3.7.6Escort uncleared maintenance staff in Rev. 3
Reworded: 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 3.7.6 Maintenance Personnel
Assessment objectives · 800-171A
- [a] maintenance personnel without required access authorizations are supervised during maintenance and diagnostic activities
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 its Rev. 3 successor. A mechanical comparison of the two verbatim texts, not an interpretation.
removed in Rev. 3 added in Rev. 3
Rev. 2 3.7.6 → Rev. 3 03.07.06 Maintenance Personnel
8 words kept, 3 removed, 48 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
- New security requirement title
- Aligned with SP 800-53, Rev 5 to provide more comprehensive detail on and foundational tasks for security related to maintenance personnel
- Includes withdrawn requirement: 03.07.02
NIST, SP 800-171 Rev. 2 to Rev. 3 change analysis, class “Significant change”. At adoption, Bedrock files this under “Rework”.
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 3.7.6 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 03.07.06
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]