspection checklists and results (including remediation tracking).
• Access logs or visitor/escort records for power rooms/cages where applicable.
• Photo evidence of protected cabling and secured equipment (date-stamped and tied to location).
• Exception register for known deviations (temporary power while awaiting parts) with expiration and approvals.

Common exam/audit questions and hangups

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

• “Show me where your system power cabling is routed and how it’s protected.”
• “How do you prevent accidental unplugging during maintenance?”
• “Who is allowed to modify rack power, and how do you know changes are authorized?”
• “How do you detect damaged cabling before it causes an outage?”
• “Which portions of PE-9 are inherited from your third party facility, and what evidence supports that?”
  Hangup to avoid: handing over a policy that says “protect cabling” without diagrams, tickets, photos, and inspection records.

Frequent implementation mistakes (and how to avoid them)

1. Writing a policy instead of implementing routing standards.
   Fix: publish a simple facility standard with pictures: good/bad routing, retention requirements, and “no floor runs.”

2. No owner because “facilities owns it.”
   Fix: assign a control owner in GRC and a facilities operator accountable for evidence production.

3. Evidence exists but is not tied to system scope.
   Fix: label rooms/racks as in-scope, and make inspection/ticketing tags include that scope label.

4. Temporary cabling becomes permanent.
   Fix: require exceptions with an expiry date and a remediation ticket.

5. Assuming cloud means PE-9 is irrelevant.
   Fix: document inheritance and keep provider artifacts; auditors still expect a clear story ².

Risk implications (why this control gets attention)

PE-9 is an availability and safety control with security spillover. Damaged power cabling can cause outages, unsafe conditions, and uncontrolled shutdowns that increase the chance of data corruption. Poorly controlled power access also creates an easy sabotage path in shared environments. From a compliance standpoint, PE-9 failures often show a broader weakness: facilities changes happening outside governance.

Practical 30/60/90-day execution plan

First 30 days (stabilize and scope)

• Assign PE-9 owner(s) and define in-scope spaces and assets.
• Collect existing diagrams, rack layouts, provider documents, and prior work orders.
• Walk the spaces (or request a remote hands report) and capture baseline photos.
• Publish a one-page interim standard: routing, retention, labeling, and prohibited practices.

Days 31–60 (implement controls and make evidence repeatable)

• Build/refresh power path maps for each in-scope site.
• Stand up an inspection checklist and remediation workflow.
• Update change management to flag power-impacting work and require approval.
• For third parties, formalize the inherited-control narrative and evidence request routine.

Days 61–90 (prove operation and close gaps)

• Run at least one full inspection cycle and close findings or document exceptions.
• Sample work orders: confirm they contain approvals, implementation notes, and post-work verification.
• Prepare an audit-ready PE-9 packet: diagrams, SOPs, inspections, photos, and exception register.
• Add PE-9 evidence tasks to Daydream so collection is continuous and role-based (owner, reviewer, approver).

Frequently Asked Questions

Does PE-9 require redundant power feeds (A/B power)?

PE-9 does not state redundancy explicitly; it requires protection from damage and destruction ¹. Redundancy can be one way to reduce impact, but auditors will still expect protected routing, secured equipment, and controlled changes.

We are fully in the cloud. How do we satisfy PE-9?

Document PE-9 as primarily inherited from your cloud provider’s physical environment, and retain the provider evidence you can obtain ². Also cover what you control, such as office network closets, endpoint charging stations for critical devices, or any on-prem connectivity equipment.

What counts as “power equipment and cabling” in scope?

Include the components that supply power to in-scope systems: panels/breakers feeding the space, UPS, PDUs, rack power distribution, and the cords/whips to the devices. Define the boundary in your SSP/control narrative so audits do not expand scope midstream.

How do we show evidence without giving auditors sensitive facility diagrams?

Provide redacted diagrams, rack-level schematics, and dated photos that show protections without exposing full layouts. Pair them with inspection logs and change tickets to prove operational control.

Our colocation provider won’t share detailed diagrams. What do we do?

Keep what they will provide (attestations, SOC reports if available, facility procedures) and supplement with your cage/rack photos, your routing standards, and your tickets for any work performed in your footprint. Document the limitation as an assumption and track it as a third party risk item.

What is the fastest way to fail PE-9 in an audit?

Having no repeatable evidence. A neat policy with no diagrams, inspections, work orders, or photos usually results in a finding because the assessor cannot verify that cabling and equipment are actually protected ².

Footnotes

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

2. NIST SP 800-53 Rev. 5