PE-18: Location of System Components

PE-18: Location of System Components requires you to place servers, network gear, storage, and supporting equipment inside facilities so they are less likely to be damaged by local hazards and less accessible to unauthorized people. Operationalize it by inventorying components, identifying site-specific threats and access paths, then documenting and enforcing placement standards with repeatable evidence. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Key takeaways:

• You must control where critical components sit inside each facility, not just who can log in.
• PE-18 is evaluated through facility diagrams, placement standards, and consistent physical inspection evidence.
• Treat “location” as a risk decision tied to hazards (water, fire, HVAC, power) and to access opportunities (doors, windows, shared spaces). (NIST SP 800-53 Rev. 5 OSCAL JSON)

Compliance teams often treat physical controls as “handled by Facilities” and move on. PE-18 tends to break that pattern during assessments because it asks a concrete question: are your system components physically positioned to reduce harm from predictable facility threats and to reduce the chance of unauthorized access? The control is deceptively simple. Assessors want proof that you made intentional placement decisions (what goes where, and why), and that those decisions are implemented consistently across rooms, racks, closets, cages, and shared colocation spaces. (NIST SP 800-53 Rev. 5 OSCAL JSON)

For a CCO or GRC lead, the fastest path is to convert PE-18 into a small set of non-negotiable placement rules, assign accountable owners, and create evidence you can reproduce on demand. That evidence is rarely a single policy document. It is a package: floor plans or rack elevations (even simplified), a hazard and access-path review, implementation tickets, and periodic checks that confirm components stay where they are supposed to be. If you can show those artifacts for each in-scope facility, PE-18 becomes routine instead of a scramble. (NIST SP 800-53 Rev. 5)

Target keyword: pe-18: location of system components requirement

Regulatory text

Requirement (verbatim): “Position system components within the facility to minimize potential damage from {{ insert: param, pe-18_odp }} and to minimize the opportunity for unauthorized access.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

Operator meaning: you need a documented approach to placing system components (for example, servers, routers, switches, storage arrays, backup media systems, KVMs, management consoles, and network termination points) so that:

1. foreseeable facility hazards are less likely to damage them (think water intrusion, fire/smoke exposure, HVAC failures, physical impact, power distribution risks), and
2. physical access opportunities are reduced (components are not in public/shared areas, not easily reachable from uncontrolled spaces, and not exposed to casual tampering). (NIST SP 800-53 Rev. 5 OSCAL JSON)

PE-18 is not satisfied by “the building has badge access.” The control is about specific placement decisions inside the building and your ability to show that those decisions are deliberate, implemented, and maintained. (NIST SP 800-53 Rev. 5)

Plain-English interpretation (what assessors are really testing)

Assessors typically test PE-18 by walking a site (or reviewing virtual walkthrough evidence for remote/colo sites) and asking:

• “Show me where the system lives.”
• “Why is it located there, versus somewhere riskier?”
• “What prevents an unauthorized person from getting close enough to connect something, unplug something, or walk off with something?” (NIST SP 800-53 Rev. 5 OSCAL JSON)

Your goal is to prove three things:

1. You identified hazards and access paths relevant to each facility or space.
2. You translated those into placement rules (location standards).
3. You implemented and keep verifying the placement in practice. (NIST SP 800-53 Rev. 5)

Who PE-18 applies to

Entities: Federal information systems and contractor systems handling federal data commonly inherit PE controls into their baselines and assessment expectations. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Operational contexts where PE-18 becomes “real work”:

• On-prem data rooms, MDF/IDF closets, lab environments, and wiring closets in corporate offices
• Colocation cages and shared colo suites (where your “facility” is your space inside the provider’s building)
• Third-party managed sites where your components are installed but you do not run the building
• Distributed edge deployments (retail, manufacturing, clinics) where “server room” is sometimes a locked closet (NIST SP 800-53 Rev. 5)

If you rely heavily on cloud services, PE-18 still matters for your on-prem network gear, end-user infrastructure that supports privileged access, backup devices, and any hardware you own that connects to the system boundary. (NIST SP 800-53 Rev. 5)

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

1) Set scope and ownership

• Define which facilities/spaces are in scope (HQ data room, branch closets, colo cage, offsite storage room).
• Assign a control owner (often Physical Security or Facilities) and a technical owner (often Infrastructure/IT), with GRC as the coordinator.
• Decide how exceptions are approved (for example, a documented risk acceptance) when ideal placement is not possible. (NIST SP 800-53 Rev. 5)

2) Inventory system components by location

Create (or export) a location-aware inventory:

• Component name/type, asset ID/serial, system boundary mapping
• Current facility, room, rack/cabinet, RU position if relevant
• Whether the component is “critical” (core network, identity, logging, backup, key management) for prioritization (NIST SP 800-53 Rev. 5)

Practical tip: you do not need perfect CMDB maturity to pass; you need credible traceability between in-scope components and where they sit.

3) Identify hazards and unauthorized access opportunities per site

For each facility/space, document:

• Hazards: water sources above/beside racks (sprinkler heads, pipes), proximity to exterior walls, known flooding areas, HVAC single points of failure, areas with high dust/chemical exposure, loading dock adjacency, power distribution layout.
• Unauthorized access paths: shared corridors, unmonitored doors, windows, ceiling tile access, shared telecom closets, third-party cleaning access, “temporary” staging areas that become permanent. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Keep this pragmatic. A simple table per site is enough if it drives action.

4) Define placement standards (“where components may and may not go”)

Create a short standard that answers:

• Approved room types (data room, secured IDF) and prohibited locations (lobby closet, open office shelf, shared break room cabinet).
• Minimum physical protections for the approved locations (locked rack, cage, cabinet; restricted keys; camera coverage if applicable).
• Environmental constraints that drive placement (avoid below water lines; keep away from exterior doors; keep away from high-traffic areas; keep clear airflow and service access). (NIST SP 800-53 Rev. 5)

Write standards so they can be tested by inspection.

5) Remediate: move, harden, or compensate

For each nonconforming component, choose one:

• Move it to a compliant space.
• Harden the space (add locked cabinet, add physical barriers, improve access controls).
• Compensate with documented risk acceptance and additional monitoring if relocation is not feasible. (NIST SP 800-53 Rev. 5)

Track each change as a ticket with before/after photos or diagrams.

6) Operationalize: make it stick

• Add PE-18 checks to new install / change management: no rack-and-stack without confirming the target location meets the standard.
• Add a recurring inspection: a quick walkdown or remote review that confirms placements still match diagrams and that “temporary staging” did not become permanent.
• Update diagrams/inventory whenever equipment moves. (NIST SP 800-53 Rev. 5)

Where Daydream fits naturally: many teams fail PE-18 because evidence is scattered across Facilities, IT tickets, and colo contracts. Daydream can act as the control record system that maps PE-18 to a named owner, an implementation procedure, and recurring evidence artifacts, so you can answer assessor requests quickly and consistently. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Required evidence and artifacts to retain

Maintain an evidence set per facility/space:

• Location inventory for in-scope components (export from CMDB, asset list, or spreadsheet with controlled versioning)
• Facility/space diagrams: floor plan excerpt, room layout, rack elevations, or cabinet layout (simple is acceptable if accurate)
• Hazard and access-path assessment per site, with date and reviewer
• Placement standard (policy/standard/procedure) plus any exception workflow
• Remediation records: change tickets, work orders, photos (before/after), acceptance sign-offs
• Recurring inspection records: checklist, findings, and corrections
• Third-party documentation for colo/managed sites: cage assignment, access controls description, and any constraints impacting placement (NIST SP 800-53 Rev. 5)

Common exam/audit questions and hangups

Expect these:

• “Show me a diagram for each facility where the system has components.”
  Hangup: diagrams exist but are outdated or not mapped to the system boundary.
• “How did you decide this rack/cabinet location reduces hazard exposure?”
  Hangup: teams describe generic building controls instead of local risks near the rack.
• “Who can physically reach console ports, network drops, and management interfaces?”
  Hangup: racks in shared rooms, contractors with broad access, or weak key control.
• “How do you prevent unauthorized access in a colo?”
  Hangup: reliance on the colo provider’s SOC report without showing your cage, rack locks, and access list controls. (NIST SP 800-53 Rev. 5)

Frequent implementation mistakes (and how to avoid them)

1. Treating PE-18 as a policy-only control.
   Fix: pair the standard with diagrams, tickets, and inspection logs that prove actual placement. (NIST SP 800-53 Rev. 5)

2. Ignoring “supporting” components.
   Fix: include network termination points, backup devices, jump boxes, and management consoles if they support the system boundary. (NIST SP 800-53 Rev. 5)

3. No exception process.
   Fix: create an approval path that documents compensating controls and a review cadence for exceptions. (NIST SP 800-53 Rev. 5)

4. Colo ambiguity (“provider handles it”).
   Fix: document your assigned space, your rack locking standard, and your authorized personnel list; store the artifacts with the control. (NIST SP 800-53 Rev. 5)

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat PE-18 as an assessment-readiness and risk-reduction control rather than one tied here to a specific penalty narrative. The operational risk is straightforward: poorly located components increase downtime likelihood from local hazards and increase the chance of physical tampering or theft, which can turn into a confidentiality or integrity incident. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Practical 30/60/90-day execution plan

First 30 days (triage and visibility)

• Name owners and finalize scope (sites and component categories).
• Build the first location-aware inventory for in-scope components.
• Collect existing diagrams and validate they reflect reality for the highest-risk rooms (data rooms, MDFs). (NIST SP 800-53 Rev. 5)

Next 60 days (standards and remediation)

• Publish a short placement standard with prohibited locations and required protections.
• Complete hazard/access-path assessments for each site.
• Open remediation tickets for top placement gaps (exposed racks, public-area closets, equipment near water/power risks). (NIST SP 800-53 Rev. 5)

By 90 days (operationalize and evidence)

• Embed placement checks into install/change workflows.
• Start recurring inspections and record findings/corrections.
• Centralize evidence (standard, inventories, diagrams, inspections, exceptions) so PE-18 can be answered in one pull for audits and assessments. (NIST SP 800-53 Rev. 5)

Frequently Asked Questions

Does PE-18 apply if everything is in the cloud?

It still applies to any system components you operate inside facilities you control or occupy, such as network gear, backup appliances, and privileged access workstations. Document what remains on-prem and apply placement standards to that footprint. (NIST SP 800-53 Rev. 5)

What counts as “within the facility” for a colocation provider?

Your “facility” is typically your defined space inside the provider site (cage, suite, cabinets). Keep evidence showing how your components are positioned and protected within that space, not only the provider’s general building controls. (NIST SP 800-53 Rev. 5)

Do I need engineered environmental studies to meet PE-18?

No. You need a reasonable, documented assessment of local hazards and access opportunities that drives placement decisions. A site checklist plus annotated diagrams is often sufficient if it is accurate and maintained. (NIST SP 800-53 Rev. 5 OSCAL JSON)

How do I handle components that cannot be moved due to cabling or uptime constraints?

Use a documented exception with compensating controls (for example, locking cabinet, stricter key control, added monitoring) and a defined review point. Keep the approval and rationale with PE-18 evidence. (NIST SP 800-53 Rev. 5)

What evidence is most persuasive to an assessor?

Current diagrams tied to a location-aware inventory, plus work tickets and inspection logs that show the standard is implemented over time. Photos can help when they are dated and mapped to a room/rack identifier. (NIST SP 800-53 Rev. 5)

How should a GRC team test PE-18 without physical access to all sites?

Require standardized photo packs or video walkthroughs for each space, paired with updated diagrams and an inventory export. Validate exceptions and remediation tickets for any deviations found during the review. (NIST SP 800-53 Rev. 5)