New clinic opens with server in reception
Mini-server under the front desk. PE-18 review relocates it to a locked IDF before go-live with ePHI.
Location of Information System Components
Medium Risk
Moderate
Medium Cost
PE-18 requires positioning system components within the facility to minimize potential damage from physical and environmental hazards and to minimize the opportunity for unauthorized access. EHR servers under leaky pipes, badge printers in public lobbies, and backup tapes in unlocked break rooms violate this siting discipline.
Control Objective
Locate ePHI system components to reduce exposure to environmental hazards and casual unauthorized access, informed by facility risk and care delivery constraints.
Implementation Guidance
- Include physical siting criteria in design standards for servers, storage, network cores, and bulk media.
- Avoid water, public access, and high-traffic hazard zones when placing critical components.
- Prefer controlled rooms (PE-3) over open office for systems storing ePHI at rest.
- Separate public-facing kiosks from backend ePHI servers architecturally and physically.
- Review locations during renovations and clinic openings.
- Document accepted risks when clinical care forces suboptimal placement; add compensating controls.
- Align PE-18 with PE-14/PE-15 environmental protections.
- Consider emanation/overlooking risks (PE-19) when placing displays and printers.
Real-World Use Cases
How this control shows up in healthcare and HIPAA-covered environments.
Tape shelf by the loading dock
Backup media sits near an unsecured exit. Relocation to a controlled media room reduces theft and environment risk.
PACS archive under HVAC condensate
Historical placement under a drip line. PE-18 plus PE-15 drive rack relocation during a planned outage.
Best Practices
- Siting standards in facility projects.
- Locked rooms for ePHI stores.
- Hazard avoidance (water, public access).
- Compensating controls when relocation impossible.
- Review on renovation.
- Coordinate with environmental PE controls.
Common Gaps & Violations
- Servers in unlocked closets shared with supplies.
- Public hallway network racks.
- Media stored by docks.
- No security input to clinic construction.
- Displays with ePHI facing waiting rooms (also PE-19).
Required Documentation
- Component location standard (PE-18)
- Facility design checklist including PE-18
- Inventory of component locations for critical systems
- Exception/risk acceptance records
- Renovation review evidence
How to Test & Validate
- Tour sample critical component locations for hazard/access issues.
- Review a recent clinic build for PE-18 sign-off.
- Confirm ePHI media not in public areas.
- Check exceptions have compensating controls.
- Correlate locations with PE-14/15 risks.
Audit Considerations
Siting mistakes are visible on tours. Good PE-18 practice prevents recurring physical findings and environmental outages.
HIPAA Mapping
How this NIST control supports HIPAA Security Rule expectations.
- 164.310(a) Facility Access Controls — physical placement supports controlled access and hazard protection.
- 164.310(a)(2)(ii) Facility Security Plan — safeguard equipment from unauthorized access and hazards.
- 164.308(a)(1) Risk Analysis — physical location risks belong in analysis.
- 164.306 CIA — placement decisions affect confidentiality and availability.
Compliance Tips
- Add security to the clinic construction checklist with PE-18 items.
- Maintain a simple map of where ePHI systems live for assessors.
- Revisit locations after any flood/heat incident.
Frequently Asked Questions
Does PE-18 require a Tier III data center?
No. It requires thoughtful positioning to minimize hazards and unauthorized access — scaled to organizational risk and resources.
Are endpoints in patient rooms a violation?
Clinical endpoints are expected; apply privacy screens, auto-lock, and network controls. PE-18 focuses especially on protecting concentrated system components and media.
How does PE-18 relate to CP-6 alternate storage?
Alternate storage location selection should also apply PE-18 hazard and access thinking.
References & Resources
- NIST SP 800-53 Rev. 5 — PE-18
- Related controls: PE-14, PE-15, PE-19, CP-6, CM-8
Related Guidelines
Related controls that commonly accompany PE-18.
Need Help Implementing PE-18?
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