Physical security design for critical infrastructure facilities in the US — utilities, water systems, transit, energy — sits under the influence of the Cybersecurity and Infrastructure Security Agency (CISA), which publishes physical security guidance covering active-shooter, vehicle-ramming, and UAS/drone threats, alongside its broader mandate around cyber and supply-chain security. CISA's role is guidance and resource-provision more than direct regulatory enforcement of hardware choices, though funding programs (DOE grid security grants, EPA water utility grants, FTA transit grants, DHS grants) frequently attach compliance conditions, including federal supply-chain restrictions.
The most consequential of those conditions is NDAA Section 889, which restricts federal agencies — and, through flow-down clauses, many federally-funded critical infrastructure projects — from using certain named Chinese manufacturers' video surveillance and telecommunications equipment. Camera and related equipment selection has to be screened against the current restricted manufacturer list and their OEM/subsidiary relationships. CISA separately runs a "Secure by Design" pledge program manufacturers can sign onto voluntarily, increasingly used by owners as a practical vetting signal alongside mandatory Section 889 screening.
Why this matters specifically for US projects
Security design for critical infrastructure elsewhere typically centers on physical resilience without an equivalent federal supply-chain restriction regime attached to funding. In the US, a technically excellent camera or access control system can be entirely disqualified from a federally funded project if its manufacturer appears on the restricted list, verified at the specific model and supply-chain level, not just the surface brand level.
| Consideration | Standard commercial security design | US critical infrastructure design |
|---|---|---|
| Governing guidance | Owner requirements, insurance, local code | CISA physical security guidance layered on top, often grant-conditioned |
| Supply-chain restrictions | Generally none beyond standard procurement | NDAA Section 889 screening where federal funding/flow-down applies |
| Manufacturer vetting | Performance, warranty, support-based | Performance plus Section 889 screening plus CISA Secure by Design pledge status |
| Threat scope considered | Intrusion, theft, life safety | Broader: active shooter, vehicle ramming, IED, UAS/drone threats |
Practical guidance
ASDV treats federal funding/grant status as a design-input question asked at project kickoff, since it determines whether Section 889 screening is mandatory. We reference CISA's published physical security guidance as a design-quality benchmark and track manufacturer participation in the Secure by Design pledge as one vetting input.
Common mistakes
Assuming Section 889 screening only applies to direct federal agency projects, missing flow-down clauses in grant agreements; screening only the visible brand name without checking OEM manufacturing relationships; treating CISA guidance as optional reading.
Future outlook
Expect continued tightening of federal supply-chain restrictions and growing adoption of the Secure by Design pledge as a market differentiator. Any specific project should have its funding source and applicable flow-down clauses verified directly against current federal guidance.