PE-10(1): Accidental and Unauthorized Activation

PE-10(1) requires you to prevent physical environment systems from being accidentally or unauthorizedly activated in ways that could harm personnel, disrupt operations, or degrade security. Operationalize it by inventorying activation-capable systems, putting them behind positive controls (locks, guards, covers, interlocks, authorization), and proving the controls work through tests, logs, and maintenance records. ¹

Key takeaways:

• Scope the “activation risk” inventory first: any device/system that can be turned on, triggered, or armed without intent.
• Implement layered controls: physical protection, authorization, and fail-safe behaviors for accidental triggers.
• Keep assessor-ready evidence: diagrams, procedures, test results, and work orders mapped to the control. ²

PE-10(1): accidental and unauthorized activation requirement sits in the Physical and Environmental Protection (PE) family, but it is rarely “just facilities.” It is a cross-functional control that touches security operations, data center engineering, building management, and sometimes OT/ICS teams. The compliance failure mode is predictable: the organization has reasonable physical security for entry, yet has not addressed what happens when someone (or something) activates a system that should not be activated, or activates it at the wrong time.

For a CCO, GRC lead, or Compliance Officer, the quickest path is to treat PE-10(1) as an “activation safety and authorization” requirement. You define which mechanisms can cause disruptive or unsafe outcomes if activated (intentionally or accidentally), then you put them behind deliberate, documented, testable safeguards: covers, locks, keyed switches, guardrails in procedures, dual control where warranted, and maintenance practices that prevent misfires.

This page gives you requirement-level implementation guidance you can assign, track, and evidence. Where your program uses NIST SP 800-53 as the baseline for federal systems or contractor systems handling federal data, PE-10(1) is easiest to defend when you can point to a clear owner, repeatable procedures, and recurring artifacts. ³

Regulatory text

Control excerpt (as provided): “NIST SP 800-53 control PE-10.1.” ²

Operator meaning (what you must do): Implement physical and procedural safeguards so that systems in the physical environment that can be “activated” (turned on, triggered, armed, discharged, released, switched, started, opened/closed) cannot be activated accidentally or by an unauthorized person. Your implementation must be demonstrable: you can show the inventory of in-scope mechanisms, the protection methods, and proof they operate as intended. ¹

Practical translation: “No one should be able to bump, flip, press, remote-trigger, or misconfigure a physical control and cause an unsafe or disruptive event without being authorized, and you can prove you engineered and run it that way.”

Plain-English interpretation

PE-10(1): accidental and unauthorized activation requirement focuses on trigger prevention and access-to-actuation, not just access-to-space.

You are protecting against scenarios such as:

• An unescorted person hitting an emergency power-off (EPO) button.
• A cleaner or contractor switching off a rack PDU or HVAC breaker.
• A curious employee opening a protected cabinet and toggling a control.
• A malicious actor activating fire suppression, alarms, or other building controls to cause downtime or confusion.
• Accidental activation during maintenance because a procedure did not require lockout/tagout-like steps for the activation mechanism.

Your safeguards can be physical (guards, covers, locks, interlocks), administrative (authorization and change procedures), and operational (maintenance, testing, monitoring, incident handling). The key is that activation pathways are identified, restricted, and tested. ¹

Who it applies to

Entity types

• Federal information systems.
• Contractor systems handling federal data. ²

Operational context

• Data centers, comms rooms, wiring closets, and critical infrastructure spaces.
• Facilities/building management systems that support system availability and safety.
• Any location hosting equipment where unintended activation can create downtime, safety hazards, or security impacts.

Third parties This control often fails at the boundary: facilities vendors, colocation operators, managed service providers, maintenance contractors, and security guard providers can all access activation mechanisms. Treat “who can activate” as a third-party due diligence and contract requirement, not just an internal policy. ¹

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

Step 1: Assign ownership and define “activation” for your environment

• Control owner: usually Facilities + Physical Security with IT/Infra as a co-owner.
• Definition: document what counts as “activation” (power control, suppression release, alarms, mechanical switches, remote triggers, software commands that actuate physical devices).
• Scope statement: identify which sites and rooms are covered and which are excluded with justification. ¹

Deliverable: PE-10(1) control implementation statement with named owners and scope.

Step 2: Build an “activation risk inventory”

Create a list of activation-capable mechanisms and classify by impact if activated incorrectly.

Minimum fields to capture:

• Location (site, room, cabinet/rack if relevant)
• Mechanism (EPO, breaker, PDU switch, UPS bypass, fire suppression release, HVAC override, water shutoff, alarm panel, generator transfer switch)
• Activation method (push button, key switch, software console, remote panel)
• Who currently has access (roles + third parties)
• Current safeguards (cover, lock, badge door, camera, two-person rule)
• Failure mode (accidental bump, unauthorized use, maintenance error)
• Required safeguard level (low/medium/high based on impact)

Tip for speed: start with your most critical rooms and expand outward. Your assessor will accept incremental maturity if scope and prioritization are documented and rational. ¹

Deliverable: Activation Risk Register (spreadsheet is fine).

Step 3: Implement layered safeguards for each high-risk mechanism

Use a simple hierarchy. Pick controls you can operate and evidence.

A. Physical anti-accidental controls

• Protective covers over buttons and switches.
• Recessed or guarded actuators.
• Keyed switches instead of toggle switches for high-impact actions.
• Mechanical interlocks (door open prevents activation, or activation requires a deliberate sequence).

B. Access controls for unauthorized activation

• Locked panels/cabinets for control systems.
• Key control program (issuance, tracking, retrieval, and periodic review).
• Badge access restrictions for rooms with activation controls (least privilege).
• Escort requirements for third parties and non-authorized staff.

C. Procedural controls

• Written “activation authorization” procedure for high-impact actions (who approves, what prerequisites, what notifications).
• Maintenance procedures that prevent accidental activation (pre-job brief, signage, barriers, work permits).
• Emergency procedures that specify who can activate emergency mechanisms and when.

D. Detection and response

• Cameras or monitoring for high-impact activation points.
• Logging for software-actuated physical controls (where applicable).
• Incident playbooks for accidental activation events (containment, restoration, investigation, corrective actions).

You do not need exotic engineering. You need consistent, documented guardrails mapped to each activation pathway. ¹

Step 4: Validate the controls with tests and operational checks

Assessors ask, “How do you know it works?”

Build a validation routine:

• Visual inspection checklist for covers/locks/signage.
• Access test: confirm only authorized roles can reach the mechanism.
• Procedure test: tabletop or supervised operational drill for an activation scenario (especially for emergency controls).
• Maintenance check: verify work orders include steps preventing mis-activation.

Document results and track remediation items to closure. ¹

Step 5: Embed into third-party management and change management

PE-10(1) breaks when a third party has “helpful” access that bypasses your authorization model.

Minimum expectations for relevant third parties:

• Contract language: access limits, escort rules, and “no activation without authorization” clauses.
• Onboarding: site rules and activation restrictions training before granting access.
• Offboarding: retrieve keys/badges and disable access promptly.
• Change management: any changes to physical controls, panels, or building systems require documented review and approval.

Daydream can help by mapping PE-10(1) to a single accountable owner, a procedure, and recurring evidence artifacts so audits stop being an email chase across facilities and IT. ²

Required evidence and artifacts to retain

Keep artifacts that prove design and operation.

Design evidence (what you built)

• Activation Risk Register (inventory + classification).
• Site/room diagrams marking high-impact activation points.
• Photos of protective covers, locked panels, signage (date-stamped where practical).
• Key/badge access role matrix for rooms and control cabinets.
• Written procedures: activation authorization, escorting, maintenance safeguards, emergency actions. ¹

Operating evidence (what you do repeatedly)

• Access logs or reports showing who accessed restricted rooms (where available).
• Key issuance/return logs (or key management system exports).
• Work orders/maintenance tickets showing safeguards were applied.
• Inspection checklists and completed inspection records.
• Test/drill records and remediation tracking items with closure proof. ¹

Common exam/audit questions and hangups

Auditors and assessors tend to probe these points:

1. “Show me the inventory.” If you cannot list activation mechanisms, you cannot show coverage.
2. “Who is allowed to activate this?” Role clarity matters more than policy prose.
3. “Prove it’s prevented, not just discouraged.” They will look for physical barriers and access controls.
4. “How do you manage third-party access?” Expect questions about colocation staff and maintenance vendors.
5. “How do you test?” A one-time install photo is weaker than recurring inspections and a remediation log. ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails in assessment	Fix
Treating PE-10(1) as “door access only”	Activation points may be inside a room that many can enter	Inventory activation mechanisms and secure the mechanisms, not just the room
No named authorization roles	“Authorized” becomes ambiguous during incidents and maintenance	Publish a role-based authorization matrix and tie it to access provisioning
Controls exist but aren’t maintained	Broken covers, missing keys, bypassed locks become normal	Add recurring inspections and require work orders for fixes
Third parties can act without oversight	Colocation/facilities vendors often have broad access	Add contract controls, escort rules, and access reviews
No evidence trail	Teams “know” it’s controlled but cannot prove it	Standardize evidence artifacts and store them centrally 1

Enforcement context and risk implications

No public enforcement cases were provided in the supplied sources for this requirement, so do not plan on citing case law or agency actions in your control narrative.

Risk still matters operationally. Accidental or unauthorized activation events commonly become:

• Availability incidents (power-off, cooling loss, suppression discharge).
• Safety incidents (improper activation of emergency systems).
• Security incidents (distraction alarms, forced shutdowns, or bypass conditions created during recovery).

For federal or federal-adjacent environments, these outcomes can trigger incident response, outage reporting obligations under your contracts, and assessment findings that affect authorizations and renewals. Keep the narrative grounded: you are reducing the likelihood of preventable physical-origin incidents. ¹

Practical execution plan (30/60/90 days)

First 30 days (establish control shape)

• Assign the PE-10(1) owner and backups.
• Draft the “activation” definition and scope statement.
• Build the initial Activation Risk Register for the most critical site(s).
• Identify top activation points needing immediate physical guards (covers/locks/signage).
• Stand up an evidence folder structure and naming convention aligned to PE-10(1). ¹

By 60 days (implement and document)

• Install/enable safeguards for high-impact mechanisms (covers, locks, key control, access restrictions).
• Publish the activation authorization procedure and escort rules.
• Update third-party onboarding rules for facilities/colo/maintenance access.
• Run one validation exercise: inspection + access test + procedure walk-through; track remediation items. ¹

By 90 days (operate and make it repeatable)

• Expand inventory coverage across remaining sites/rooms in scope.
• Establish recurring inspections and evidence capture (checklists + photos + tickets).
• Add PE-10(1) checks into change management for facilities and building systems changes.
• Produce an assessor-ready packet: inventory, procedures, proof of safeguards, test results, and remediation closure. ¹

Frequently Asked Questions

What counts as “activation” for PE-10(1) in a data center?

Treat activation as any action that initiates, stops, releases, arms, bypasses, or overrides a physical function that can affect system availability or safety, such as EPO, UPS bypass, breakers, suppression release, and HVAC overrides. Document your definition and apply it consistently. ¹

Do I need two-person control for every activation mechanism?

No. Use two-person control for the mechanisms where a single unauthorized or accidental action would cause high-impact downtime or safety risk. For lower-impact points, a guarded cover, lock, and role-based access may be sufficient if you can evidence it. ¹

How do I handle colocation facilities where I don’t control the building systems?

Treat the colo as a third party: document shared responsibility, obtain their procedures and evidence where possible, and add contract and access terms that restrict who can activate high-impact controls affecting your footprint. Keep your own evidence of what you verified. ¹

What evidence is strongest for auditors?

A current inventory of activation mechanisms, photos/diagrams showing safeguards in place, access/key control records, maintenance tickets, and inspection/test records with remediation closure. Policies without operational records are usually weak. ¹

Can software controls satisfy PE-10(1) if activation is performed via a building management system?

They can contribute, but assessors typically expect layered controls: strong authentication/authorization and logging for the console, plus physical restriction of panels and fallback procedures that prevent accidental actuation during maintenance. Keep both cyber and physical evidence. ¹

How should I map PE-10(1) in my GRC tool?

Map it to a single accountable owner, a clear implementation procedure, and a set of recurring evidence artifacts (inspection logs, access reviews, work orders, tests). Daydream is useful here because it keeps the mapping and evidence requests consistent across sites and teams. ²

Footnotes

1. NIST SP 800-53 Rev. 5

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

3. NIST SP 800-53 Rev. 5; Source: NIST SP 800-53 Rev. 5 OSCAL JSON