Requirements / Maintenance (MA)
MA.L2-3.7.6
Maintenance Personnel
Official Source Material
Supervise the maintenance activities of maintenance personnel without required access authorization.
Determine if:
- [a] maintenance personnel without required access authorization are supervised during maintenance activities.
Source: CMMC Assessment Guide - Level 2, Version 2.13, September 2024
Practitioner Guidance
How to meet it
This requirement covers the outsider fixing your systems, not your own administrators.
Maintenance personnel with required access authorization, your IT staff and the vetted provider technicians documented in your program, are not the subject. Objective [a] is about the one-off vendor engineer, the copier technician, and anyone else who works on systems without authorization for the CUI, Controlled Unclassified Information, that they could touch. Supervise those people while they work.
Supervision is a person watching, start to finish.
Assign an employee who knows what the work should look like to stay with the technician for the duration. Sign the visitor in under your PE.L2-3.10.3 procedure, watch the work, and sign them out. A maintenance log entry naming the technician, the supervisor, and the work performed is the evidence.
Temporary credentials beat borrowed ones.
When the technician needs to log in, issue a temporary account that expires in hours, scoped to the systems under repair, and remove it when the job closes. Never hand over an administrator's own credentials. A borrowed credential defeats both the supervision and your audit trail.
Decide in advance who counts as authorized.
Write down which maintenance personnel hold required access authorization: your administrators and the named provider staff. Everyone outside that list gets the supervised treatment, and the list is what lets you answer [a] without improvising at the door.
Edge cases
- The HVAC or electrical contractor working in a closet that houses network switches is doing facility work inside your operating environment. Escort them under PE.L2-3.10.3, because the supervision here and the escorting there overlap, and the switch in the HVAC closet is the reason both exist.
- When a remote employee's machine is repaired at home by a hired technician, the employee is the supervisor. Lock or sanitize CUI out of reach first so the supervision is workable, and if the device instead leaves for a shop, MA.L2-3.7.3 governs.