U.S. Department of Homeland Security
Immigration and Customs Enforcement
Office of Professional Responsibility
Inspections and Detention Oversight
Washington, DC 20536-5501

Office of Detention Oversight
Compliance Inspection
Enforcement and Removal Operations
Miami Field Office
Broward Transition Center
Pompano Beach, Florida

February 28 – March 1, 2012

FOR INTERNAL USE ONLY. This document may contain sensitive commercial, financial, law
enforcement, management, and employee information. It has been written for the express use of the
Department of Homeland Security to identify and correct management and operational deficiencies. In
reference to ICE Policy 17006.1, issued 09/22/05; any disclosure, dissemination, or reproduction of this
document, or any segments thereof, is prohibited without the approval of the Assistant Director, Office of
Professional Responsibility.

COMPLIANCE INSPECTION
BROWARD TRANSITION CENTER
MIAMI FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...............................................................................................1
INSPECTION PROCESS
Report Organization .................................................................................................6
Inspection Team Members .......................................................................................6
OPERATIONAL ENVIRONMENT
Internal Relations .....................................................................................................7
Detainee Relations ...................................................................................................7
ICE PERFORMANCE BASED NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................8
Admission and Release ............................................................................................9
Environmental Health and Safely ..........................................................................11
Food Service ..........................................................................................................13
Grievance System ..................................................................................................14
Hold Rooms in Detention Facilities ......................................................................16
Medical Care ..........................................................................................................18
Telephone Access ..................................................................................................21
Transfer of Detainees ............................................................................................22

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO)
conducted a Compliance Inspection (CI) of the Broward Transition Center (BTC) in Pompano
Beach, Florida, from February 28 - March 1, 2012. The facility is owned and operated by the
Global Expertise in Outsourcing (GEO) Group, Inc. BTC houses ICE detainees of classification
Level One for periods in excess of 72 hours.
GEO initially entered into a contract agreement with the Broward County Sheriff’s Office in
1996 to manage the facility, which was formerly a hotel complex that was converted into workrelease housing for Broward County inmates. By 2002, GEO had ended its contract with the
Broward County Sheriff’s Office and entered into a contract with ICE to provide a transitional
center comprised of 150 beds for female detainees (asylum seekers). ICE awarded a subsequent
contract to GEO in 2003, increasing the female detainee population to 200. In 2005, BTC began
to accommodate male detainees, and the ICE detainee capacity increased to 450 beds. On
February 1, 2007, the ICE contract was increased to 600 beds, and increased again in July 2009,
to a maximum of 700 beds. The current contract permits the housing of Level One non-criminal
male and female detainees under the newly-instituted DHS Model Detainment Center. The
Model Detainment Center allows more freedom of movement for ICE detainees.
At the time of the ODO CI, BTC housed 642 detainees (572 males and 70 females). BTC is
accredited by the American Correctional Association (ACA). BTC staff provides both medical
care and food services.
Since 2010, major building renovation/expansion projects have been accomplished to meet the
Model Detainment Center contractual requirements, as well as the needs of the larger population,
including: a transport unit equipped with a fleet of vehicles and a staff of(b)(7)ea larger medical
department operating 24 hours a day, seven days a week; and an expanded food service area and
dining room. Two designated detainee-client waiting rooms were added, as well as separate
detainee-client meeting rooms. Two remodeled court rooms now serve the detainee needs for
televised court appearances. A significant renovation and expansion in the control room,
visitation area, and intake area have also been completed. ODO observed ongoing renovation
projects during the CI, including upgrading male detainee rooms and converting the facility’s
common outdoor space into a break area.
According to BTC staff, ongoing improvements are incorporated into the Model Detainment
Center concept such as painting the outside structures in pink, the color selected by GEO
management to provide a soothing, calming environment for detainees. There will be no
increase in the numbers of rooms; however, BTC staff said each room now holds a maximum of
six detainees, although the rooms will be reduced to four detainees per room when the renovation
is completed.
ICE management staff informed ODO, the Model Detainment Center configuration results in
reduced costs compared to maximum security jails; resources in a Model Detainment Center are
directed toward improving services for detainees’ care and welfare. These services include
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improving detainees’ health, welfare, and socialization; realistic self-help educational programs;
intra-institutional work assignments; and individual social, psychological, medical, and religious
counseling.
The ERO Field Office Director in Miami, Florida (FOD/Miami) is responsible for ensuring BTC
complies with ICE policies and the PBNDS. An Assistant Field Office Director (AFOD), who is
located on-site at BTC, is assigned oversight responsibility of the facility. Including the AFOD,
ERO has(b)(7)efull-time positions at BTC, which consist of(b)(7)eSupervisory Detention and
Deportation Officers (SDDOs),(b)(7)eDeportation Officers (DOs),(b)(7)e Supervisory Immigration
Enforcement Agents (SIEAs)(b)(7)e mmigration Enforcement Agents (IEAs), and (b)(7)e
Enforcement Removal Assistants (ERAs). An IEA and an ERA position were vacant during the
period of review. A Detention Service Manager (DSM) is assigned to BTC. The total number of
non-ICE staff employed by GEO at BTC is (b)(7)e with(b)(7)e
vacancies at the time of the CI.
In July 2009, ODO conducted a Quality Assurance Review (QAR) of BTC, and reviewed 25
National Detention Standards (NDS). A total of 89 deficiencies were found during the review in
the following standards: Access to Legal Material (1 deficiency); Admission and Release (7);
Contraband (1); Correspondence and Other Mail (6); Detainee Classification System (2);
Detainee Handbook (6); Detention Files (3); Disciplinary Policy (4); Emergency Plans (6);
Environmental Health and Safety (2); Food Service (3); Funds and Personal Property (5);
Issuance and Exchange of Clothing, Bedding, and Towels (3); Key and Lock Control (8);
Medical Care (4); Population Counts (1); Post Orders (2); Recreation (1); Religious Practices (2)
Security Inspections (4); Staff-Detainee Communication (4); Tool Control (6); Use of Force (3);
Visitation (4); and Voluntary Work Program (1).
During the 2009 QAR, there were no recorded deficiencies in five of the standards reviewed,
including: Detainee Grievance Procedures; Hunger Strikes; Suicide Prevention and Intervention;
Telephone Access; and Terminal Illness, Advanced Directives, and Death.
On November 30, 2011, ICE Enforcement and Removal Operations (ERO), Detention Standards
Compliance Unit contractor MGT of America, Inc., conducted an annual review of the ICE
Performance Based National Detention Standards (PBNDS) at BTC. The facility received an
overall rating of “Meets Standards,’’ and was found in compliance with all 41 standards
reviewed.
During this CI, ODO reviewed 23 PBNDS. Overall, ODO found BTC to be well-managed, and
in compliance with the standards inspected relative to the concept of a Model Detainment
Center. ODO verified BTC was in full compliance with 15 of the 23 PBNDS reviewed, while
deficiencies were recorded in the following eight standards: Admission and Release (3
deficiencies); Environmental Health and Safety (3); Food Service (1); Grievance System (1);
Hold Rooms in Detention Facilities (1); Medical Care (2); Telephone Access (1); and Transfer of
Detainees (2). ODO noted two deficiencies were found which were similar to deficiencies
identified during the 2009 ODO QAR, in the Admission and Release, and Medical Care
standards.

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This report includes descriptions of all deficiencies and refers to the specific, relevant ICE
PBNDS. The report will be provided to ERO to develop corrective actions to resolve identified
deficiencies. All deficiencies were discussed with BTC personnel on-site during the inspection,
as well as during the closeout briefing conducted on March 1, 2012.
ERO staff informed ODO several measures are in place to avoid accepting detainees other than
Level One detainees. One such measure involves meticulous classifications by ICE officers.
The facility has requested a GEO classification officer position, which will ensure full coverage
of classification duties if ICE personnel are unavailable. ODO found detainees, upon arrival at
BTC, are not screened for security purposes through metal detectors. Additionally, detainees are
not required to shower prior to entering their respective housing units. Detainee question and
answer sessions with facility staff are not conducted with detainees following the orientation
briefings. These deficiencies were discussed during the review and at the close-out briefing.
BTC staff was receptive to ODO’s findings, and agreed to incorporate corrective actions.
Medical and mental health screenings are performed by nursing staff at the time of intake.
Available data indicates there were 7,641 intake health screenings conducted in 2011. There
were 6,016 detainee contacts with a physician, and 84,561 detainee encounters with nursing
staff. Screening for TB is performed as part of intake processing by way of low radiation digital
chest X-rays. Chest X-ray results are returned within four hours of taking the X-ray, which ODO
identifies as a best practice. Determination of the presence or absence of possible TB during
intake supports infection control.
ODO identified one area of concern regarding medical practices. According to BTC policy,
officers are trained to not only distribute over-the-counter medications, but also to determine
when there is chronic use or abuse. Even if officers are trained, ODO considers it an unwise and
potentially dangerous practice to assign this responsibility to non-medical personnel. As BTC
has round-the-clock medical coverage, ODO recommends rescinding its policy allowing
distribution of over-the-counter medications by correctional officers. A similar deficiency was
noted during the 2009 ODO QAR.
ODO found that BTC provides limited health care service at the facility. As a result, medical
care cases that cannot be sufficiently handled at BTC are promptly referred to a hospital. BTC
has contracts for off-site medical care with North Broward Medical Center and Atlantic Shores
Hospital. Facility staff also explained the adoption of a Model Detainment Center with a less
restrictive environment for detainees eliminates the need for Special Management Units. BTC
staff advised detainees housed at BTC and at other FOD/Miami detention facilities are aware of
the privileges of being accommodated at BTC. The GEO transporting unit is on constant
standby to potentially remove disruptive detainees from BTC to an alternative facility.
ODO noted the Sexual Abuse and Assault Prevention and Intervention (SAAPI) program at BTC
as a best practice which could be applied in other ICE detention facilities. Information
concerning the SAAPI program is posted in all dorms and at other locations throughout the
facility. The information is available in both English and Spanish, and includes toll-free
telephone numbers. Staff receives training on an annual basis. Interviews with facility staff
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confirmed familiarity with the program and how to handle any information concerning sexual
abuse. As part of the facility’s SAAPI program, detainees are screened during the intake process
for sexual abuse and victimization histories. Detainees are given a tri-fold brochure during the
intake process with information and guidance for reporting any kind of sexual abuse or
misconduct by other detainees or staff.
There have been no hunger strikes in the past year, and no deficiencies were noted in the 2009
QAR. ODO verified facility policy addresses all requirements of the PBNDS. A review of
training records revealed all medical and detention staff received training regarding hunger strike
procedures.
A review of suicide prevention and intervention found there were three attempted suicides and
no completed suicides in 2011. BTC does not provide on-site suicide watches; however,
detainees in need of suicide watches are transferred on an emergency basis to a community
hospital or to another ICE facility. From the time of referral until the detainee’s transfer, the
detainee is held in the BTC Health Services Unit, under constant supervision. ODO was
informed transfers take place within one to two hours. Staff received training on suicide
prevention and intervention during orientation and within the past year.
BTC policies address terminal illness, fatal injury, and advance directives, and provide specific
guidance in the event of a detainee’s death. No detainee deaths have occurred at BTC, and no
deficiencies were found in this standard.
ODO observed DOs conducting scheduled visitations on Tuesdays and Thursdays. During the
scheduled visits, ICE officers met individually with every detainee with questions or concerns.
The visits were held in the dining area, and detainees received individual attention from the ICE
officers. ODO cites the positive impact of the thorough personalized contact with detainees as a
model for Staff-Detainee Communication, which can be applied at other ICE detention facilities.
ODO noted one area of concern regarding BTC’s food service. Detainees on kosher diets are
given frozen meals which are heated one at a time for six minutes in the dining hall’s one
microwave oven. Depending upon the number of detainees on kosher diets, wait time for use of
the microwave oven could extend through the allotted dining time. ODO recommends the
facility take steps to ensure all detainees have ample time to heat and consume their meals.
BTC has a functioning grievance system which allows detainees to file formal and informal
grievances. Grievance forms are available upon request, and detainees are able to appeal
grievance decisions. ODO cited one deficiency regarding a lack of logbook documentation for
informally-resolved grievances. However, the Grievance Officer maintains copies of informal
and formal grievances, with the associated responses.
During the past calendar year, a total of 85 disciplinary hearings were held. According to facility
staff, any incident involving detainee misconduct from minor to severe must undergo a
disciplinary hearing process to determine whether to transfer the detainee to another facility.
Detainees found guilty of any offense is transferred to another facility. Since the facility is a
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residential MDC, the facility must ensure safe custody and security of a large population of
detainees. The disciplinary hearings ensure the detainee has been provided a proper hearing
before transferring to another facility. Translation and interpretation services were available to
detainees involved in the discipline process. ODO verified disciplinary reports are investigated
by a shift supervisor, and all evidence and documentation is reviewed by the Unit Disciplinary
Committee or Institutional Disciplinary Panel.
ODO reviewed the Use of Force and Restraints PBNDS at BTC to determine if the facility
authorizes staff to use necessary force after all reasonable efforts to otherwise resolve a situation
have failed, for protection of all persons; to minimize injury to self, detainees, staff, and others;
to prevent escape or serious property damage; or to maintain the security and orderly operation
of the facility. ODO also conducted the review to determine if staff uses only the degree of force
necessary to gain control of detainees, and if staff uses physical restraints to gain control of a
dangerous detainee under specified conditions. This standard does not specifically address the
use of restraints for medical or mental health purposes, which is addressed by the Medical Care
PBNDS. Canine units, in facilities that have them, may be used for contraband detection; ODO
conducted the review to determine if, in facilities that use canines, the canine units’ use for force,
control, or intimidation of detainees is prohibited. ODO toured the facility, interviewed staff,
and reviewed policies and procedures.
Interviews with staff and a review of documentation indicated BTC did not have any calculated
use of force incidents in 2011, and there have been none so far in 2012. A thorough review of
the current Use of Force policy revealed clear guidance is provided for use of calculated rather
than immediate force in most situations. If necessary, staff is authorized to use immediate force
without a supervisor’s presence or direction. Annual training is provided in the use of force team
technique, and protective gear is readily available. BTC documents after-action reviews of force
incidents using a Use of Force Summary & Review Form covering all aspects of the review
process, including justification for the use of force and any noted discrepancies.
BTC has no chemical weapons or munitions on-site. Although BTC staff receives training in
calculated use of force situations, they do not use cell extraction teams as BTC’s housing areas
are six-plus person rooms, and are not conducive to the cell extraction team method.
ODO has identified an area of concern with respect to the Use of Force and Restraints standard.
BTC does not use four or five point restraints. Any detainee requiring this type of restraint is
removed from the facility. The only restraints used are handcuffs, leg irons, and martin chains,
all of which are classified as ambulatory restraints. There are no policies or procedures
addressing application of these restraints, duration of use, physical checks on the detainee by a
supervisor while restrained, removal of the restraints, or documentation of the reason for
continuance in restraints. Interviews with staff yielded inconsistent responses to questions
concerning ambulatory restraint procedures. ODO recommends development of policy and
procedures addressing the use of ambulatory restraints.

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INSPECTION PROCESS
ODO inspections evaluate the welfare, safety, and living conditions of detainees. ODO primarily
focuses on areas of noncompliance with the ICE NDS or the PBNDS, as applicable. The
PBNDS apply at BTC. In addition, ODO may focus its inspection based on detention
management information provided by the ERO Headquarters (HQ) and ERO field offices, and on
issues of high priority or interest to ICE executive management. Inspection objectives are to
evaluate the welfare, safety, and living conditions of detainees.
ODO reviewed the processes employed at BTC to determine compliance with current policies
and detention standards. Prior to the inspection, ODO collected and analyzed relevant
allegations and detainee information from multiple ICE databases, including the Joint Integrity
Case Management System (JICMS) and the ENFORCE Alien Booking Module (EABM) and
Alien Removal Module (EARM). ODO also gathered facility facts and inspection-related
information from ERO HQ staff to prepare for the site visit at BTC.

REPORT ORGANIZATION
This report documents inspection results, serves as an official record, and is intended to provide
ICE and detention facility management with a comprehensive evaluation of compliance with
policies and detention standards. It summarizes those PBNDS that ODO found deficient in at
least one aspect of the standard. ODO reports convey information to best enable prompt
corrective actions and to assist in the on-going process of incorporating best practices in
nationwide detention facility operations.
OPR classifies program issues into one of two categories: deficiencies and areas of concern.
OPR defines a deficiency as a violation of written policy that can be specifically linked to the
PBNDS, or to ICE policy or operational procedure. OPR defines an area of concern as
something that may lead to or risk a violation of the PBNDS or ICE policy or operational
procedure. When possible, the report includes contextual and quantitative information relevant
to the cited standard. Deficiencies are highlighted in bold throughout the report and are encoded
sequentially according to a detention standard designator.
Comments and questions regarding the report findings should be forwarded to the Deputy
Division Director, OPR Office of Detention Oversight.

INSPECTION TEAM MEMBERS

(b)(6), (b)(7)c

Detention and Deportation Officer (Team Lead)
Management Program Analyst
Management Program Analyst
Special Agent
Contract Inspector
Contract Inspector
Contract Inspector

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ODO, Headquarters
ODO, Headquarters
ODO, Headquarters
ODO, Houston
Creative Corrections
Creative Corrections
Creative Corrections
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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the BTC Warden, the Assistant Warden, Correctional Officers (CO), the ICE
AFOD, an SDDO, an SIEA who also serves as the Contracting Officer’s Technical
Representative (COTR) at the facility, and the DSM. ERO management stated the staffing level
for ICE officers, which includes(b)(7)efull-time positions assigned to BTC, is adequate to support
the facility. BTC and ICE staff stated morale is good and described their working relationship as
excellent, with no current issues.
BTC staff expressed concerns with the level of experience with respect to the DSM and the
application of the PBNDS, and ICE detention policies and procedures, to the facility. The DSM
also told ODO that additional training would likely enhance the skills needed to best inform and
coordinate with BTC staff.

DETAINEE RELATIONS
ODO interviewed 28 (20 males and 8 females) randomly-selected detainees. All reported they
have sufficient contact with facility staff and all know the names of their respective ERO
immigration case officers. All received the facility and ICE National Detainee handbooks, in the
individually applicable English or Spanish version. All detainees stated they know how to use
the facility telephones and all fully understand how to gain access to, and use, the law library.
All receive recreational opportunities each day and visitation by family is available.
A majority of the detainees stated the medical care was of good quality. Four of the 28 claimed
it took too long to be seen by medical staff once sick request forms were submitted. ODO
reviewed the medical records of the four detainees and determined adequate and timely medical
care was provided.
All detainees stated hygiene supplies were issued during intake processing, and thereafter. All
detainees stated the food was good; however, three detainees claimed their meals lacked variety
and good taste.
In addition to the 28 detainees, ODO randomly interviewed 20 males and 5 females who had
never filed a grievance at BTC to determine their respective overall understanding of the
grievance system. All stated they are aware of the grievance process and currently have no
reasons to complain about the facility. All are concerned about their departure dates from the
facility and the status of their individual immigration cases.

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ICE PERFORMANCE BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 23 ICE PBNDS and found BTC fully compliant with the following 15
standards:
Law Library and Legal Material
Classification System
Correspondence and Other Mail
Detainee Handbook
Disciplinary System
Hunger Strikes
Recreation
Religious Practices
Staff-Detainee Communication
Staff Training
Sexual Abuse and Assault Prevention and Intervention
Suicide Prevention and Intervention
Terminal Illness, Advance Directives, and Death
Visitation
Use of Force and Restraints
As these standards were compliant at the time of the review, synopses for these areas were not
prepared for this report.
ODO found deficiencies in the following eight standards:
Admission and Release
Environmental Health and Safety
Food Service
Grievance System
Hold Rooms in Detention Facilities
Medical Care
Telephone Access
Transfer of Detainees
Findings for each of these standards are presented in the remainder of this report.

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ADMISSION AND RELEASE (AR)
ODO reviewed the Admission and Release PBNDS to determine if the facility protects the
community, detainees, staff, volunteers, and contractors by ensuring secure and orderly
operations when detainees are admitted to or released from a facility. ODO reviewed detention
files, forms, policies, procedures, intake processing, and the orientation video; and interviewed
staff assigned to admission and release processing duties, as well as detainees.
ODO observed BTC intake processing officers conducting detainee interviews and completing
questionnaires upon admission. BTC officers are not screening arriving detainees through the
use of metal detectors (Deficiency AR-1). During the ODO review, BTC staff corrected this
deficiency. The staff began using a new metal detector to screen arriving detainees prior to the
conclusion of the CI.
Visual searches and pat-downs of detainees are conducted by BTC officers of the same gender.
BTC policy states strip searches of detainees are only to be conducted by ICE/ERO personnel
with ICE supervisory approval, if reasonable suspicion exists that a detainee may be concealing a
weapon or other contraband. ODO determined that strip searches of detainees upon admission
are not conducted at the facility.
Arriving detainees stated that they are provided with the choice of a shower during intake
processing or in their assigned housing units (Deficiency AR-2). A similar deficiency was noted
during the 2009 ODO QAR. Allowing detainees to shower during intake processing promotes
good health at the facility and potentially prevents diseases from being introduced to the general
population.
BTC policy requires detainees have the opportunity to ask questions and obtain answers from
facility staff following the orientation video. ODO found that the required question and answer
session is not taking place at BTC (Deficiency AR-3). A question and answer session allows
detainees to gain a more thorough understanding of facility services, common practices and
procedures.
ODO reviewed 30 active detention files to ensure all admission and release documents, including
Forms I-203 Order To Detain or Release or I-203A, are maintained in the records and property
files. ODO found all required forms and documents are maintained in detention files.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY AR-1
In accordance with the ICE PBNDS, Admission and Release, section (V)(B)(2), the FOD must
ensure all detainees shall be screened upon admission, ordinarily including: Screening with a
metal detector.

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DEFICIENCY AR-2
In accordance with the ICE PBNDS, Admission and Release, section (V)(B)(2), the FOD must
ensure all detainees shower before entering his or her assigned unit. During the detainee’s
shower, an officer of the same gender shall remain in the immediate area.
DEFICIENCY AR-3
In accordance with the ICE PBNDS, Admission and Release, section (V)(F)(4), the FOD must
ensure, following the orientation video, staff shall conduct a question-and-answer session. Staff
shall respond to the best of their ability. Under no circumstances may staff give advice about a
legal matter or recommend a professional service.

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ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Environmental Health and Safety PBNDS at BTC to determine if the facility
protects detainees, staff, volunteers, and contractors from injury and illness by maintaining high
facility standards of cleanliness and sanitation, safe work practices, and control of hazardous
substances and equipment. ODO toured the facility; interviewed staff; and reviewed policies and
procedures, and documentation of inspections, hazardous chemical management and inventories,
and fire drills.
Direct observation and staff interviews found BTC staff had a clear understanding of the proper
handling of hazardous materials, the need for inventories, and proper storage and issuance
procedures. A master file for Material Safety Data Sheets (MSDS) is maintained in the Safety
Office, and MSDS are available throughout the facility. Employees receive training in
flammable, toxic, and caustic materials during basic orientation and during in-service refresher
training. The facility follows current Occupational Safety and Health Administration (OSHA)
standards, as well as the National Fire Protection Association (NFPA) 101 Life Safety Codes.
ODO verified weekly and monthly fire inspections are completed, and fire protection equipment
was observed strategically located throughout the facility. Documentation of annual inspections
by the local fire marshal was available. Reports for water quality testing and pest control were
current. Facility sanitation is maintained at a high level.
The facility has three emergency power generators. Preventive maintenance is performed by an
external company, and facility staff checks the generators every other week as required by the
standard. However, review of generator logs and staff interviews revealed the generators are
tested every two weeks for a period of 15 to 20 minutes, rather than for one hour as required
(Deficiency EH&S-1). Testing generators for one hour ensures there is sufficient time to reach
operating temperature, verify the engine’s ability to provide the required power over time, and
identify any fuel and oil leaks.
Eye wash stations, which meet OSHA standards, are installed in designated areas throughout the
facility where protective eye and face equipment is used. However, eye hazard warning signs
are not consistently posted (Deficiency EH&S-2).
Emergency exit diagrams, signed by the local fire marshal, and exit signs were observed
throughout the facility. Areas of safe refuge were not identified or explained on the diagrams
(Deficiency EH&S-3).

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EH&S-1
In accordance with the ICE PBNDS, Environmental Health and Safety, section (V)(F), the FOD
must ensure, at least every two weeks, emergency power generators are tested for one hour and
the oil, water, hoses and belts of these generators are inspected for mechanical readiness to
perform in an emergency situation.
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DEFICIENCY EH&S-2
In accordance with the ICE PBNDS, Environmental Health and Safety, section (VI)(B), the FOD
must ensure protective eye and face equipment is available where there is a reasonable
probability of injury that can be prevented by such equipment. Areas of the facility where such
injuries can occur shall be conspicuously marked with eye hazard warning signs.
DEFICIENCY EH&S -3
In accordance with the ICE PBNDS, Environmental Health and Safety, section (VII)(E), the
FOD must ensure, in addition to a general area diagram, "Areas of Safe Refuge" are identified
and explained on these diagrams. Diagram posting will be in accordance with applicable fire
safety regulations of the jurisdiction.

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FOOD SERVICE (FS)
ODO reviewed the Food Service PBNDS at BTC to determine if the facility ensures detainees
are provided a nutritionally balanced diet that is prepared and presented in a sanitary and
hygienic food service operation. ODO interviewed staff, inspected storage areas, observed meal
preparation and service, and reviewed policy and relevant documentation.
Meals are served in the facility dining hall. ODO verified food service personnel received
medical clearances prior to working in food service. A registered dietician certified the menu is
nutritionally complete, and religious and medical diets are provided in accordance with the
standard. Inspection of the food service area revealed food temperatures were met, temperatures
of the coolers and freezers were consistent, and utensils were controlled. No knives are used in
the food service operation.
Sanitation levels for the food preparation, dishwashing, serving line area, and the kitchen overall
were very high. ODO observed the feeding of the noon meal during the second day of the
inspection. A random tray was chosen from the serving line and sampled. The food items were
consistent with the menu, temperature requirements were met, and the sampled food was found
to be tasty. All mandatory components of the standard were reviewed by ODO and found to be
compliant with the requirements of the standard.
Upon inspection of the two dry storage areas, ODO found items and products were stored six
inches off the floor; however, the items were stacked against and touching the walls (Deficiency
FS-1). This deficiency was corrected during the inspection.
ODO notes one area of concern. Detainees on kosher diets are given frozen meals which are
heated one at a time for six minutes in the dining hall’s one microwave oven. Depending upon
the number of detainees on kosher diets, wait time for use of the microwave oven could extend
through the allotted dining time. ODO recommends the facility take steps to ensure all detainees
have ample time to heat and consume their meals.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with the ICE PBNDS, Food Service, section (V)(K)(3)(d), the FOD must ensure
products are stored at least six inches from the floor and sufficiently far from walls to facilitate
pest-control measures.

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GRIEVANCE SYSTEM (GS)
ODO reviewed the Grievance System PBNDS at BTC to determine if the facility protects
detainees’ rights and ensures they are treated fairly by providing a procedure by which they may
file formal grievances and receive timely responses relating to any aspect of his/her detention,
including medical care. ODO interviewed staff, and reviewed logbooks, forms, detainee
grievance policies and procedures, and the detainee handbook.
BTC has a grievance system that allows detainees to submit formal or emergency grievances,
and provides detainees with at least one level of appeal. The grievance process may begin as an
informal grievance where facility staff attempts to resolve the issue at the lowest possible level,
in an orderly and timely manner. The informal grievance may be given either verbally or in
writing. If the grievance is not resolved at this level, or if the detainee decides to skip the
informal process, the detainee may proceed with submitting a formal grievance in writing.
Grievance forms are available at the officer’s station in each housing area.
Detainees who claim an issue is sensitive, or believe their safety or well-being could be
jeopardized if others in the facility were apprised of the nature of the grievance, may seal the
grievance in an envelope and submit it directly to the Facility Administrator. Otherwise, the
detainee can place a grievance in a locked grievance drop box located in the housing area.
Grievances are picked up on a daily basis by a designated BTC staff member and delivered to the
Captain’s office. Each written grievance is logged, and referred to the appropriate department
personnel for resolution. The Captain may also review the grievance for resolution at any time.
The department head officially meets with the detainee and attempts to resolve the issue. If a
detainee agrees with a proposed resolution, the form is signed and a copy is placed in the
detainee’s detention file. This initial process is resolved within five days. If the detainee is not
satisfied with the decision, he/she may file an appeal to the Facility Administrator. A Grievance
Committee conducts a review of the initial findings within five working days of the appeal, and
provides a written response to the detainee stating the decision and the reason(s) for the decision.
The detainee may submit his/her grievance at any time to ICE. According to BTC staff, two
appeals were filed between 2011 and 2012.
ODO interviewed (b)(7)e ICE and(b)(7)e BTC randomly-selected staff members who have daily
contact with detainees, to determine their awareness of the grievance system. All staff members
were able to describe the grievance process, including the informal, formal, and emergency
grievance processes, as well as the appeal process. BTC officers stated they make a concerted
effort to resolve all grievances informally, but do not discourage detainees from filing a formal
grievance. All staff has been trained during an initial orientation and during on-the-job training
to handle emergency grievances expeditiously, ensuring detainee’s safety and welfare.
A review of the Grievance Log revealed grievances are logged with all pertinent information,
including the nature of the grievance and date of resolution. Log numbers are assigned in
chronological order for each grievance. The log is maintained in the Captain’s office.

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ODO reviewed the grievance log from July 2011 to February 2012, and noted 18 formal logged
grievances. Seventeen grievances were resolved within five days and the remaining grievance
was forwarded to ERO for resolution. Four grievances were medical care-related. All were
referred to, and resolved by, the facility medical unit prior to ODO’s arrival. Two grievances
were appealed, of which one was withdrawn by the detainee. BTC management informed ODO
that there has been no pattern of misuse of the grievance system by any detainees. A review of
BTC documentation revealed the facility does not document informal grievances in detainee
detention files, logs, or data systems to track such actions, as required (Deficiency GS-1).
Detainees are informed of the grievance system through the BTC orientation video and detainee
handbook. ODO randomly interviewed 20 males and 5 females who had never filed a grievance
at BTC to determine their respective overall understanding of the grievance system. All stated
they are aware of the grievance process and currently have no reasons to complain about the
facility.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY GS-1
In accordance with the ICE PBNDS, Grievance System, section (V)(B), the FOD must ensure the
facility documents the informal grievances in the detainee’s Detention File and in any logs or data
systems the facility has established to track such actions.

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HOLD ROOMS IN DETENTION FACILITIES (HR)
ODO reviewed the Hold Rooms in Detention Facilities PBNDS at BTC to determine if the
facility ensures the safety, security, and comfort of detainees temporarily held in hold rooms
waiting further processing. ODO also reviewed this standard to determine if the maximum
aggregate time an individual may be confined in the facility’s hold room is 12 hours. Hold
rooms are used for detention of individuals awaiting removal, transfer, Executive Office of
Immigration Review hearings, medical treatment, intra-facility movement, or other processing
into or out of a facility. ODO interviewed staff and inspected the intake area.
BTC does not have an area designated as a hold room. However, BTC has a multi-occupancy
waiting room in the intake area used to temporarily hold detainees waiting processing. Though
not referred to as a hold room, ODO determined BTC’s waiting room serves the purpose of a
hold room as defined in the standard, and all requirements apply. Measuring 12 feet by 16 feet,
the room qualifies as a small hold room adequately sized to hold up to 14 detainees. The room
was well ventilated and well lit; however, the activating switches were not located outside the
room in places accessible to staff only. ODO observed activating switches were in the room and
covered with standard, removable plates. Benches provide sufficient seating for 14 detainees;
however, they are moveable and not bolted to the floor or attached to the wall. The room is not
equipped with a stainless steel, combination lavatory/toilet fixture, though there is one porcelain
sink and toilet. Porcelain may be broken and is a security risk. The room does not have a floor
(b)(7)e
drain to prevent accidental or intentional flooding. ODO observed
(b)(7)e

(Deficiency HR-1).

(b)(7)e

ODO notes one area of concern. Whereas BTC has neither a secure hold room nor a Special
Management Unit, there is no area to secure a detainee requiring a higher degree of restraint or
supervision for a temporary period of time. In addition, no written procedures are in place to
ensure consistent and appropriate action is taken in the event a detainee becomes unruly and
combative, to the point where removal from the general population is necessary. Interviews with
shift supervisors and senior executive staff revealed no consistency with respect to procedures
that would be followed. To support staff and detainee safety, ODO recommends development of
procedures addressing actions to be taken when a detainee must be temporarily secured.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY HR-1
In accordance with the ICE PBNDS, Hold Rooms in Detention Facilities, section (V)(A)(3-4)(69)(12), the FOD must ensure, based on the ICE/[ERO] Hold Room Design Guide, Hold Rooms
shall be designed and constructed to comply with the following criteria:
3. Each Hold Room shall be well ventilated and well lit. All activating switches and
controls shall be located outside the room, in places accessible to staff only.

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4. Each Hold Room shall contain sufficient seating for the maximum room-capacity but
shall contain no moveable furniture. Benches shall provide 18" of seat space per detainee
and may be bolted to the floor or attached to the wall if the wall is of suitable
construction.
6. Each Hold Room shall be equipped with stainless steel, combination lavatory/toilet
fixtures with modesty panels, in compliance with the Americans with Disabilities Act of
1990. Consistent with the International Plumbing Code:
 Each small Hold Room (up to 14 detainees) shall have one combi-unit;
 Each large Hold Rooms (15 to 49 detainees), at least two combination units.
(The Hold Room Design Standards A-E, HDR Architecture, recommends a
third combination unit for a Hold Room with 30 or more detainees, or one
combination unit for every 15 detainees).
7. Each Hold Room shall have floor drain(s).
8. Hold-room walls shall be escape- and tamper-proof, for example, 8-inch, reinforced
concrete masonry unit wall. Impact-resistant, steel-studded surfaces shall also meet this
standard, especially in existing buildings that cannot support reinforced concrete. The
walls shall extend and be built into the floor/room structure above. Ceilings shall also be
escape- and tamper-proof, preferably 10 to 16 feet high, but no less than 9 feet, except in
currently existing facilities with lower floor-to-floor heights.
9. Each Hold Room shall have two-inch thick, detention-grade, 14-gauge steel doors that
swing outward, and the 14-gauge steel doorframes shall be grouted into the surrounding
wall. Also required are tamper-resistant bolt locks, door-mounted with paracentric keys,
jamb-mounted, with mogul keys.
12. The glazing shall meet or exceed the impact-resistant standard of glass-clad
polycarbonate laminate. Window jambs shall be 14-gauge steel.

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MEDICAL CARE (MC)
ODO reviewed the Medical Care PBNDS at BTC to determine if the facility ensures detainees
have access to emergent, urgent, or non-emergent medical, dental, and mental health care that are
within the scope of services provided by the ICE Health Service Corps, so that their health care
needs are met in a timely and efficient manner. ODO toured the medical clinic, reviewed
policies and procedures, interviewed detainees, and examined 30 ICE detainee health files. ODO
also observed sick call, intake screening, and initial health appraisals. Several medical staff were
interviewed, to include the Health Services Administrator, Clinical Director, nursing staff, and
correctional officers assigned to the Health Services Unit.
BTC is currently accredited by the American Correctional Association (ACA). Health care for
the approximate 600 male and female detainees is provided 24 hours a day, seven days a week,
by GEO Group Inc. Staffing includes a Health Services Administrator who is also a licensed
Registered Nurse,(b)(7)eLicensed Registered Nurses(b)(7)eLicensed Practical Nurses, and (b)(7)e
medical secretary/clerk. There is currently(b)(7)eLicensed Practical Nurse vacancy. Contract staff
includes a physician who is on-site 40 hours a week, a physician assistant (PA) as needed, and an
X-ray technician. Dental care is provided off-site on an as-needed basis. Contracts for off-site
care are in place with the North Broward Medical Center and the Atlantic Shores Hospital.
The medical clinic is of adequate size and is sufficiently equipped to serve the detainee
population. There are three examination rooms, two observation rooms, secure medication and
medical records rooms, a nursing station, a supply storage room, a hazardous waste closet, and
two offices. There are two detainee waiting rooms so male and female detainees can be
separated, and each waiting area has access to restrooms and drinking water. Each waiting area
also has a television that plays health wellness videos for detainees as they wait for their
appointment.
Medical and mental health screenings are performed by nursing staff at the time of intake.
Health records of 30 ICE detainees were reviewed, and all records included documentation of
complete, thorough intake screenings performed upon arrival. Available data indicates there
were 7,641 intake health screenings conducted in 2011. Screening for TB is performed as part of
intake processing by way of low radiation digital chest X-rays, located in the receiving area.
Chest X-ray results are returned within four hours of taking the X-ray, which ODO identifies as a
best practice. Determination of the presence or absence of possible TB during intake supports
infection control.
In all 30 records reviewed, ODO found physical examinations (PE) were completed within 14
days of arrival by trained Registered Nurses or the physician. PE’s are performed in accordance
with the PBNDS and the National Commission on Correctional Health Care standards, and ICE
Health Service Corps Performance Improvement criteria were met. Initial assessments
performed by a Registered Nurse were reviewed by the physician, and appropriate follow-up
occurred.

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Detainees request health care services by submitting written request forms, available in English
and Spanish. The forms are deposited into a locked box outside the Health Services Unit. Nonmedical staff does not handle detainees’ medical request forms. The Health Services Unit is
located directly across the hall from the detainee dining room, which gives detainees three
opportunities each day to submit requests. ODO verified requests are triaged within 48 hours
and, when indicated, a sick call appointment is provided either the same day or within 24 hours.
Chronic care clinics are provided to detainees with chronic conditions and special needs. ICE
detainees are not charged medical co-pays. Available data indicates, during 2011, there were
6,016 detainee contacts with the physician, and 84,561 detainee encounters with nursing staff.
ODO’s review of(b)(7)e ustody staff and(b)(7)e edical staff training records revealed all were
certified in first aid and cardiopulmonary resuscitation (CPR). Initial or emergent mental health
problems are addressed by the staff physician, as there are no licensed mental health providers at
BTC. Detainees are referred to a psychiatrist in the local community when required. A review
of records for ten detainees referred to the psychiatrist revealed none were seen by the
psychiatrist within 14 days of the referral (Deficiency MC-1).
Medications are stored in a secure medication room that has a window leading directly to the
BTC compound, through which medications are administered. There is a drinking fountain
outside the window to ensure detainees swallow their medications. Prescribed medications for
chronic conditions, such as heart disease, diabetes, and hypertension, are administered by trained
medical staff. There are limited medications detainees are allowed to keep on person, such as
inhalers and nitroglycerin. Though medical personnel are available at the facility round-theclock, BTC policy states over-the-counter medications such as Ibuprofen, Tylenol, aspirin, BandAids, antacids, and throat lozenges are given to detainees by officers. Consistent with the
PBNDS, the policy further states officers must be trained to perform this function; however, the
HSA was able to produce documentation of training for only six of the total complement of BTC
officers. No syllabus or lesson plan was produced for their training. ODO’s review of the log
used by officers documenting when detainees are given over-the-counter medications revealed
officers other than the six who were trained gave medications to detainees. Further, ten
randomly-selected officers’ training records included no documentation of training. Though the
medications are over-the-counter, these medications may be misused and abused. The
medication may also be contraindicated by prescribed medications or the detainee’s medical
condition. Dispensing of these medications is neither reviewed by medical personnel nor
documented in detainees’ medical records (Deficiency MC-2). A similar deficiency was noted
during the 2009 ODO QAR.
ODO further notes, according to BTC policy, officers are to be trained to not only distribute
over-the-counter medications, but also to determine when there is chronic use or abuse. Even if
officers were trained, ODO considers it an unwise and potentially dangerous practice to assign
this responsibility to non-medical personnel. As BTC has round-the-clock medical coverage,
ODO recommends rescinding its policy allowing distribution of over-the-counter medications by
correctional officers.

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STANDARD/POLICY REQUIREMENT FOR DEFICIENT FINDINGS
DEFICIENCY MC - 1
In accordance with the ICE PBNDS, Medical Care, section (V)(K)(4), the FOD must ensure any
detainee referred for mental health treatment receives a comprehensive evaluation by a licensed
mental health provider as clinically necessary, but no later than fourteen days of the referral.
DEFICIENCY MC–2
In accordance with the ICE PBNDS, Medical Care, section (V)(P), the FOD must ensure
distribution of medication is in accordance with specific instructions and procedures established
by the administrative health authority. Written records of all medication given to detainees shall
be maintained.
 If medication must be delivered at a specific time when medical staff is not on duty, it
may be distributed by detention officers who have received proper training by the
administrative health authority.
 The facility shall maintain documentation of the training given any officer required to
distribute medication, and the officer shall have available for reference the training
syllabus or other guide or protocol provided by the health authority.
 Detainees may not deliver or administer medications to other detainees.

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TELEPHONE ACCESS (TA)
ODO reviewed the Telephone Access PBNDS at BTC to determine if the facility ensures
detainees may maintain ties with their families and others in the community, legal
representatives, consulates, courts, and government agencies by providing them reasonable and
equitable access to telephone services. ODO toured BTC, and interviewed ERO and facility staff
as well as ICE detainees. ODO also reviewed Telephone Serviceability records maintained by
BTC and ERO.
ODO found telephone equipment is maintained in proper working order. All 86 telephones were
inspected daily, and needed repairs were completed promptly. Serviceability records, maintained
by BTC and ERO, were available for review. ICE staff inspects the telephones weekly and
documents that speed dial checks are performed.
The ratio of telephones to detainees is 1 to 8, exceeding the PBNDS requirement. At no time,
during the inspection were detainees observed waiting to use a telephone. Although BTC is
undergoing extensive construction, facility staff put forth great effort in ensuring the level of care
provided to ICE detainees is not diminished.
ODO noted one area, a male dayroom, where telephone rules were not posted (Deficiency TA1). The lack of notice of telephone rules in the dayroom was communicated to the BTC Program
Manager, and was immediately corrected.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY TA-1
In accordance with the ICE PBNDS, Telephone Access, section (V)(C), the FOD must ensure
the facility shall provide telephone access rules in writing to each detainee upon admission, and
also shall post these rules where detainees may easily see them in a language they understand.

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TRANSFER OF DETAINEES (TD)
ODO reviewed the Transfer of Detainees PBNDS at BTC to determine if the facility ensures
transfers of detainees from one facility to another are professionally and responsibly managed in
regard to notifications, detainee records, safety and security, and protection of detainee funds and
personal property. For detainee transfers outside of the Field Office Director’s area of
responsibility, ODO reviewed ICE Policy 11022.1, Detainee Transfers, to determine if ICE staff
makes all notifications and provides all documents required by the policy. ODO reviewed
policies and procedures, and interviewed staff regarding the transfer of detainees from one
facility to another.
According to ERO staff, the majority of the detainees housed at BTC were processed at the
Krome Service Processing Center (Krome SPC). Transfers to BTC are mainly from Krome SPC
and the Glades County Detention Center, both located in the FOD/Miami’s area of
responsibility. Detainees are transferred to BTC for operational purposes, including eliminating
overcrowding in some facilities, a change of court venue, and for legal representation. Detainees
are transferred from BTC to other facilities for similar reasons, as well as for medical and
disciplinary reasons. Staff interviews and detention file reviews confirmed, before a detainee is
transferred, BTC returns all funds and property to each detainee.
The PBNDS requires a Detainee Transfer Checklist (Checklist) to be completed for every
detainee processed for transfer. A properly executed Checklist provides comprehensive
information and reasons for transfer, and alerts officers to any pertinent concerns, including
safety or security issues. ERO staff is responsible for generating the Checklist and providing a
copy to the receiving facility; however, BTC has a locally-generated Transfer Checklist, which is
referred to as the Admission and Orientation Checklist. The Admission and Orientation
Checklist does not cover all required information, and therefore cannot be considered an
adequate alternative form.
ODO reviewed 30 detention files belonging to detainees who were transferred to BTC from other
ICE facilities within the FOD/Miami’s area of responsibility. All 30 files reviewed contained a
copy of the BTC Admission and Orientation Checklist, but none contained the required ERO
Checklist. ODO interviewed ICE staff to determine whether the Checklist and notification
paperwork are completed during processing, and if the copies of the completed paperwork are
maintained in the A-file, and corresponding detention file. ICE staff stated they have not always
completed and provided the Detainee Notification form to detainees during transfer (Deficiency
TD-1). Additionally, the Detainee Transfer Checklist has not always been completed and
maintained in each detainee’s A-File or detention file (Deficiency TD-2). ODO reiterated a
properly executed Checklist ensures all required processing procedures have been completed
prior to a transfer. The Checklist also provides pertinent information about the detainee to the
receiving facility.
ICE and BTC staff also stated information about the transfer is not disclosed to detainees until
immediately prior to leaving the sending facility, as a safety precaution. From interviews and

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file reviews, ODO verified Form G-391, Official Detail form, and the Medical Transfer
Summary forms are completed, and copies are maintained in all detention files.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY TD-1
In accordance with the ICE PBNDS, Transfer of Detainees, section (V)(B), the FOD must ensure
ICE/[ERO] shall make all necessary notifications when a detainee is transferred.
DEFICIENCY TD-2
In accordance with the ICE PBNDS, Transfer of Detainees, section (V)(D), the FOD must ensure
sending facility staff shall complete the attached Detainee Transfer Checklist to insure all
procedures are completed. The sending facility staff shall place a copy of the checklist in the
detainee’s A-file or work folder. The records must accompany the detainee to the receiving
facility. If any procedure cannot be completed prior to transfer, the detainee may be transferred
only if the authorized receiving Field Office official has expressly waived that procedure and
sending facility staff shall note any such waivers on the Checklist.

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