PE-13: Fire Protection

PE-13 requires you to deploy and maintain fire detection and fire suppression for the facilities that house your information systems, and those systems must have an independent energy source so they still work during a power outage. To operationalize it quickly, assign a facilities/control owner, confirm coverage for each in-scope site (including third-party data centers), and collect recurring inspection and power-backup evidence. ¹

Key takeaways:

• You must have both detection and suppression, not just alarms or handheld extinguishers. ¹
• The “independent energy source” requirement drives design and evidence: backup power for panels, detectors, and releasing controls. ¹
• Audit success depends on site-by-site scope mapping plus maintenance and test records you can produce on demand.

The pe-13: fire protection requirement is a facilities control with security consequences: if a fire disables your systems, availability, integrity, and even confidentiality can fail at the same time. PE-13 is short, but assessment expectations are not. Assessors typically test two things: (1) did you implement appropriate fire detection and suppression for every location where the system operates, and (2) can those protections still function when building power is disrupted, because fires and power loss often co-occur.

Operationalizing PE-13 starts with scoping and ownership. Your CISO team may “own” the control in the SSP, but the real operators are facilities, data center operations, and third parties (colocation providers, IaaS providers with dedicated spaces, managed hosting). Your job as a Compliance Officer, CCO, or GRC lead is to translate one sentence of requirement text into a repeatable, evidence-producing process: define in-scope spaces, verify detection/suppression and independent power, and run a maintenance cadence that leaves a clean paper trail. ¹

Regulatory text

Requirement (PE-13): “Employ and maintain fire detection and suppression systems that are supported by an independent energy source.” ¹

What the operator must do:

• Employ: Put fire detection and fire suppression in place for the facilities/areas that support the system. ¹
• Maintain: Keep those systems in working order through inspections, testing, servicing, and repairs with records. ¹
• Independent energy source: Ensure detection/suppression components that must operate during an outage (for example, fire alarm control panels, releasing panels, notification and control circuits) have backup power independent of normal building power. ¹

Plain-English interpretation (what PE-13 means in practice)

If a fire starts in or near your data center, comms room, or critical wiring spaces, you need automated ways to detect it early and suppress it quickly, even if the building loses power. PE-13 is less about buying equipment and more about proving you have reliable coverage and disciplined upkeep across all sites.

A practical interpretation that holds up in assessment:

• Detection: Smoke/heat detection tied to a monitored fire alarm system, appropriate to the space and local code requirements.
• Suppression: Sprinkler and/or clean-agent systems appropriate for the room and equipment risk.
• Power resilience: Backup power for fire detection/suppression control components so alarms and releasing functions are not defeated by a power failure.

Who it applies to

PE-13 applies to:

• Federal information systems and the facilities that host them. ¹
• Contractor systems handling federal data, including environments operated by third parties on your behalf (colocation, managed hosting, certain dedicated cloud footprints). ¹

Operational contexts where PE-13 is commonly examined:

• Company-owned data centers and MDF/IDF rooms
• Office server rooms and network closets that support in-scope systems
• Colocation cages/suites
• Third-party data centers used for managed services
• Disaster recovery sites and warm/cold sites (if they support the system boundary)

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

1) Assign ownership and define the system boundary touchpoints

• Name a control owner (often Facilities/Real Estate or Data Center Ops) and a GRC owner responsible for evidence collection and assessor coordination.
• List all in-scope locations where the system operates or where critical supporting infrastructure lives (power distribution, network core, storage, backups).

Deliverable: a “PE-13 site register” with each location, address, space type, and responsible operator (internal team or third party).

2) Map fire detection coverage per site

For each site/space:

• Identify the detection type (smoke, heat, aspirating detection if present) and the monitoring path (local panel, central station monitoring, SOC/NOC ticketing).
• Confirm coverage for “gray areas” auditors ask about: underfloor/overhead plenum, battery rooms, generator rooms, staging/receiving areas adjacent to IT spaces.

Deliverable: a per-site detection summary plus a diagram or marked floor plan excerpt showing device locations (if you can obtain it without creating security risk).

3) Map fire suppression coverage per site

For each site/space:

• Identify suppression method (sprinklers, pre-action, clean agent) and protected zones.
• Confirm any interlocks that matter operationally (HVAC shutdown, power shutdown, door releases) and who can authorize resets after a discharge event.

Deliverable: a per-site suppression summary with system type, protected areas, and service provider contact.

4) Prove “independent energy source” for detection/suppression controls

This is where teams most often fall short on evidence.

For each site:

• Identify what must remain powered during an outage: fire alarm control panel, releasing panel (if clean agent), notification appliances as applicable, monitoring communicator, and any required control circuits.
• Gather proof of backup power design: battery backup specs, generator/UPS feed to panels, or vendor attestations.
• Confirm maintenance/testing includes backup power checks (battery testing/replacement records).

Deliverable: “Independent energy source” evidence package per site (photos of panel nameplates, battery cabinet details, inspection reports noting battery tests, or third-party compliance letters).

5) Establish and document a maintenance and testing cadence

PE-13 says “maintain,” so you need a repeatable schedule and records. Build a single table that lists:

• What gets inspected/tested
• Who performs it (internal or third party)
• Where the record is stored
• Who reviews it for completion

Deliverable: a PE-13 maintenance plan and a current-year log showing completed activities and exceptions.

6) Extend PE-13 to third parties (contracts + evidence)

If a third party operates the facility:

• Add contract language or addenda requiring fire detection/suppression and independent power support for life-safety/fire systems, plus evidence sharing.
• Obtain recurring artifacts (see below) on a schedule that matches your audit cycle.

Practical note: if the third party will not share detailed drawings, negotiate for a compliance letter plus recent inspection summaries that show detection/suppression and backup power status.

7) Tie PE-13 to your assessment package (SSP/controls matrix)

Document:

• How PE-13 is implemented per site
• What evidence exists and where it lives
• Who the assessor can interview

Daydream fit: many teams lose time chasing facilities evidence across email threads. Daydream works well as the control hub to map PE-13 to a named owner, a documented procedure, and a recurring evidence checklist so you can produce a clean package for each site on demand. ¹

Required evidence and artifacts to retain

Keep evidence by site and by period (current plus prior period as needed for your audit window). Typical artifacts:

• Fire detection and suppression system inventory (panels, zones, suppression type)
• Inspection, testing, and maintenance reports from the service provider
• Work orders and remediation records for deficiencies
• Proof of independent energy source:
  • Panel/battery inspection records
  • Battery replacement logs
  • UPS/generator feeding documentation where applicable
  • Third-party facility compliance letter attesting fire systems have backup power
• Monitoring/alerting evidence (sample alarm test notification, ticket, or central station test report)
• Third-party contracts/addenda and evidence request workflow
• Exception register for any temporary impairments, plus compensating measures and restoration dates

Common exam/audit questions and hangups

Auditors and assessors tend to focus on:

• “Show me your in-scope facilities list. How did you confirm you didn’t miss closets or DR sites?”
• “Do you have both detection and suppression in each in-scope space?” ¹
• “Where is the independent energy source documented and tested?” ¹
• “What happens if suppression discharges? Who is on call, and how do you restore services safely?”
• “For a colocation or managed hosting site, what evidence do you obtain, and how often?”

Hangups that cause findings:

• Evidence is only a building-level certificate, with no link to the system boundary spaces.
• Backup power exists, but you cannot show it applies to the alarm/releasing panels.
• Maintenance is performed, but reports are not retained centrally or are missing for one site.

Frequent implementation mistakes (and how to avoid them)

1. Treating PE-13 as ‘facilities has it covered’ with no security evidence.
   Fix: maintain a PE-13 evidence binder per site, owned by GRC, refreshed on a schedule.

2. Assuming sprinklers alone satisfy the requirement.
   Fix: explicitly document detection and suppression as separate elements. ¹

3. Independent power is implied but not proven.
   Fix: capture battery/UPS/generator support details for the specific panels and circuits that run detection/suppression controls. ¹

4. Third-party facilities are in scope but not contractually obligated to provide evidence.
   Fix: add evidence-rights language and define what “good evidence” looks like (inspection summaries, compliance letters, test results).

5. No impairment process.
   Fix: establish a short impairment workflow: record the impairment, compensating measures (fire watch, restricted access, portable suppression), and restoration proof.

Enforcement context and risk implications

No public enforcement cases were provided in the source material for PE-13, so you should treat this as an assessment-driven requirement rather than one with specific cited penalties in this page.

Risk implications you should communicate internally:

• Fire protection failures create single-event outages that can exceed typical cyber incident recovery assumptions.
• A missing independent energy source can turn a manageable incident into total loss of monitoring and delayed response during a power interruption. ¹
• Weak PE-13 evidence frequently becomes a “paper cut” finding that drags in broader facilities controls during assessments.

Practical 30/60/90-day execution plan

First 30 days (triage and scope control)

• Build the in-scope PE-13 site register mapped to your system boundary.
• Assign control owner(s) and backups; set the evidence storage location.
• Collect what you already have: last inspection reports, service contracts, monitoring details.
• Identify gaps: sites with unknown suppression type, missing inspection records, or unclear backup power.

Days 31–60 (close design gaps and lock evidence flow)

• For each site, document detection, suppression, and independent energy source proof. ¹
• Put third-party evidence requests on a repeating calendar; update contracts/addenda where needed.
• Stand up an impairment log and remediation workflow with facilities and data center ops.
• Run a tabletop walkthrough: “power outage + smoke event,” and confirm alarms still report and suppression controls remain powered.

Days 61–90 (operationalize and audit-proof)

• Normalize artifacts: one checklist, one folder structure, one naming convention per site.
• Perform an internal control test: sample a site and trace from requirement to evidence to interview.
• Add PE-13 to your ongoing compliance calendar and management reporting.
• If you use Daydream, configure PE-13 with a mapped owner, procedure, and recurring evidence tasks so gaps show up before the next audit cycle. ¹

Frequently Asked Questions

Does PE-13 apply if all of our systems are in the cloud?

It applies to the facilities that house the system components, which may be operated by third parties. If your system boundary depends on third-party data centers, you still need contractual assurance and evidence of detection, suppression, and independent power support. ¹

What counts as an “independent energy source”?

You need backup power that keeps fire detection and suppression controls functioning if normal building power fails. In practice this is commonly batteries and/or UPS/generator-backed circuits for the relevant panels, supported by maintenance records. ¹

Do handheld fire extinguishers satisfy PE-13?

Extinguishers can be part of your overall fire safety posture, but PE-13 explicitly requires fire detection and suppression systems with independent energy support. Treat extinguishers as supplemental unless your assessor agrees the space and risk justify an alternative design. ¹

What evidence is strongest for auditors?

Site-specific inspection/testing reports plus proof of backup power for the alarm/releasing controls are usually decisive. A facility letter can help, but it rarely replaces maintenance records and clear scoping to the system boundary.

How do we handle a temporary outage of the suppression system during repairs?

Document the impairment, implement compensating measures approved by facilities leadership, and retain restoration evidence once repairs are complete. Keep the log with your PE-13 artifacts so you can show controlled handling of exceptions.

Who should be the control owner: Security or Facilities?

Facilities/Data Center Ops usually owns implementation and maintenance, while Security/GRC owns requirement mapping, evidence quality, and assessment readiness. Write both roles into the procedure so tasks don’t fall into a gap.

Footnotes

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