CNC shops, tool-and-die operations, and metal fabricators handle Controlled Unclassified Information differently than a typical office — print packets on the shop floor, legacy machine controllers, and a constant flow of visitors and subcontractors. Your CMMC path needs to reflect that.
Most CMMC guidance is written for office IT environments — laptops, email, cloud storage. A San Jose precision machining or fabrication shop has all of that plus a second, harder problem: physical CUI. Engineering drawings, dimensional tolerances, and material specs for a defense program are Controlled Unclassified Information whether they live in a PDM system or a printed packet clipped to a CNC machine on the shop floor. Assessors expect the same rigor for both.
On top of that, shop floor equipment — CNC controllers, PLCs, older Windows-based HMI panels — often can't run modern endpoint agents or support multi-factor authentication the way an office workstation can. That doesn't exempt a shop from NIST SP 800-171; it means the compliance approach has to be built around network segmentation and compensating controls instead of forcing incompatible software onto machines that were never designed for it.
No MFA on legacy CNC/HMI terminals, and no network boundary separating them from systems that store or transmit CUI.
No visitor or badge-access log covering anyone — vendors, temp labor, tooling reps — who can view or handle CUI-bearing print packets.
Unrestricted USB drives moving G-code and part programs between office systems and shop floor machines with no logging or encryption.
No documented process for shredding or destroying superseded blueprints and work orders that contain CUI.
Yes, if the part drawings, dimensional tolerances, or material specifications a prime shares with you are tied to a DoD program, that information is typically Controlled Unclassified Information (CUI) regardless of whether it exists on paper, on a shop floor terminal, or in a PLM system. Physical CUI is covered by the same 110 NIST SP 800-171 controls as digital CUI.
In most cases, yes — by segmenting legacy CNC and PLC equipment onto an isolated network (or VLAN) separate from the systems that store or transmit CUI, and documenting compensating controls in your System Security Plan (SSP) and Plan of Action & Milestones (POA&M). Assessors expect a documented boundary, not a fully patched shop floor.
The most frequent gaps are missing multi-factor authentication on shop floor terminals, no formal visitor or badge-access log for anyone handling print packets or blueprints, and unclear boundaries between CUI-bearing systems and general shop equipment. All three are fixable with process changes rather than new hardware.
Speak with a local Silicon Valley defense contractor IT compliance expert who understands machine shop environments.