3.7.2Control maintenance tools and who uses them in Rev. 3
Withdrawn and incorporated elsewhere: 03.07.04 Maintenance Tools, 03.07.06 Maintenance Personnel.
Status as of 2026-09-08
Rev. 2 is what a contract requires today. DFARS 252.204-7012 and the CMMC rule at 32 CFR 170 point at NIST SP 800-171 Rev. 2, and a standing DoD class deviation keeps it there. NIST has published Rev. 3, but publishing a revision does not change an obligation. A move to Rev. 3 would arrive through the Department's reform process and formal rulemaking, a change to that deviation or an amendment to the rule, not through publication. The Department has published its organization-defined parameter values for Rev. 3 in preparation; that is groundwork, not adoption.
Side by side
Rev. 2 · in force 3.7.2 System Maintenance Control
Assessment objectives · 800-171A
- [a] maintenance tools used on the system are controlled
- [b] maintenance techniques used on the system are controlled
- [c] maintenance mechanisms used on the system are controlled
- [d] maintenance personnel performing maintenance on the system are controlled
Rev. 3 · not adopted 03.07.04 Maintenance Tools
a. Approve, control, and monitor the use of system maintenance tools.
b. Check media with diagnostic and test programs for malicious code before it is used in the system.
c. Prevent the removal of system maintenance equipment containing CUI by verifying that there is no CUI on the equipment, sanitizing or destroying the equipment, or retaining the equipment within the facility.
Determination statements · 800-171A Rev. 3
- 03.07.04.a[01] the use of system maintenance tools is approved.
- 03.07.04.a[02] the use of system maintenance tools is controlled.
- 03.07.04.a[03] the use of system maintenance tools is monitored.
- 03.07.04.b media with diagnostic and test programs are checked for malicious code before the media are used in the system.
- 03.07.04.c the removal of system maintenance equipment containing CUI is prevented by verifying that there is no CUI on the equipment, sanitizing or destroying the equipment, or retaining the equipment within the facility.
Rev. 3 · not adopted 03.07.06 Maintenance Personnel
a. Establish a process for maintenance personnel authorization.
b. Maintain a list of authorized maintenance organizations or personnel.
c. Verify that non-escorted personnel who perform maintenance on the system possess the required access authorizations.
d. Designate organizational personnel with required access authorizations and technical competence to supervise the maintenance activities of personnel who do not possess the required access authorizations.
Determination statements · 800-171A Rev. 3
- 03.07.06.a a process for maintenance personnel authorization is established.
- 03.07.06.b a list of authorized maintenance organizations or personnel is maintained.
- 03.07.06.c non-escorted personnel who perform maintenance on the system possess the required access authorizations.
- 03.07.06.d[01] organizational personnel with required access authorizations are designated to supervise the maintenance activities of personnel who do not possess the required access authorizations.
- 03.07.06.d[02] organizational personnel with required technical competence are designated to supervise the maintenance activities of personnel who do not possess the required access authorizations.
Left: NIST SP 800-171 Rev. 2 and 800-171A, verbatim. Right: NIST SP 800-171 Rev. 3 and 800-171A Rev. 3, verbatim, with organization-defined blanks highlighted.
Word by word
The Rev. 2 requirement compared with each Rev. 3 requirement it feeds into. A mechanical comparison of the two verbatim texts, not an interpretation.
removed in Rev. 3 added in Rev. 3
Rev. 2 3.7.2 → Rev. 3 03.07.04 Maintenance Tools
6 words kept, 8 removed, 52 added. Rev. 3 statement labels omitted for the comparison.
Rev. 2 3.7.2 → Rev. 3 03.07.06 Maintenance Personnel
5 words kept, 9 removed, 51 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
Rev. 3 withdraws this requirement as a separate item and folds it into other requirements. NIST's note: Incorporated into 03.07.04 and 03.07.06.
NIST's Rev. 3 discussion for 03.07.04
Approving, controlling, monitoring, and reviewing maintenance tools address security-related issues associated with the tools that are used for diagnostic and repair actions on the system. Maintenance tools can include hardware and software diagnostic and test equipment as well as packet sniffers. The tools may be pre-installed, brought in with maintenance personnel on media, cloud-based, or downloaded from a website. Diagnostic and test programs are potential vehicles for transporting malicious code into the system, either intentionally or unintentionally. Examples of media inspection include checking the cryptographic hash or digital signatures of diagnostic and test programs and media. If organizations inspect media that contain diagnostic and test programs and determine that the media also contain malicious code, the incident is handled consistent with incident handling policies and procedures. A periodic review of system maintenance tools can result in the withdrawal of approval for outdated, unsupported, irrelevant, or no-longer-used tools. Maintenance tools do not address the hardware and software components that support maintenance and are considered a part of the system.
NIST's Rev. 3 discussion for 03.07.06
Maintenance personnel refers to individuals who perform hardware or software maintenance on the system, while <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.10.01">03.10.01</a> addresses physical access for individuals whose maintenance duties place them within the physical protection perimeter of the system. The technical competence of supervising individuals relates to the maintenance performed on the system, while having required access authorizations refers to maintenance on and near the system. Individuals who have not been previously identified as authorized maintenance personnel (e.g., manufacturers, consultants, systems integrators, and vendors) may require privileged access to the system, such as when they are required to conduct maintenance with little or no notice. Organizations may choose to issue temporary credentials to these individuals based on their risk assessments. Temporary credentials may be for one-time use or for very limited time periods.
What this means for you now
Nothing changes in what you are assessed against until a class deviation or a published rule adopts Rev. 3. Keep meeting 3.7.2 as written in Rev. 2.
Bedrock CMMC shows this same comparison against your own package, with your current status on the Rev. 2 side, so the day adoption lands the migration is a review, not a rewrite.
Where this page's facts come from
- Rev. 2 text and objectives
- bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.basicRequirement@rev2; bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2
- Mapping and change class
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/r2_r3_transition_map.json#r2_to_r3
- Rev. 3 03.07.04
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]
- Rev. 3 03.07.06
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]