Independent education for small defense contractorsPublished by Federal Bid Partners LLC
Safeguards

Physical access and media disposal in a small business

Connect office habits, remote work, visitor handling, keys, and retired devices.

Follow the equipment into the real world

Begin at the place where a person can physically reach the relevant systems or media. That may be an office, workshop, home workspace, or shared location. Ask who can enter, what they can reach, and how the organization controls the situation. Avoid assuming that a locked front door answers every question about a device left accessible inside.

For remote work, discuss the approved arrangement with the employee and responsible manager. Use a non-sensitive walkthrough or suitable internal records. This site's planner should not contain home addresses, photographs of private living spaces, alarm details, or a map of valuable equipment.

Break the visitor requirement into its parts

FAR 52.204-21 includes escorting and monitoring visitors, maintaining audit logs of physical access, and managing physical access devices. Review each part explicitly. A sign-in sheet alone does not establish escorting, and a verbal rule to escort visitors does not establish the existence of appropriate access records.

For an illustrative small office, identify who receives a maintenance worker, what areas the worker can enter, how the visit is recorded, and what happens if the usual receptionist is absent. The goal is a process people can perform consistently. Choose records and controls suited to the actual operating environment and official objectives.

Account for keys and badges through their lifecycle

Ask who authorizes issue, where the current list is maintained, and how a key or badge is returned, disabled, or replaced. Include personnel departures and lost devices. Review a safe sample of a past change and determine whether the operational record matches the current state.

Physical access arrangements supplied by a landlord or service provider deserve questions too. Determine what the provider controls, what the company controls, and what proof is available. A lease or service description can describe responsibilities, but it does not automatically demonstrate that every relevant action occurred.

Retirement is a security workflow

Identify media that can hold FCI, including storage in retired computers, removable drives, and other relevant equipment. Before disposal or release for reuse, apply the required sanitization or destruction process. Assign responsibility and retain an appropriate internal record of what happened, without unnecessarily duplicating the underlying information.

Do not equate deleting a folder with a verified sanitization method. Ask a knowledgeable technical owner to select and verify a suitable process for the media and applicable requirements. If a vendor performs the work, clarify handling, accountability, and the record the company will receive. Link the disposal record to the inventory so the same retired device does not continue to appear as active.

Official sources & review notes

Editorial review: October 25, 2026. Practical examples are illustrative. Official sources and your contract govern. This article does not determine your required level or issue an assessment result.
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