ICE Detention Standards Compliance Audit - CCA Mason, Mason, TN, ICE, 2007

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ICE Detention Standards Compliance Audit - CCA Mason, Mason, TN, ICE, 2007

• June 2, 2016 • Locations: United States of America -> Tennessee • Topics: Corrections Corporation of America/CoreCivic, Corrections Audits, Immigration

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•

Department of Homeland securit).
Immigration and Customs Enforcement
Office of Detention and Removal

Condition of Confinement Review Worksheet
(This document must be attached to each G-324a Inspection Form)
This Form to be used for Inspections of alllGSA Facilities Used over 72 Hours

Field Office Detention Review Worksheet

Local Jail- IGSA
State Facility - IGSA
ICE Contract Detention
Name
CCAMason
Address (Street and Name)
P.O. Box 509
State and Zip Code
TN 38049

of Chief Executive Officer (Warden/OIC/Superintendent)

Assessment

Other

•

Table of Contents

DETAINEE SERVICES STANDARDS

(SECTION I)

............................................................. 3

'~~~~I~~ ~~1~i~~~,~~:,:::~::::::::::::::::::::::::::::::::::::::~:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: ..... C~~I.~!.~~:.~~~RJ'~i;;;~·~;~~;~~~~:::::~
CLASSIFICATION SYSTEM ........................................................................................................................ .
CORRESPONDENCE AND OTHER MAIL...... , ................................... , ........................................................... .
DETAINEE HANDBOOK ............................................................................................................................ .
FOOD SERVICE""" .......................................... , ........................................................................................... .
FUNDS AND PERSONAL PROPERTY .......................................................................................................... .

.;p~T~l'!l?~ g~!3:y.~~~. ~~~~~.r>y~~.~:,:.,: ,.,: ,.~: ,:.:: ,'~: 'c'.:, c·,: c·,: ,.~:, .,'"

c·,: C·.·::C·::C·': C','" c·,: c·:: :.,':: C'~: ,.,',: c·, ".,':: c·, ......... { Deleted: II
GROUP PRESENTATIONS ON LEGAL RIGHTS........................ ..... ........... ............................ .... ....... ..............
'------''--------

ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS.~ •.•. ,............,.•.•.•.,......:.:.•.:.,....,......,.:.:..:.•.•.•.•.:........!.!.•.•.•.:....:.:.•.:.:.•.•.•. "-••
MARRIAGE REQUESTS ............................................................................................................................. .
NON·MEDICAL ESCORTED TRIPS ............................................................................................................ .
RECREATION ........................................................................................................................... : ................ .
RELIGIOUS PRACTICES ....= ..........:.:...........:.:.•.:.•.•.•.•.•.•.•. ! .•.•.:.................,.~!.!:.!'"-.•".:..•.•.••!!.!....:.......~.•.•.:.:............ :..•.•.: .•.•!!•.:!'.:.•.:.:.!:.•~.:.•.: .•.:..:".•.•.:.:..=....'-'!•.,.:....:"•.,.............:.:....
ACCESS TO TELEPHONES ................................... ,=".!.................................................................................
VISITATION .............................................................................................................................................. .
VOLUNTARY WORK PROGRAM ............................................................................................................... .

HEALTH SERVICES STANDARDS (SECTION II) ................................................................. 33
HUNGER STRIKES .................................................................................................................................... .
MEDICAL CARE ....................................................................................................................................... .
SUICIDE PREVENTION AND INTERVENTION ............................................................................................ ..
TERMINAL ILLNESS, AnV ANCED DIRECTIVES AND DEATH .......:....,.............,........:......:.:..=.•.•.•~•.,............,......:....................:.......=.:... .!.!.'-' •..'~....." .......

SECURITY AND CONTROL STANDARDS (SECTION ill) .................................................. 40

~~I\J.T~~l'!:r;>,,·~ :,.~::,.: :,'~, :c.:: ,.:: ,.,':,.,':: ,.,: ,.~: 'c·,:c·~:::·: :,.:: ,.,'"

,.,: ,.,: ,.,', , ,.: ::.:::.,':::.:: ,.::,.,',: c':: ,.:" ,.:: ,.:: ,.,':: c·:: ,':: ,',': ...... ' .-( Deleted: ~
DETENTION FILEs.....................................................................................................................................
~--'--------~
DISCIPLINARY POLICy ... ·.......................................................................................................................... .
EMERGENCY PLANS ................: ... ".=.,............................. ::=.:.:=! ............... ::.,......................... .:.:.!.:.:...!•.:~
ENVIRONMENTAL HEALTH AND SAFETy ................................................................................................ ..
HOLD ROOMS IN DETENTION FACILITIES ................................. ! .............................................................. .
KEy AND LOCK CONTROL ....................................................................................................................... .
POPULATION COUNTS .............................................................................................................................. .

f.9.~T. Q~~~..,':: ,.,'::.::, :':: ,','.: ,:.:: c·: ::.,':, c·,::·,': ,.::: c·:: ,.,':::.,',.:,: c·,: ,.,':, .,':, c·,: ",'.::C':::':::',': :.,',: ,.::::','. c·:: ,.,': ,.,':: c',: ::::, .,', ...... ,. {LDeleted:
-_ _ 1r _ _ _ _ _ _ _ _ _ _ _ _
~

=. . .:. . . . . :. . . . :. . . . . .:. . . . . . . . .:. . . . . . .:.:. . . .

SECURITY INSPECTIONS.•.•.!.! .••: .•.•.:......:......:.•., ...." .•.:.., .•.:.!.!..'...............:....:.•-".:....! =..•.•.• ! •.!.!.•.•"~ .......:.•.•. :..•., .•. :......: .•.•.:....." •.•.•.
~
SPECIAL MANAGEMENT UNIT (ADMINISTRATIVE SEGREGATION) .......................................................... .
SPECIAL MANAGEMENT UNIT (DISCIPLINARY SEGREGATION) ............................................................... .
TOOL CONTROL ................. : ..................................................................................................... ::............... .
TRANSPORTATION (LAND) .............................................................. , ................ " ..................................... .
USE OF FORCE-==.:.:,.=.=" ................... !: ......................................................................... : ................,
STAFF/DETAINEE COMMUNICATIONS ..................................................................................................... .
DETAINEE TRANSFER STANDARD ..:.................................. ,........

=. . . .

.:.! •..•.•.•.:.............................., .•..•., .•.•.., ............

"!!.•.•.•.,,..................!.!.! .•.•. = . . . . . . . ". . . . . .

! •..•.•.•.•..•.•.•..•.•.:...... .

For each standard rated below Acceptable, facilities must attach a Plan of Action for bringing
operations into compliance. Each facility should examine the entire worksheet to identify areas of
improvement including those standards where an overall finding of acceptable was achieved.
2
G·324A Detentiolllnspection Form Worksheet for IGSAs . Rev: 01104/05

•

Section I
Detainee Services Standards

3
G·324A Detention Inspection Fonn Worksheet for IGSAs . Rev: 01104/05

•

ACCESS TO LEGAL MATERIALS

The facility provides a designated law library for
detainee use.
The law library contains all materials listed in the
"Access to Legal Materials" Standard, Attachment A.
The IistinQ of materials is posted in the law library.
The library contains a sufficient number of chairs, is well
lit and is reasonably isolated from noisy areas.
The law library is adequately equipped with typewriter,
computers or both and has sufficient supplies for daily
use by the detainees.
In addition to the physical law library, ICE detainees
have access to the Lexus Nexus electronic law library.
Where provided, the Lexus Nexus library is updated and
is current.
Outside persons and organizations are permitted to
submit published legal material for inclusion in the legal
library. Outside published material is forwarded and
reviewed by the ICE prior to inclusion.
There is a designated ICE or facility employee who
inspects, updates, and maintain/replace legal material
and equipment on a routine basis.
Detainees are offered a minimum 5 hours per week in
the law library. Detainees are not reguired to forego
recreation time in lieu of librarY usage. Detainees facing
a court deadline are given priority use of the law library.
Detainees may request material not currently in the law
library. Each request is reviewed and where appropriate
an acqUisition request is initiate and timely pursued.
Request for copies of court decisions are
accommodated within 3 - 5 business days.
The facility permits detainees to assist other detainees,
voluntarily and free of charge, in researching and
preparing legal documents, consistent with security.
Staff ensures that illiterate or non-English-speaking
detainees without legal representation receive more
than access to English-language law books after
indicating their need for help.
Detainees may retain a reasonable amount of personal
legal material in the general population and in the
special management unit. Stored legal materials are
accessible within 24 hours of a written request.
Detainees housed in Administrative Segregation and
Disciplinary Segregation units have the same law library
access as the general population, barring security
concerns. Detainees denied access to legal materials
are documented and reviewed routinely for lifting of
sanctions.
All denials of access to the law library fully documented.
Facility staff informs ICE Management when a detainee
or group of detainees is denied access to the law library
or law materials.

[8l

18l

Remarks

Memphis S.O. provided
Lexus Nexus and
computer.

No request.

4
G·324A Detention Inspection FOIm Worksheet for IOSAs . Rev: 01104/05

•

ACCESS TO LEGAL MATERIALS

Policy: Facilities holding ICE detainees shall permit detainees access to a law library, and provide legal
materials, facilities, equipment and document copying privileges, and the opportunity to prepare legal
. documents.
Components
Detainees who seek judicial relief on any matter are not
subjected to reprisals, retaliation, or penalties.
~ Acceptable

o Deficient

['gJ

At-Risk

Remarks

o Repeat Finding

Remarks: (Record significant facts, observations, alternate source used for verification, etc.)
(b)(6), (b){7)c

.." h
""d•

") - ...J'

•.. ~)

5
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

•

ADMISSION AND RELEASE

•

Policy: All detainees will be admitted and released in a manner that ensures their health, safety, and welfare.
The admissions procedure will, among other things include: medical screening; a file-based assessment and
, classification process; a body search; and a search of personal belongings, which will be inventoried,
documented, and safeguarded as necessary.
..- - ....
•..
. - -..
---'--"
Components
N
,I
Y
NA
Remarks
In processing includes an orientation of the facility.
The orientation includes; Unacceptable activities and
behavior, and corresponding sanctions; How to contact
ICE; The availability of pro bono legal services, and
how to pursue such services. Schedule of programs,
[gI
0
0
services, daily activities, including visitation, telephone
usage, mail service, religious programs, count
procedures, access to and use of the law library and
the general library; sick-call procedures, etc., and the
detainee handbook.
Medical screenings are performed by medical staff or
[gI
persons who have received specialized training for the
0
0
purpose of conducting an initial health screening.
Each new arrival is classified according to criminal
[gI
history and threat levels, Criminal history is provided
0
0
for each detainee by the ICE field office.
All new arrivals are searched in accordance with the
"Detainee Search" standard. An officer of the same
[gI
sex as the detainee conducts the search and the
0
0
search is conducted in an area that affords as much
privacy as possible.
Detainees are stripped searched only when cause has
been established and not as routine policy. Non[gI
0
0
criminal detainees are not strip-searched but are patted
down unless reasonable suspicion is established.
The "Contraband" standard governs all personal property
searches. I GSAs/CDFs use or have a similar contraband
[gI
0
0
standard. Staff prepares a complete inventory of each
detainee's possessions. The detainee receives a copy.
Staff completes Form 1-387 or similar form for CDFs and
[gI
IGSAs for every lost or missing property claim. Facilities
0
0
forward all 1-387 claims to ICE.
Detainees are issued appropriate and sufficient clothing
~
0
0
and bedding for the climatic conditions.
The facility provides and replenishes personal hygiene
[gI
items as needed. Gender-specific items are available.
0
0
ICE Detainees are not charged for these items.
All releases are properly coordinated with ICE using a
[gI
0
0
Form 1-203.
Staff completes paperwork/forms for release as required,
0
0
LJ

D Deficient

~ Acceptable

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b )(7)c

,
I

6
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

o Repeat Finding

•

CLASSIFICATION SYSTEM

Policy: All facilities will develop and implement a system according to which ICE detainees are classified. The
: classification system will ensure that each detainee is placed in the appropriate category, physically separated
. from detainees in other categories

Components
- - - _ . _ - _ . _ - _ . __ ._-_...
.... The facility has a system for classifying detainees. In
CDFs and IGSAs, an Objective Classification System
or similar is used.
The facility classification system includes:
• ClaSSifying detainees upon arrival.
• Separating individuals who cannot be classified
upon arrival from the general population.
• The first-line supervisor or designated
classification specialist reviewing every
classification decision.
The intake/processing officer reviews work-folders, Afiles, etc., to identifyand classify_each new arrival.
Staff use only information that is factual, and reliable to
determine classification assignments. Opinions and
unsubstantiated/ unconfirmed reports may be filed but
are not used to score detainees classifications.
Housing assignments are based on classificationlevel.
A detainee's classification-level does not affect his/her
recreation opportunities. Detainees recreate with
persons of similar classification designations.
Detainee work assignments are based upon
classification designations.
The classification process includes
reassessment/reclassification. At IGSA's , detainees
mayrElquest reassessment 60 days after arrival.
Procedures exist for a detainee to appeal their
classification assignment. Only a designated
supervisor or classification specialist has the authority
to reduce a classification-level on appeal.
Classification appeals are resolved within five business
days and detainees are notified of the outcome within
10 business days.
Classification designations may be appealed to a
hiQher authority such as the Warden or equivalent.
The Detainee Handbook or equivalent for IGSAs
explains the classification levels, with the conditions
and restrictions applicable to each.

--:;:;- ...

o Acceptable

o Deficient

-".-

_ .. _ -

NA
_...

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

7
G-324A Detention blspection Fonn Worksheet for lGSA. - Rev: 01/04/05

Remarks

- - - - - - _..

o Repeat Finding

-._-

•

CORRESPONDENCE AND OTHER MAIL

The rules for correspondence and other mail are posted
in each housing or common area or provided to each
detainee via a detainee handbook.
The facility provides key information in languages other
than English; In the language(s) spoken by significant
numbers of detainees. List any exceptions.
Incoming mail distributed to detainees within 24 hours or
1 business day after it is received and insRected.
Outgoing mail is delivered to the postal service within
one business day of its entering the internal mail system
(excludinfl weekends and holidays).
Staff do not open and inspect incoming general
correspondence and other mall (including packages and
publications) without the detainee present unless
documented and authorized in writing by the Warden or
equivalent for prevailing security reasons.
Staff does not read incoming general correspondence
without the Warden's prior written approval.
Staff does not inspect incoming special Correspondence
for physical contraband or to verify the "special" status
of enclosures without the detainee present.
Staff are prohibited from reading or copying incoming
special correspondence.
Staff are only authorized to inspect outgoing
correspondence or other mail without the detainee
present when there is reason to believe the item might
present a threat to the facility's secure or orderly
operation, endanger the recipient or the public, or might
facilitate criminal activity.
Correspondence to a politician or to the media is
processed as special correspondence and is not read or
copied.
The official authorizing the rejection of incoming mail
sends written notice to the sender and the addressee.
The official authorizing censorship or rejection of
outgoing mail provides the detainee with signed written
notice.
Staff maintains a written record of every item removed
from detainee mail.
The Warden or equivalent monitors staff handling of
discovered contraband and its disposition. Records are
accurate and up to date.
The procedure for safeguarding cash removed from a
detainee protects the detainee from loss of funds and
theft. The amount of cash credited to detainee accounts
is accurate. Discrepancies are documented and
investigated. Standard procedure includes issuing a
receipt to the detainee.

Yes

8
G-324A Detention Inspection FOlm Worksheet for IGSAs - Rev: 01104/05

Remarks

ERMAIL

CORRESPONDENCE AND

Policy: All facilities will ensure that detainees send and receive correspondence in a timely manner, subject to
limitations required for the safety, security, and orderly operation of the facility. Other mail will be permitted,
subject to the same limitations. Each facility will widely distribute its guidelines conceming correspondence and
other mail.
Original identity documents (e.g., passports, birth
certificates) are immediately removed and forwarded to
ICE staff for
in A-files.
aetamee a copy of
Staff disposes of prohibited items found in detainee mail
in accordance with the "Control and Disposition of
Contraband" Standard or the similar prevailing policy in
IGSAs.

and

cg] Acceptable

D Deficient

[gJ

At-Risk

9
G-324A Detention Inspection FOlm Worksheet for IGSAs - Rev: 01104/05

D Repeat Finding

•

---- . ---.---..- - .. ···_······---··--b-ETAIN-.
EE-H-AND-B-O()-K-· ··-·---···--·--····-----·--1
Policy: Every ole will develop a site-specific detainee handbook to serve as an overview of, and guide to, the
detention policies, rules, and procedures in effect at the facility. The handbook will also describe the services,
programs, and opportunities available through various sources, including the facility, ICE, private organizations,
etc. Every detainee will receive a copy of this handbook upon admission to the facility.
Components

The detainee handbook is written in English and
translated into Spanish or into the next most-prevalent
Language(s).
The handbook supplements the facility orientation
video where one is provided.
All staff members receive a handbook and training
regarding the handbook contents.
The handbook is revised as necessary and there are
procedures in place for immediately communicating
any revisions to staff and detainees.
There an annual review of the handbook by a
designated committee or staff member.
The detainee handbook address the following issues:
• Personal Items permitted to be retained by the
detainee.
• Initial issue of clothes, bedding and personal
hygiene items.
The detainee handbook states in clear language basic
detainee responsibilities.
The handbook clearly outlines the methods for
classification of detainees, explains each level, and
explains the classification appeals process.
The handbook states when a medical examination will
be conducted.
The handbook describes the facility, housing units,
dayrooms, In-dorm activities and special management
units.
The handbook describes; Official count times and
count procedures Meal times, feeding procedures,
procedures for medical or religious diets, smoking
policy, Clothing exchange schedules and if authorized,
clothes washing and drying procedures and expected
personal hygiene practices.
The handbook describe times and procedures for
obtaining disposable razors and allows that detainees
attending court will be afforded the opportunity to shave
first.
The handbook describes barber hours and hair cutting
restrictions.
The handbook describes; the telephone policy, debit
card procedures, direct and frees calls; locations of
telephones; policy when telephone demand is high; and
policyand procedures for emergency phone calls.
The handbook addresses religious programming.
The handbook states times and procedures for
commissary or vending machine usage. (where
available)
The handbook describes the detainee voluntary work
program.

[gI

C8J

[gI

C8J

[gI

C8J

10
G-324A Detention Inspection Fonn Worksheet for IGSAs .. Rev: 01104/05

Remarks

•

DETAINEE HANDBOOK

Policy: Every OIC will develop a site-specific detainee handbook to serve as an overview of, and guide to, the
. detention policies, rules, and procedures in effect at the faCility. The handbook wtll also describe the services,
, programs, and opportunities available through various sources, including the facility, ICE, private organizations,
; etc. Every detainee will receive a copy of this handbook upon admission to the facility.
Components

The handbook describes the library location and hours
of operation and law library procedures and schedules.
The handbook describes; attomeyand regular visitation
hours, policies, and~rocedures.
The handbook describes the facility contraband policy.
The handbook describes the facility visiting hours and
schedule and visiting rules and regulations.
The handbook describes the correspondence policy

D
D
D

and~ocedures.

The handbook describes the detainee disciplinary policy
and procedures:
Including:
• Prohibited acts and severity scale sanctions.
• Time limits in the Disciplinary Process.
Summary of Disciplinary Process.
The grievance section of the handbook explains all
steps in the grievance process - Including:
• Informal (if used) and formal grievance
procedures;
The appeals process;
• In CDF facilities: procedures for filing an
appeal of a grievance with ICE.
• Staff/detainee availability to help during the
grievance process.
Guarantee against staff retaliation for
filing/pursuing a grievance.
• How to file a complaint about officer
misconduct with the Department of Homeland
Security.
The detainee handbook describes the medical sick call
procedures for general population and segregation.
The handbook describes the facility recreation policy
including:
• Outdoor recreation hours.
• Indoor recreation hours.
The handbook describes the detainee dress code for
daily living; and work assignments.
The handbook specifies the rights and responsibilities
of all detainees.

Remarks

D
0

•

I:8J Acceptable

D Deficient

At-Risk

11
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

D Repeat Finding

•

FOob SERVICE"----·-·---···--·····---···--····

Policy: Every facility will provide detainees in its care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.
..

Components
Y
_-_
..... _--_
_._------- r-.--The food service program is under the direct
.....••_--_.....

. ...

supervision of a professionally trained and certified
service administrator. Responsibilities of cooks and
cook foremen are in writing. The Food Service
Administrator (FSA) determines the responsibilities of
the Food Service Staff.
The Cook Foreman is on duty on days when the FSA is
off duty and vice versa.
The FSA provides food service employees with training
that specifically addresses detainee-related lssues.

•

In ICE Facilities this includes a review of the
ICE "Food Service" standard

Knife cabinets close with an approved locking device
and the on-duty cook foreman maintains control of the
key_that locks the device.
All knlves not in a secure cuWng room are physlcally
secured to the workstation and staff directly supervise
detainees using knives at these workstations. Staff
monitor the condition of knives and dining utensils
Special procedures (when necessary) govern the
handling of food items that pose a security threat.
Operating procedures include daily searches
(shakedowns) of detainee work areas.
The FSA monitor staffs implementation of the facility's
population counts procedures. Staff are trained in
counts procedures.
The detainees assigned to the food service department
look neat and clean. Their clothing and grooming
comply with the "Food Service" standard.
The FSA annually reviews detainee-volunteer job
descriptions to ensure they are accurate and up-todate.
The Cook Foreman or equivalent instructs newly
assigned detalnee workers in the rules and procedures
of the food servlce department.
During orientation and tralning session{s), the CS
explains and demonstrates:
• Safe work practices and methods.
Safety features of individual products! pieces of
equipment.
Training covers the safe handling of hazardous
material[sj the detainee are likely to encounter
in their work.
The Cook Foreman documents all training in indlvidual
detainee detention files.
Detainees at CDFs are paid in accordance with the
''Voluntary Work Program" standard. Detainee workers
at IGSAs are subject to local and State rules and
reflulations reQarding detainee pay.

•

N_
c-. _

---.-

t8J

Remarks

-----------

No knives in facility.

•

12
G·324A Detention inspection Fonn Worksheet for IGSAs . Rev: 01104/05

•

FOOD SERVICE

Policy: Every facility will provide detainees in Its care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.
Components
Detainees are served at least two hot meals every day.
No more than 14 hours elapse between the last meal
served and the first meal of the following day.
For cafeteria style operations, a transparent "sneeze
guard" protects both the serving line and salad bar line.
The facility has a standard 35-day menu cycle. IGSAs
use a 35 day or similar system for rotating meals.
The FSA or facility considers the ethnic diversity of the
facility's detainee population when developing menu
cycles. (Provide examples)
A registered dietitian conducts a complete nutritional
analysis of every master-cycle menu planned.
The FSA has established procedures to ensure that
items on the master-cycle menu are prepared and
presented accordinQ to approved recipes.
The Cook Foreman has the authority to change menu
items if necessary.
• If yes, documenting each substitution, along
with its justification
• With copy to FSA
All staff and volunteers know and adhere to written
"food preparation" procedures.
Detainees whose religious beliefs require the
adherence to particular religious dietary laws are
referred to the Chaplain or FSA.
A common-fare menu available to detainees whose
dietary requirements cannot be met on the main.
• Changes to the planned common-fare menu
can be made at the facility level.
• Hot entrees are offered three times a week.
• The common-fare menus satisfy nutritional
recommended daily allowances (RDAs).
Staff routinely provides hot water for instant
beverages and foods.
Common-fare meals are served with:
0
Disposable plates and utensils.
0
Reusable plates and utensils.
0
Staff use separate cutting boards, knives,
spoons, scoops, etc., to prepare the commonfare diet items.
A supervisor at the command level must approve a
detainee's removal from the Common-Fare Program.

•

The Warden, in conjunction with the chaplain and/or
local religious leaders, provide the FSA a schedule of
the ceremonial meals for the following calendar year.

13
G-324A Detention inspection Fonn Worksheet for IGSAs - Rev: 0\/04105

Remarks

On a 4 week cycle.

FOOD SERVICE
Policy: Every facility will provide detainees in its care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.

program accommodates detainees
abstaining from particular foods or fasting for religious
purposes at prescribed times of the year.
•
Muslims fasting during Ramadan receive their
meals after sundown.
• Jews who observe Passover but do not
participate in the Common-Fare Program
receive the same Kosher-for- Passover meals
as those who do participate.
•
Main-line offerings include one meatless meal
(lunch or dinner) on Ash Wednesday and
Lent.

•
•
•

[8]

on:
Personal cleanliness and hygiene;
Sanitary techniques for preparing, storing, and
serving food, and;
The sanitary operation, care, and maintenance

Standard operating procedures
inspections of all food service areas, including dining
and food-preparation areas and equipment.
• who conducts the

14
G-324A Detention inspection FOlm Worl<,heet for [GSA, - Rev: 01104/05

Continuous clean

•

FOOD SERVICE

. Policy: Every facility will provide detainees in its care with nutritious and appetizing meals, prepared in
. accordance with the highest sanitary standards.

I YIN I

Components

I2!:J Acceptable

Deficient

At-Risk

Remarks

D Repeat Deficiency

15
G·324A Detention Inspection Form Worksheet for IGSAs . Rev: 01104/05

•

FUNDS AND PERSONAL PROPERTY

Policy:
All facilities will implement procedures to control and safeguard detainees' personal property.
Procedures will provide for the secure storage of funds, valuables, baggage and other personal property; the
documentation and receipting of surrendered property; and the initial and regularly scheduled inventorying of all
funds, valuables, and other property.

o Standard NA:

(IGSA ONLY) Check this box if all ICE detainee Funds, Valuables and Property are
handled only by the ICE Field Office or Sub·Office in control of the detainee case.

Components
Detainee funds and valuables are properly separated
and stored away. Detainee funds and valuables are
accessible to designated supervisor(s) only.
Detainees' large valuables are secured in a location
accessible to deSignated supervisor(s) or processing
staff only.
Staff itemizes the baggage and personal property of
arriving detainees, including funds and valuables). For
IGSAs and CDFs, using a personal property inventory
form that meets the ICE standard?
Staff forwards an arriving detainee's medicine to the
medical staff.
Staff searches arriving detainees and their personal
property for contraband.
There is a written policy for returning forgotten property
to detainees and staff follows procedures?
Property discrepancies are imrnediately reported to the
COEO or Chief of Security.
Staff follows written procedures when returning property
to detainees.
CDFIIGSA facility procedures for handling detainee
property claims are similar with the ICE standard.
The facility attempts to notify an out-processed detainee
that he/she left property in the facility.
• By sending written notice to the detainee's last
known address;
• Via certified mail;
• The notice state that the detainee has 30 days
in which to claim the property, after which it will
be considered abandoned.
The facility disposes of abandoned property in
accordance with written procedures.
• If a CDFIIGSA facility, written procedure
requires the prompt forwarding of abandoned
prooertv to ICE.
~ Acceptable

o Deficient

Yes

At·Risk

Remarks: (Record significant fact , observations, other sources used, etc.)

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

I .1'1&r,
16
G-324A Detention inspection

FOlID

Worksheet for IGSAs - Rev: 01/04/05

Remarks

o Repeat Finding

•

GROUP LEGAL RIGHTS PRESENTATIONS

Policy: Facilities housing ICE detainees shall permit authorized persons to make presentations to groups of
detainees for tAe purpose of informing them of U.S. immigration law and procedures, consistent wlth the
security and orderly operation of each faCility. ICE encourages such presentations, which instruct detainees
about the immigration system and their rights and options within it.

C8l Check here if No Group Presentations were conducted within the past 12 months.

__ __ __
__
Components

Acceptable overall and continue on with next portion of worksheet.
-.....
....
...
..
....•. -_...._ - - ..- - .....: - . _.. : - : - The Field Office is responsive to requests by attorneys
and accredited representatives for group presentations.
Upon receipt of concurrence by the Field Office Director,
the facility or authorized ICE Field Office ensures proper
notification to attorneys or accredited representatives in
a timely manner.
The facility follows policy and procedure when rejecting
or requesting modifications to objectionable material
provided or presented by the attorney or accredited
representative.
Posters announcing presentations appear in common
areas at least 48 hours in advance and sign-up sheets
are available and accessible.
Documentation is submitted and maintained when any
detainee is denied permission to attend a presentation
and the reason(s) for the denial.
When the number of detainees allowed to attend a
presentation is limited, the facility allows a sufficient
number of presentations so that all detainees signed up
may attend.
Detainees in segregation, unable to attend for security
reasons may request separate sessions with presenters.
Such requests are documented.
Interpreters are admitted when necessary to assist
attorneys and other legal representatives.
Presenters are afforded a minimum of one hour to make
the presentation and to conduct a question-and-answer
session.
Staff permits presenters to distribute ICE-approved
materials.
The facility permits presenters to meet with small groups
of detainees to discuss their cases after the group
presentation. ICE or authorized detention staff are
present but do not monitor conversations with legal
providers.
Group presenters who have had their privileges
suspended are notified in writing by the Field Office
Director or disignee; and the reasons for suspension are
documented. The Headquarters Office for Detention
and Removal, Field Operations and Detention
management Division is notified when a group or
individual is suspended from making presentations.
The facility plays ICE-approved videotaped
presentations on legal rights, at regular opportunities at
the request of outside organizations.

Yes

-NA

17
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Mark Standard as

"---'.'--_."---' - -

Remarks

Pol'icy: Facilities housing ICE detainees shall permit authorized persons to make presentations to groups of
detainees for the purpose of informing them of U.S. immigration law and procedures, consistent with the
security and orderly operation of each facility. ICE encourages such presentations, which instruct detainees
about the immigration system and their rights and options within it.

[8l Check here if No Group Presentations were conducted within the past 12 months. Mark Standard as
Acceptable overall and continue on with next portion of worksheet.
A copy of the Group Legal Rights Presentation policy,
including attachments, is available to detainees upon

[8l Acceptable

o Deficient

OAt-Risk

Remarks: (Record significant facts, obseNations, other sources used, etc.)
(b)(6), (b)(7)c

18
G·324A Detention Inspection Fonn WOlxsheet for IGSAs - Rev: 01/04/05

o Repeat Finding

.-- .....-------------

•

DETAiN'EE GRIEVANCE PROCEDURES-

•

........

... -..~

Policy: Every facility will develop and implement standard operating procedures (SOPs) for addressing
detainee grievances in timely fashion. Each step in the process will occur within the prescribed time frame.
Among other things , a grievance will be processed " investigated and decided (subjectloappeal) in accordance
with the SOPs; a grievance committee will convene as provided in the SOPs. Standard procedure will include
: providing the detainee with a written response to any formal grievance, which will include the basis for the
. decision. The facility will also establish standard procedures for handling emergency grievances. All
grievances will receive supervisory review. Reprisal against the filer of a grievance will not be tolerated.

Components
Written procedures provide for the informal resolution
of oral grievances (Not mandatory).
• If yes, the detainee has up to five days within
which to make his/her concem known to a
member of the staff.
Detainees have access to the grievance committee (or
equivalent in IGSA), using formal procedures.
• Detainees may seek help from other detainees
or facility staff when preparing a grievance.
• Illiterate, disabled, or non-English-speaking
detainees receive special assistance when
necessary.
Every member of the staff knows how to identify
emergency grievances, including the procedures for
expediting them.
There are documented or substantiated cases of staff
harassing, disciplining, penalizing, or otherwise
retaliating against a detainee who lodges a complaint.
• Ifyes , explain.
Procedures include maintaining a Detainee Grievance
Log.
If not, an altemative acceptable record keeping
system is maintained.
• "Nuisance complains" are identified in the
records.
For quality control purposes, staff documents
nuisance complaints received but not filed.
Staff is required to forward any grievance that includes
officer misconduct to a higher official or, in a CDFIIGSA
facility, to ICE.

Remarks

•

I:8J Acceptable

D Deficient

At-Risk

19
G·324A Detention ~lSpection FOffil Worksheet for rGSAs - Rev: 01/04/05

D Repeat Finding

•

ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS

•

Policy: ICE requires that all facilities housing ICE detainees provide clean clothing, bedding, linens and towels
to every ICE detainee upon arrival. Further, facilities shall provide ICE detainees with regular exchanges of
clothing, linens, and towels for as long as they remain in detention.
:

Components
....
The facility has a policy and procedure for the regular
issuance and exchange of clothing, bedding, linens and
towels.
The supply of these items exceeds the
minimum required for the number of detainees.
All new detainees are issued clean, temperatureappropriate, presentable clothing during in-processing.
Detainees receive
One uniform shirt and one pair of uniform pants
or one jumpsuit.
• One pair of socks.
• One pair of underwear (Daily change).
• One pair of facility-issued footwear.
Additional clothing is available for changing weather
conditions or is seasonallv appropriate.
New detainees are issued clean bedding, linens and
towel. They receive at a minimum:
• One mattress
• One blanket
• Two sheets
• One pillowcase
• One towel
• Additional blankets are issued based on local
weather conditions.
Detainees assigned to special work areas are clothed in
accordance with the requirements of the job.
Detainees are provided clean clothing, linen and towels.
• Socks and undergarments - exchanged daily.
Outer garments - twice weekly.
• Sheets - weekly.
• Towels - weekly.
Pillowcases - weekly.
Food service detainee volunteer workers permitted to
exchanqe outer qarments daily.
Volunteer detainee workers are permitted to exchanges
of outer qarments more frequently.

Yes

·~c---··-----··

•

...-

NA
-'"

I2l

Remarks

. _ - - - - _....-

•

I2l Acceptable

o Deficient

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

¢ . ·-a '.-''{

/.,.-?#

. d ..· . ()

20
G·324A Detention hlspection Form Worksheet for lGSAs . Rev: 01104/05

o Repeat Finding

•

MARRIAGE REQUESTS

Policy: All detainee marriage requests will receive case-by-case consideration from ICE management.
Components
The Field Office considers detainee marriage requests
on a case-by-case basis.
The Field Office Director reviews every marriage
request rejected by a Warden/OIC or IGSA. Rejections
are documented.
It is standard practice to require a written request for
permission to marry.
The written request includes a signed statement or
comparable documentation from the intended spouse,
confirming marital intent.
The Warden/OIC provides a written copy of his/her
decision to the detainee and his/her legal representative.
When permission is denied, the Warden/OIC states the
basis for his/her decision.
The Warden/OIC provides the detainee with a place and
time to make wedding arrangements.

o Deficient

~ Acceptable

[81

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

'j";, /0.-"1,
.......

21
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

Remarks

o Repeat Finding

•

NON-MEDICAL EMERGENCY ESCORTED TRIPS

Policy: The Immigration and Customs Enforcement (ICE) may provide detainees with staff-escorted trips into
the community for the purpose of visiting critically ill members of the detainee's immediate family, or for
attending funerals.

D Standard NA: Check this box if all ICE Non-Medical Emergency Escorted Trips are handled only by
the ICE Field Office or Sub-Office in control of the detainee case.
Components
The Field Office Director considers and approves, on a
case-by-case basis, trips to immediate family member's:
• Funeral
• Deathbed
The facility recognizes mother, father, brother, sister,
spouse, child, stepparent, and foster parent as
"immediate family".
The IGSA facility notifies ICE of all detainee requests for
non-medical escorts.
The detainee's Deportation Officer reviews the file
before forwarding a detainee's request, with
recommendation, to the approving official. Each
recommendation addresses the individual's suitability for
travel, e.Q., the kind of supervision required.
Each escort includes at least two officers.
Escorting officers report unexpected situations to the
originating facility as a matter of procedure and the
ranking supervisor on duty has the authority to issue
instructions for comj)letion of the trip.
Escorting officers have the discretion to; Increase or
decrease minimum restraints in accordance with written
procedures and classification level of the detainee.
Escort officers do not accept gifts/gratuities from a
detainee, detainee's relative or friend for anYJeason.
Escort officers ensure that detainees:
• Conduct themselves in a manner that does not bring
discredit to the ICE.
• Do not violate federal, state, or local laws.
• Do not purchase, possess, use, consume, or
administer narcotics, other drugs, or intoxicants.
• Make no unauthorized phone calls.
• Know they are subject to search, urinalysis,
breathalyzer, or comparable test upon return.
Standard procedure requires the immediate return to the
facility of any detainee who violates trip rules.
~ Acceptable

Deficient

Yes

IZJ

At-Risk

Remarks: (Record significant facts, obse,rvations, other sources used, etc.)
(b )(6), (b)(7)c

f/l.'fl , " J

.<.•. ,

11--JfJ.l-l I

22
G·324A Detention inspection Fonn Worksheet for IGSAs . Rev: 01104/05

Remarks

Repeat Finding

•

RECREATION

•

Policy: It is ICE policy to provide access to recreational programs and activities to all ICE detainees, to the
extent possible, under conditions of security and supervision that protect their safety and welfare.
Components
N
NA
Remarks
Y
[]
The facUityhas a recreation program and facility.
[J
~
A recreational specialist (for facUities with more than 350
detainees) taUors the program activities and offerings to
D
D
~
the detainee population.
Regular maintenance keeps recreational facilities and
~
D
D
equipment in good condition.
The recreational specialist or trained equivalent
D
~
D
supervises detainee recreation workers.
The recreational specialist or trainee equivalent
oversees recreation programs for Special Management
D
D
~
Unit and special-needs detainees.
Dayrooms offer sedentary activities, e.g., board games,
D
D
~
cards, television.
Outside activities are restricted to limited-contact sports.
~
D
U
Each detainee has the opportunity to participate in daUy
~
D
D
recreation.
Detainees have access to recreation activities outside
the housing units for at least one hour daUy, 5 days a
~
D
D
week.
Staff checks all items for damage and condition when
D
D
~
equipment is returned.
Staff conducts searches of recreation areas before and
D
~
D
after use.
All recreation areas under constant staff supervision.
~
D
LJ
Supervising staff is equipped with radios.
[J
D
~
The facility provides detainees in the SMU at least one
hour of outdoor recreation time daUy, five times per
D
D
~
week.
Detainees in disciplinary/administrative segregation
receive a written explanation when a panel revokes
D
~
D
his/her recreation privileges.
Special programs or religious activities are available to
D
D
~
detainees.
Volunteers are required to sign a waiver of liability
before entering a secure portion of the facility where
~
D
D
detainees are present.
Visitors, relatives or friends are not allowed to serve as
D
D
~
volunteers.
[gJ If outdoor recreation is offered check this box. No further information is required when outdoor
recreation is offered.
If the facility has no outside recreation, are detainees
considered for transfer after six months?
D
D
D
• If yes, written procedures ensure timely review
of all eligible detainees.
Case officers make written transfer recommendations
D
D
D
about every six-month detainee to the OIC.
The OIC documents all detainee-transfer decisions,
D
D
D
whether yes or no.
The detainee's written decision for or against an offered
D
D
D
transfer documented in his/her A-file.

23
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

RECREATION
Policy: It is ICE policy to provide access to recreational programs and activities to all ICE detainees, to the
extent possible, under conditions of security and supervision that protect their safety and welfare.

is notified of the

o Acceptable

o Deficient

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

. ,'''l~''
i_:J6~"'?«

24
G·324A Detention Inspection FOim Worksheet for IGSAs • Rev: 01/04/05

o Repeat Finding

•

RELIGIOUS PRACTICES

Policy: Facilities will provide ICE detainees of all faiths with reasonable and equitable opportunities to
participate in the practices of their faith, limited only by the constraints of safety, security, the orderly operations
of the facility and budgetary considerations.
Components
Detainees are allowed to engage in religious services.
Space is available for detainees to conduct religious
services.
The facility allows detainees to observe the major "holy
days" of their religious faith.
• List any exceptions.
The facility accommodates recognized holy-day
observances by:
• Providing special meals, consistent with dietary
restrictions.
• Honoring fasting requirements.
• Facilitating religious services.
• Allowing activity restrictions.
Each detainee is allowed religious items in his/her
immediate~ossession.
Volunteer's credentials are checked and verified before
allowing participation in detainee programs.
Members of faiths not represented by clergy conduct
may request to present their own services within security
allowances.
Detainees in the Special Management Unit to participate
in religious practices unless otherwise documented for
the safety and security of the facility.

[gJ Acceptable

D Deficient

D
D

I:8l

At·Risk

D Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

J /"1
?/ (
,..l·- !(~

Remarks

-r:)

25
G-324A Detention Inspection FOlm Worksheet for IGSAs - Rev: 01/04/05

•

DETAINEE TELEPHON'E ACCESS

Policy: All facilities housing ICE detainees will permit detainees' reasonable and equitable access to
telephones.
Components

C8J

C8J
C8J

0
[J

0
0

C8J

Telephones are inspected regularly by facility staff to
ensure that they are in good working order.

C8J

The facility administration promptly reports out-of-order
telephones to the facility's telephone service provider.

C8J

The facility administration monitors repair progress and
take appropriate measures to ensure that the required
repairs are begun and completed timely.

C8J

C8J
C8J

0
0

C8J

C8J
C8J

0
0

C8J

Detainees are allowed access to telephones during
established facility waking hours.
Upon admittance, detainees are made aware of the
facility's telephone access Qolicy.
Access rules are posted in housing units.
The facility makes a reasonable effort to provide key
information to detainees in languages spoken by any
significant portion of the facility's population.
Telephones are provided at a minimum ratio of one
telephone per 25 detainees in the facility population.

Detainees are afforded a reasonable degree of privacy
for legal phone calls.
A procedure exists to assist a detainee who is having
troubleplacing a confidential call.
The facility provides the detainees with the ability to
make non-collect (special access) calls.
Special Access calls are at no charge to the detainees.
In facilities unable to fully meet this requirement initially
because of limitations of its telephone service, the ICE
makes alternate arrangements to provide required
access within 24 hours of a request by a detainee.
No restrictions are placed on detainees attempting to
contact attorneys and legal service providers who are
on the approved "Free Legal Services Lisf'.
Special arrangements are made to allow detainees to
speak by telephone with an immediate family member
detained in another Facility.
Any telephone restrictions are documented.
The facility has a system for taking and delivering
emergency detainee telephone messages.
Emergency phone call messages are immediately
given to detainees.
Detainees are allowed to return emergency phone calls
as soon as possible.
Detainees in disciplinary segregation are allowed
phone calls relating to the detainee's immigration case
or other legal matters, including consultation calls.
Detainees in disciplinary segregation are allowed
phone calls to consular/embassy officials.
Detainees in disciplinary segregation are allowed
phone calls for family emergencies.

26
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

Remarks

•

DETAINEE TELEPHONE ACCESS

Policy: All facilities housing ICE detainees will permit detainees' reasonable and equitable access to
telephones.
Components
Detainees in administrative segregation and protective
custody afforded the same telephoning privileges as
those in Qeneral population.
When detainee phone calls are monitored, notification
is posted by detainee telephones that phone calls
made by the detainees may be monitored. Special
Access calls are not monitored.

rgj Acceptable

o Deficient

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

27
G-324A Detention Inspection FOIm Worksheet for IGSAs - Rev: 01/04/05

Remarks

o Repeat Finding

•

VISITATION

Policy: ICE shall permit detainees to visit with family, friends, legal representatives, special interest groups and
the news media.

t:8l

The visitation schedule and rules are available to the
public.

t:8l

The hours for all categories of visitation are posted in
the visitation waiting area.

t:8l

0
0
0
0
D
0

Components
There is a written visitation schedule and hours for
general visitation.
The visitation hours tailored to the detainee population
and the demand for visitation.

A written copy of the rules regulating visitation and the
hours of visitation is available to visitors.

A visitor dress code is available to the public.

t:8l
t:8l
t:8l
t:8l

Visitors are searched and identified according to
standard requirements.

t:8l

0
D
D
D
D

The requirement on visitation by minors is complied
with.

t:8l

At facilities where there is no provision for visits by
minors, the ICE arranges for visits by children and
stepchildren, on request, within the first 30 days.

t:8l

t:8l
t:8l

0
0

On regular business days legal visitation hours provide
for a minimum of eight (8) hours per day and a
minimum of four hours per day on weekends and
holidays.

t:8l

On regular business days, detainees are given the
option of continuing a meeting with a legal
representative through a scheduled meal.

t:8l

A general visitation log is maintained.
The detainees are permitted to retain personal property
item specified in the standard.

After that time, on request, ICE considers a transfer,
when possible, to a facility that will allow minor
visitation. At a minimum, monthly visits are allowed.
Detainees in special housing afforded visitation.
Legal visitation is available seven (7) days a week,
including holidays.

Private consultation rooms are available for attomey
meetings. There is a mechanism for the detainee and
his/her representative to exchange documents.
There are written procedures goveming detainee
searches.
When strip searches are required after every contact
visit with a legal representative, the facility provides an
option for non-contact visits with legal representatives.
Prior to each visit, legal service providers and
assistants are identified per the standard.
The current list of pro bono legal organizations is
posted in the detainee housing areas and other
appropriate areas.

28
G·324A Detention Inspection Form Worksheet for IGSAs . Rev: 01/04/05

Remarks

•

VISITATION

Policy: ICE shall permit detainees to visit with family, friends, legal representatives, special interest groups and
the news media.
The decision to permit or deny a tour is not delegated
below the level of Field Office Director.

IZI

Provisions for NGO visitation as stated in the Detention
Standards are complied with.

IZI

Law enforcement officials, requesting to visit with a
detainee, are referred to the ICE Field Office for
approval.

IZI

Former detainees or aliens in proceedings, requesting
to visit with a detainee, are referred to the OIC or ICE
Field Office.

IZI

Procedures are in place, consistent with the detention
standard, for examinations by independent medical
service providers and experts.

IZI

D Deficient

~ Acceptable

_"'nnlTl'''R/~l

At-Risk

facts, observations, other sources used, etc.)

29
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

D Repeat Finding

•

VOLUNTARY WORK PROGRAM

Policy: In every facility offering a voluntary work program, ICE detainees will have the opportunity to work and
earn money by parUcipaUng. While not legally required, ICE affords detainee workers basic Occupational
Safety and Health Administration (OSHA) protections.

(gJ Check here if ICE detainees are not authorized to work at the IGSA facility. Mark NA on Form G·
324A, page 3 and move to next section.
Components
Does the facility have a voluntary work program?
• Do ICE detainees participate?
Detainee housekeeping meets neatness and cleanliness
standards.
Detainees have the opportunity to participate in special
details, however, are never allowed to work outside the
secure perimeter.
Written procedures govern selection of detainees for the
Voluntary Work Program.
Where possible, physically and mentally challenged
detainees participate in the program.
The facility complies with work-hour requirements for
detainees, not exceeding:
• Eight hours a day and Forty hours a week.
Detainee volunteers generally work according to fixed
schedule.
If a detainee is removed from a work detail, staff places
the written justification for the action in the detainee's
detention file.
Staff, in accordance with written procedure, ensures that
detainee volunteers understand their responsibilities as
workers before they join the work program.
The voluntary work program meets:
• OSHA, NFPA, ACA standards
Medical staff screens and formally certifies detainee food
service volunteers.
• Before the assignment begins
• As a matter of written procedure
Detainees receive safety equipment! training sufficient for
the assignment
Proper procedure is followed when an ICE detainee is
injured on the job.

(gJ Acceptable

Deficient

At·RisK

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

:J-7 1

30
G-324A Detention Inspection FOIm Worksheet for !GSAs - Rev: 01104/05

Remarks

Repeat Finding

•

Section II
Health Services
Standards

31
G-324A Detention Inspection FOlm Worksheet for IGSAs - Rev: 01/04105

•

HUNGER STRIKES

Policy: All facilities will follow standard guidelines for the medical and administrative management of ICE
detainees engaging in hunger strikes. By monitoring of the health and welfare of the individual detainees,
facilities will strive to sustain their lives .
.. - - - .. - - - . ---'_._- .. - _ . - _ .....__...
.. __ .... _
.. . .. _---_ .. _ - . - ...
Components
Y
Remarks
N "NA-rWhen a detainee has refused food for 72 hours, it is
standard practice for staff to refer him/her to the medical
~
0
0
department.

CDFs and IGSAs immediately report a hunger strike to
the ICE.

The facility has established procedures to ensure staff
respond immediately to a hunger strike.

Policy and procedure require that staff isolate a hungerstriking detainee from other detainees.
• If y_es, in an observation room?
Medical personnel are authorized to place a detainee in
the Special Management Unit or a locked hospital room.

Medical staff records the weight and vital signs of a
hunger-striking detainee at least once every 24 hours.

The OIC of the facility obtains a hunger striker's consent
before medical treatment.

A signed Refusal of Treatment form is required of every
detainee who rejects medical evaluation or treatment.

During a hunger strike, staff documents and provides
the hunger-striking detainee three meals a day.

Staff maintains the hunger striker's supply of drinking
water/other beverages.

During a hunger strike, staff removes all food items from
the hunger striker's living area.

Staff is directed to record the hunger striker's fluid intake
and food consumption, does staff always use Hunger
Strike Monitoring Form 1-839 or similar IGSA form.

The medical staff has written procedures for treating
hunger strikers.

Staff documents all treatment attempts, including
attempts to persuade hunger striker of medical risks.

Staff has received training in identification of hunger
strikes. Medical staff receives early training in hungerstrike evaluation and treatment. Staff remain current in
evaluation and treatment techniques.

J:8l Acceptable

o Deficient

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

32
G-324A Detention Inspection Fonn Worksheet for [GSAs • Rev: 01104/05

o Repeat Finding

•

ACCESS TO MEDICAL CARE

Policy: Every facility will establish and maintain an accredited/accreditation-worthy health program for the
general well-being of ICE detainees.
Components

Facilities operate a health care facility in compliance
with State and Local laws and Quidelines.
The facility's in-processing procedures of arriving
detainees include medical screening.
All detainees have access to and receive medical care.
The facility has access to a PHS/DIHS Managed Health
Care Coordinator.
The medical staff is large enough to provide, examine,
and treat the facili~s detainee population.
The facility has sufficient space and equipment to afford
each detainee privacy when receiving health care.
The medical facility has its own restricted-access area.
The restricted access area is located within the confines
of the secure perimeter.
The medical facility entrance includes a holding/waiting
room.
The medical facility's holding/waiting room under the
direct supervision of custodial staff.
Detainees in the holding/waiting room
have access to a toilet and a drinking fountain.
Medical records are kept apart from other files. They
are:
• Secured in a locked area within the medic:al
unit.
• With physical access restricted to authorized
medical staff.
• Procedurally, no copies made and placed in
detainee files.
Pharmaceuticals are stored in a secure area.
Medical screening includes a Tuberculosis (TB) test.
• Every arriving detainee receives a TB test.
• During the admission process.
• Detainee's TB-screening does not occur more
than one business'day after his/her arrival at the
facility.
• Detainees not screened are housed separate
from the general population.
All detainees receive a mental-health screening upon
arrival. It is conducted:
• Bya health care provider or specially trained
officer;
• Before a detainee's assignment to a housing
unit.
The facility health care provider promptly reviews all 1794s (or equivalent) to identify detainees needing
medical attention.
The health care provider physically examines/assesses
arriving detainees within 14 days of admission/arrival at
the facility.
Detainees in the Special Management Unit have access
to health care services.

0
0
0

Remarks

mental health question
asked at intake.

33
G-324A Detention Inspection Fonn Worksheet for IGSAs . Rev: 01104/05

ACCESS TO MEDICAL CARE

Policy: Every facility will establish and maintain an accredited/accreditation-worthy health program for the
general well-being of ICE detainees.
staff provides detainees with health- services (sick call)
request slips daily, upon request.
•
Request slips are available in the languages
other than English, including every language
spoken by a sizeable number of the facility's
detainee population.
• Service-request slips are delivered in a timely
fashion to the health care
The facility has a written plan for
delivery
emergency health care when no medical personnel are
on duty at the facility, or when immediate outside

~ Acceptable

D Deficient

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

34
G-324A Detention Inspection Fmm Worksheet for IGSAs - Rev: 01104105

D Repeat Finding

•

------l

------- - - - - - -----;UI~I~; PREVE~T;ON AND INTERVEN;I-;;;-----

Policy: All detention staff working with ICE detainees will be trained to recognize suicide-risk indicators. Staff
will handle potentially suicidal individuals with sensitivity, supervision, and referrals. A clinically suicidal detainee
will receive preventive supervision and treatment.
Components
--.Every new staff member receives suicide-prevention
training. Suicide-prevention training occurs during the
employee orientation program.
Training prepares staff to:
• Recognize potentially suicidal behavior;
• Refer potentially suicidal detainees, following
facility procedures;
• Understand and apply suicide-prevention
techniques.
A health-care provider or specially trained officer
screens all detainees for suicide potential as part of the
admission process.
• Screening does not occur later than one working
day after the detainee's arrival.
Written procedures cover when and how to refer at-risk
detainees to medical staff and procedures are followed.
The facility has a designated isolation room for
evaluation and treatment.
The designated isolation room does not contain any
structures or smaller items that could be used in a
suicide attempt.
Medical staff has approved the room for thisJ>..urQose.
Staff observes and documents the status of a suicidewatch detainee at least once eveJY 15 minutes.

,-;::---- ._.. _ - - _ . _ - .

~ Acceptable

o Deficient

_.- Y

D
D

-'-

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

l'
./'.-.
'j"" '6 '"
, t:....·~ :) ~

Remarks

35
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

o Repeat Finding

I
I

•

- - - . - - - - - - - . - -..- .. - ....- . - - - - c - -

TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATH

Policy All facilities housing ICE detainees shall have policies and procedures addressing the issues of terminal
, illness or injury, medical advanced directives, and detainee death, to include the procedures to ensure proper
notification is provided to ICE officials, family members and other interested parties in the event of a detainee
becoming terminally ill or injured or death of a detainee occurs. In addition, the policy will cover procedures to
be taken if the death of a detainee occurs while in transit.

I:8J

Check this box if the facility does not accept ICE detainees who are severely or terminally ill.
Indicate NA In the appropriate box forthi S porfon
of the worksheet ALWAYS c om plete all r ef erences
I
to detainee death and related notifications.
Components
Y
NA
N
Remarks
_.._ .._......._... ..... _--_._ ..
..... _._ ..
...... __ .. --"--Detainees, who are chronically or terminally ill, are
0
0
0
transferred to an appropriate offsite medical facility.
The facility or appropriate ICE office promptly notifies
the next of kin of the detainee's: medical condition.
0
0
0
• The detainee's location.
The
limitations
placed
on
visiting.
•
There are guidelines addressing State Advanced
Directive Form for Implementing Living Wills and
Advanced Directives.
• The guidelines include instructions for detainees 0
0
0
who wish to have a living will other than the
generic form the DIHS provides or who wish to
appoint another to make advance decisions for
him or her.
The guidelines provide the detainee the opportunity to
0
0
0
have a private attorney prepare the documents.
There is a policy addressing "Do Not Resuscitate
0
0
0
Orders"
_.",

Detainees with a "Do Not Resuscitate" order in the
medical record receive maximal therapeutic efforts short
of resuscitation?
The facility notifies the DIHS Medical Director and
Headquarters' Legal Counsel of the name and basic
circumstances of any detainee with a "Do Not
Resuscitate" order in the medical record. In the case of
IGSAs, this notification is made through the local ICE
representative.
The facility has written procedures to address the issues
of oraan donation by detainees.
The facility has written procedures to notify ICE officials,
deceased family members and consulates, when a
detainee dies while in Service.
The facility has a policy and procedure to address the
death of a detainee while in transport.
At all ICE locations the detainee's remains disposed of
in accordance with the provisions detailed in this
standard.
In the event that neither family nor conSUlate claims the
remains, the Field Office schedules an indigent's burial,
consistent with local procedures.
If the detainee's is a U.S. military veteran is the
Department of Veterans Affairs notified.
An original or certified copy of a detainee's death
certificate is placed in the subjecfs a ..file.

•

36
G-324A Detention Inspection Form Worksheet for IGSAs .. Rev: 01104105

•

TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATH

~',::l

, Policy All facilities housing ICE detainees shall have policies and procedures addressing the issues of terminal
, illness or injury, medical advanced directives, and detainee death, to include the procedures to ensure proper
: notification is provided to ICE officials, family members and other interested parties in the event of a detainee
becoming terminally ill or injured or death of a detainee occurs. In addition, the policy will cover procedures to
be taken if the death of a detainee occurs while in transit.

~ Check this box i:f the facility does not accept ICE detainees who are severely or terminally ill. i
Indicate NA in the appropriate box for this portion ofthe worksheet. ALWAYS complete all references
to detainee death and related notifications.
NA
N
Components
Remarks
Y

The facility follows established policy and procedures
describing when to contact the local coroner regarding
such issues as
Performance of an autopsy.
Who will perform the autopsy.
• Obtaining State approved death certificates.
Local transportation of the body.
ICE staff follow established procedures to properly close
the case of a deceased detainee.

•
•

•

o Acceptable

D Deficient

At-Risk

:·U ...
: . . . . . . . . cant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c
i'1\

~?~ r.", ','

-/." , r tl

41
h

37
G-324A Detention Inspection FOlm Worksheet for IGSAs - Rev: 01/04/05

o Repeat Finding

•

Section III

Security and Control

38
G-324A Detention inspection Fonn Worksheet for !GSAs - Rev: 01/04/05

•

CONTRABAND

Policy: All detention facilities will ensure the proper handling and disposal of all contraband. Documentation of
contraband destruction is required.
Components
The facility follows a written procedure for handling
illegal contraband. Staff inventories, holds, and reports
it when necessary to the proper authority for
action/possible seizure.
Contraband that is government property is retained as
evidence for potential disciplinary action or criminal
prosecution.
Staff returns property not needed as evidence to the
proper authority. Written procedures cover the return of
such property.
Altered property is destroyed following documentation
and using established procedures.
Before confiscating religiOUS items, the OIC or
designated investigator contacts a religious authority.
Staff follows written procedures when destroying hard
contraband that is illegal.
Hard contraband that is illegal (under criminal statutes)
may be retained and used for official use, e.g. training
purposes.
If yes, under specific circumstances and using
specified written procedures. Hard contraband is
secured when not in use.

J:8J Acceptable

o Deficient

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

,; I.. J
~1

39
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

Remarks

o Repeat Finding

•

DETENTION FILES

Policy: Every facility will create a detention file for every ICE detainee booked into the facility, excluding only
detainees scheduled to depart within 24 hours. The detention file will contain copies and, in some cases, the
original of specified documents concerning the detainee's stay in the facility: classification sheet, medical
questionnaire, property inventory sheet, disciplinary documents, etc.

Components

A detention file is created for every new arrival whose
stay will exceed 24 hours.
The detainee detention file contains either originals or
copies of documentation and forms generated during
the admissions process.
The detainee's detention file also contains documents
generated during the detainee's custody.
• Special requests
Any G-589s and/or 1-77s closed-out during the
detainee's stay
• Disciplinary forms/Segregation forms
• Grievances, complaints, and the disposition(s)
of same
The detention files are located and maintained in a
secured area. If not the cabinets are lockable and
distribution of the keys is limited to supervisors.
The detention file remains active during the detainee's
stay. When the detainee is released from the facility,
staff adds copies of completed release documents, the
original closed-out receipts for property and valuables,
the original 1-385 or equivalent and other
documentation.
The officer closing the detention file makes a notation
that the file is complete and ready to be archived.
Staff makes copies and sends documents from the file
when appropriately requested by supervisory personnel
at the receiving facility or office.

[8J

•

Appropriate staff has access to the detention files and
other departmental requests are accommodated by
making a request for the file. Each file is properly
logged out and in by a representative of the responsible
department.

~ Acceptable

o Deficient

At-Risk

40
G-324A Detention Inspection Fonn Worksheet for !GSAs - Rev: 01/04/05

Remarks

o Repeat Finding

•

-------. --...- - -..- - - -..--.--- ··-i:j-IS-CI-PLiN-AR-y-PO-L-IC-y---····---- ' - - - ' - " ' - -.. - - ,

Policy: All facilities housing ICE detainees are authorized to impose discipline on detainees whose behavior is
not in compliance with facility rules and regulations.
Components
Y
N
NA
Remarks
- - _ . .. _ - - - - _ .. - - - . - - - - ---Thefacility has written disciplinary system usin-g--'"
0
~
0
progressive levels of reviews and appeals.
The facility rules state that disciplinary action shall not
~
0
0
be capricious or retaliatory.
Written rules prohibit staff from imposing or permitting
the following sanctions:
'
• corporal punishment
• deviations from normal food service
• clothing deprivation
~
0
0
• bedding deprivation
• denial of personal hygiene items
• loss of correspondence privileges
• deprivation of physical exercise
The rules of conduct, sanctions, and procedures for
violations are defined in writing and communicated to all
~
0
0
detainees verbally and in writing.
The following items are conspicuously posted in
Spanish and English or other dominate languages used
in the facility:
0
~
0
• Rights and Responsibilities
• Prohibited Acts
• Disciplinary Severity Scale
• Sanctions
When minor rule violations or prohibited acts occur,
~
0
0
informal resolutions are encouraQed.
Incident reports and Notice of Charges are promptly
0
0
~
forwarded to the designated supervisor.
Incident reports are investigated within 24 hours of the
incident. The Unit Disciplinary Committee (UDC) or
0
~
0
equivalent does not convene before investigations end.
An intermediate disciplinary process is used to
0
~
0
adjudicate minor infractions.
A disciplinary panel (or equivalent in IGSAs) adjudicates
infractions. The panel:
• Conducts hearings on all charges and
allegations referred by the UDC
• Considers written reports, statements, physical
evidence, and oral testimony
~
0
0
• Hears pleadings by detainee and staff
representative
• Bases its findings on the preponderance of
evidence
• Imposes only authorized sanctions
A staff representative is available if requested for a
0
0
~
detainee facing a disciplinary hearing
The facility permits hearing postponements or
continuances when conditions warrant such a
0
0
~
continuance. Reasons for are documented.

-a

41
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

DISCIPLINARY POLICY

Policy: All facilities housing ICE detainees are authorized to impose discipline on detainees whose behavior is
not in
with
rules and
The duration
punishmen set by the OIC, as
recommended by the disciplinary panel does not exceed
established sanctions. The maximum time in disciplinary
segregation does not exceed 60 days for a single
offen
Written procedures govern the handling of confidentialinformant information. Standards include criteria for
I
evidence"
All forms relevant to the incident, investigation,
committee/panel reports, etc., are completed and
distributed as

[gJ Acceptable

o Deficient

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b )(7)c

42
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

o Repeat Finding

•

--------------------EMERGENCY (CONTINGENCY) PLANS---------------~I
Policy All facilities holding ICE detainees will respond to emergencies with a predetermined standardized plan to

,
!

minimize the harming of human life and the destruction of property It is recommended that spes and CDFs enter
into agreement. via Memorandum of Understanding (MOU), with federal, local and state agencies to assist in
times of emergency.
Components
Y
N
NA
Remarks
No Detainee or detainee groups exercise control or authority
over other detainees.
Detainees are protected from:
• Personal abuse
• Corporal punishment
• Personal injury
• Disease
• Property damage
• Harassment from other detainees
Staff are trained to identify signs of detainee unrest.
• What type of training and how often?
Staff effectively disseminates information on facility climate,
detainee attitudes, and moods to the Officer In Charge (OIC)
There is a designated person or persons responsible for
emergency plans and their implementation. Sufficient
time is allotted to the person or group for development and
implementation of the.QIans.
The plans address the following issues:
• Confidentiality
• Accountability (copies and storage locations)
• Annual review procedures and schedule
• Revisions
Contingency plans include a comprehensive general section
with procedures applicable to most emergency situations.
The facility has cooperative contingency plans with
applicable:
• Local law enforcement agencies
• State agencies
• Federal a.g_encies
All staff receive copies of Hostage Situation Management
policy and procedures.
Staff is trained to disregard instructions from hostages,
regardless of rank. Within 24 hours after release
hostages are screened for medical and psychological
effects.
Emergency plans include emergency medical treatment for
staff and detainees durinQ and after an incident.
The food service maintain at least 3-days' worth of
emergen9l.meals for staff and detainees.
Written plans locate shut-off valves and switches for all
utilities (water, gas, electric).

43
G-324A Detention Inspection FOlm Worksheet for !GSAs - Rev: 01/04/05

Orientation and annual
in-service training.

•

" ----------:::-EM=ERGEN:-:::C,-;-;Y,-;(C:::-O=-:cNT""I,-;-;N-:OG-=E:"7NC::cY;--,;):-:P:-:-L:-:A-:cN:-:::S--------=""---,

!
'I

Policy All facilities holding ICE detainees will respond to emergencies with a predetermined standardized plan to

I minimize the harming of human life and the destruction of property It is recommended that SPCs and CDFs enter I

I~~~oe:~fe:;:;~~~~~~~orandu:..~~ understan~~ng (M~~). with f~de~caIH~~d=te agenCie_s_t~ assis~ l~
Components
Written procedures cover:
Work/Food Strike
Disturbances
Escapes
• Bomb Threats
• Adverse Weather
• Internal Searches
• Facility Evacuation
• Detainee Transportation System Plan
• Internal Hostages
• Civil Disturbances

Remarks

•
•
•

IZI Acceptable

D Deficient

At-Risk

D Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

44
G-324A Detention inspection Form Worksheet for IGSAs - Rev: 01/04/05

•

ENVIRONMENTAL HEALTH AND SAFETY

•

Policy: Every facility will control flammable, toxic, and caustic materials through a hazardous materials
program. The program will include, among other things, the identification and labeling of hazardous materials in
accordance with applicable standards (e.g., National Fire Protection Association [NFPA]); identification of
incompatible materials, and safe-handling procedures
Components
--_..
._ .........
The facility has a system for storing, issuing, and
maintaining inventories of hazardous materials.

-...:-'

Constant inventories are maintained for all flammable,
toxic, and caustic substances used/stored in each
section of the facility.
The manufacturer's Material Safety Data Sheet (MSDS)
file is up-to-date for every hazardous substance used.
• The flies list all storage areas, and include a
plant diagram and legend.
The MSDSs and other information in the files
are available to personnel managing the
facilitv's safety program.
All personnel using flammable, toxic, and/or caustic
substances follow the prescribed procedures. They:
Wear personal protective
Equipment.
Report hazards and spills to the
desiQnated official.
The MSDSs are readily accessible to staff and
detainees in the work areas.

•

•
•
•
•

Hazardous materials are always issued under proper
supervision.
quantities are limited.
• Staff always supervises detainees using these
substances.
All "flammable" and "combustible" materials (liquid and
aerosol) are stored and used according to label
recommendations.
Lighting fixtures and electrical equipment are installed in
storage rooms and other hazardous areas meet
National Electrical Code requirements.
All toxic and caustic materials stored in their original
containers in a secure area.
Excess flammables, combustibles, and toxic liquids are
disposed of properly and in accordance with MSDSs.
Staff directly supervises and accounts for products with
methyl alcohol. Staff receive a list of products
containing diluted methyl alcohol, e.g., shoe dye. All
such products clearly labeled as such. "Accountability"
includes issuing such products to detainees in the
smallest workable Quantities.
Every employee and detainee using flammable, toxic, or
caustic materials receives advance training in their use,
storage, and disposal.
The facility complies with the most current edition of
applicable codes, standards, and regulations of the
National Fire Protection Association and the
Occupational Safety and Health Administration (OSHA).

•

_.....•

45
G-324A Detention Inspection FOlm Worksheet for IGSAs - Rev: 01/04/05

Remarks

......

ENVIRONMENTAL HEALTH AND SAFETY

•
•
•

requ
Monthly fire inspections.
Fire protection equipment strategically located
throughout the facility.
Public posting of emergency plan with
accessible building/room floor plans.
Exit signs and directional arrows.
An area-specific exit diagram conspicuously
in the
med area.

and disposal
All items representing potential safety or security risks
are inventoried and a designated individual checks this

•
•

ing practices include:
Using specified equipment; cleansers;
disinfectants and detergents.
An established schedule of cleaning and follow-

46
G-324A Detention Inspection Fonn Worksheet [or IGSAs - Rev: 01/04/05

ENVIRONMENTAL HEALTH AND

Policy: Every facility will control flammable, toxic, and caustic materials through a hazardous materials
program. The program will include, among other things, the identification and labeling of hazardous materials in
accordance with applicable standards (e.g., National Fire Protection Association [NFPA]); identification of
incompatible materials, and safe-handling procedures
Emergency power generators is tested at least every
two weeks.
• Other emergency systems and equipment
receive testing at least quarterly.
Testing is followed-up with timely corrective
actions
irs and rAn,I<lf"Arr'Ant"

o Deficient

IZI Acceptable

OAt-Risk

Remarks: (Record significant facts, obseNations, other sources used, etc.)

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

47
G·324A Detention Inspection FOlm Worksheet for IGSAs - Rev: 01/04/05

o Repeat Finding

•

HOLD ROOMS IN DETENTION FACILITIES

•

Policy: Hold rooms will be used only for temporary detention for detainees awaiting removal, transfer, EOIH
hearings, medical treatment, intra-facility movement, or other processing into or out of the facility.
Components

The hold room is situated within the secure perimeter.
The hold rooms are well ventilated, well lighted and all
activating switches located outside the room.
The hold rooms contain sufficient seating for the
number of detainees held.
No bunks/cots/beds or other related make shift
sleeping apparatuses are permitted inside holdrooms.
The walls and ceilings of the hold rooms are tamper and
escape proof.
Detention in hold rooms is limited to 12 hours.
Male and females are segregated from each other.
Every effort is made to ensure that detained detainees
under the aQe of 18 are not held with adult detainees.
Detainees are provided with basic personal hygiene
items such as water, soap, toilet paper, cups for water,
feminine hygiene items, diapers and wipes.
In older facilities officers are within visual or audible
range to allow detainees access to toiletfacilities on a
regular basis.
All detainees are given a patdown search for weapons or
contraband before being placed in the room.
Officers closely supervise the detention hold rooms
using direct supervision (Irregular visual monitoring.).
• Hold rooms are irregularly monitored every 15
minutes.
• Unusual behavior or complaints are noted .
When the last detainee has been removed from the
hold room, it is given a thorouQh inspection.
There is a written evacuation plan that includes a
designated officer to remove detainees from hold rooms
in case of fire and/or building evacuation.
An appropriate emergency service is called
immediately upon a determination that a medical
emergency may exist.

~
~

0
0

0
0
0
0

o Deficient

~ Acceptable

~
~

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

i l h' It",,·!;
, I",.

~() V

48
G·324A Detention inspection Form Worksheet for IGSAs . Rev: 01104/05

Remarks

o Repeat Finding

•

HOLD ROOMS IN DETENTION FACILITIES

•

The hold room is situated within the secure perimeter.
The hold rooms are well ventilated, well lighted and all
activating switches located outside the room.
The hold rooms contain sufficient seating for the
number of detainees held.
No bunks/cots/beds or other related make shift
sleeping apparatuses are permitted inside holdrooms.
The walls and ceilings of the hold rooms are tamper and
escape proof.
Detention in hold rooms is limited to 12 hours.
Male and females are seQreQated from each other.
Every effort is made to ensure that detained detainees
under the age of 18 are not held with adult detainees.
Detainees are provided with basic personal hygiene
items such as water, soap, toilet paper, cups for water,
feminine hygiene items, diapers and wipes.
In older facilities officers are within visual or audible
range to allow detainees access to toilet facilities on a
regular basis.
All detainees are given a patdown search for weapons or
contraband before being placed in the room.
Officers closely supervise the detention hold rooms
using direct supervision (Irregular visual monitoring.).
• Hold rooms are irregularly monitored every 15
minutes.
• Unusual behavior or complaints are noted .
When the last detainee has been removed from the
hold room, it is given a thorough inspection.
There is a written evacuation plan that includes a
designated officer to remove detainees from hold rooms
in case of fire and/or buildinQ evacuation.
An appropriate emergency service is called
immediately upon a determination that a medical
emergency may exist.

[g]
[g]

D
D

[g]

D
D
D
D

[g]

[g] Acceptable

o Deficient

[g]
[g]

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

',}
.
t ......-- })f ~J
.,.
•

48
G-324A Detention Inspection FOlID Worksheet for [GSAs - Rev: 0[/04/05

Remarks

o Repeat Finding

•

HOLD ROOMS IN DETENTION FACILITIES

•

Policy: Hold rooms will be used only for temporary detention for detainees awaiting removal, transfer, EOIR
hearings, medical treatment, intra-facility movement, or other processing into or out of the facility.
Components

The hold room is situated within the secure perimeter.
The hold rooms are well ventilated, well lighted and all
activating switches located outside the room.
The hold rooms contain sufficient seating for the
number of detainees held.
No bunks/cots/beds or other related make shift
sleeping apparatuses are permitted inside holdrooms.
The walls and ceilings of the hold rooms are tamper and
escape proof.
Detention in hold rooms is limited to 12 hours.
Male and females are segregated from each other.
Every effort is made to ensure that detained detainees
under the aQe of 18 are not held with adult detainees.
Detainees are provided with basic personal hygiene
items such as water, soap, toilet paper, cups for water,
feminine hygiene items, diapers and wipes.
In older facilities officers are within visual or audible
range to allow detainees access to toilet facilities on a
regular basis.
All detainees are given a patdown search for weapons or
contraband before bei~placed in the room.
Officers dosely supervise the detention hold rooms
using direct supervision (Irregular visual monitoring.).
Hold rooms are irregularly monitored every 15
minutes.
Unusual behavior or complaints are noted .
When the last detainee has been removed from the
hold room, it is given a thorough inspection.
There is a written evacuation plan that includes a
designated officer to remove detainees from hold rooms
in case of fire and/or buildinQ evacuation.
An appropriate emergency service is called
immediately upon a determination that a medical
emergency may exist.

IZI
IZI

0
0

IZI

IZI
IZI
IZI
IZI

0
0

•

IZI Acceptable

D Deficient

LJ
LJ

IZI

At·Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6). (b)(7)c

48
G-324A Detention Inspection FOlm Worksheet for ]GSAs - Rev: 01104/05

Remarks

D Repeat Finding

-----.----..- - - - - - . - -..- -

•

KEY AND

•

LocK CONTROL--·---..· - - - - - - - · · - · [

(SECURITY, ACCOUNTABILITY AND MAINTENANCE)

, Policy It is the policy of the ICE Service to maintain an efficient system for the use , accountability and
maintenance of all keys and locks.
Components

The security officer[sj, or equivalent in I GSAs, has
attended an approved locksmith training program.
The security officer, or equivalent in IGSAs, has
responsibly for all administrative duties and responsibilities
relating to keys, locks etc,
The security officer, or equivalent in IGSAs, provides
training to employees in key control.
The security officer, or equivalent in IGSAs, maintains
inventories of all keys, locks and locking devices.

0
0
0
0

~
~

0
0
0

The security officer follows a preventive maintenance
program and maintains all preventive maintenance
documentation.
Facility policies and procedures address the issue of
compromised keys and locks.
The security officer, or equivalent in IGSAs, develops
policy and procedures to ensure safe combinations
integrity.
Only dead bolt or dead lock functions are used in detainee
accessible areas.
Non-authorized locks (as specified in the Detention
Standard) are not used in detainee accessible areas.
The facility does not use grand master keying systems.
All worn or discarded keys and locks cut up and properly
disposed of .
Padlocks and/or chains are not used on cell doors.
The entrance/exit door locks to detainee living quarters, or
areas with an occupant load of 50 or more people,
conform to
• Occupational Safety and Environmental Health
Manual, Chapter 3
National Fire Protection Association Life Safety
Code 101.
The operational keyboard sufficient to accommodate all
the facility key rings including keys in use is located in a
secure area.
Procedures in place to ensure that key rings are:
• Identifiable
Numbers of keys on the ring are cited?
Keys cannot be removed from issued key rings
Emergency keys are available for all areas of the facility.
The facilities use a key accountability system.

~
~

Remarks

•

•
•

Authorization is necessary to issue any restricted key.
Individual gun lockers are provided.
• They are located in an area that permits constant
officer observation.
• In an area that does not allow detainee or public
access.

49
G-324A Detention Inspection Fonll Worksheet for rGSAs - Rev: 01104/05

Officers sign for keys with
a picture chit.

•

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)

•

Policy It is the policy of the ICE Service to maintain an efficient system for the use, accountability and
maintenance of all keys and locks.
Components
The facility has a key accountability policy and procedures
to ensure key accountability. The keys are physically
counted daily.
All staff members are trained and held responsible for
adhering to proper procedures for the handling of keys.
• Issued keys are retumed immediately in the
event an employee inadvertently carries a key
ring home.
• When a key or key ring is lost, misplaced, or not
accounted for, the shift supervisor is
immediately notified.
• Detainees are not permitted to handle keys
assigned to staff.
~ Acceptable

o Deficient

[g]

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

50
G-324A Detention Inspection Fonu Worksheet for IGSAs - Rev: 01104/05

Remarks

o Repeat Finding

•

,·--------··--·-······--····----------pOPULATION COUNTS-----··--

•
-"--"---1

Policy: All detention facilities shall ensure around-the-clock accountability for all detainees. This requires that
they conduct at least one formal count of the detainee population per shift, with additional formal and informal
. counts conducted as necessary.
._ - ... - - -.. ·..·--·Components----· .---'-.--~ " - - ' " - - " - - ' - y
N
Remarks
Staff conducts a formal count at least once each shift.
Activities cease or are strictly controlled while a formal
count is being conducted.
Do certain operations continue during formal counts.
Is a certain amount of movement tolerated during a
formal count.
Formal counts in all units take place simultaneously.
Officers do not allow detainee partiCipation in the count.
A face-to-photo count follows each unsuccessful
recount.
Officers positively identify each detainee before
counting him/her as present.
Written procedures cover informal and emergency
counts.
• They followed during informal counts .
During emergencies .
The control officer (or other designated position)
maintains an out -count record of all detainees
temporarily leaving the facility.
This training is documented in each officer's training
folder.

~ Acceptable

o Deficient

.lJ

D
D

~
~
~

D
D
D

D
D
D
11
D
D

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

51
G-324A Detention Inspeetion FOim Worksheet for IGSAs - Rev: 01/04/05

Kitchen.

o Repeat Finding

..-

.....---.-.---...-

•

.....---.--..... POST

•

ORDERS·-····--··--··-·····---··-·····~

Policy: ICE provides officers all necessary guidance for carrying out their duties. This guidance includes the
: post orders established for every post, which are reviewed at least annually, and given to each officer upon
. assignment to that post.
. ___ ._ _Components _ _ _._ _. ' _ ~~
Every Fixed post has a set of post orders.
181
Each set contains the latest inserts (emergency
181
memoranda, etc.) and revisions.
One individual or department is responsible for keeping
Il;'l
all post-orders current with revisions that take place
between reviews.
The IGSA maintains a complete set (central file) of post
Il;'l
orders.
The central file accessible to all staff.
181
The OIC or Contract /IGSA equivalent
Il;'l
initiate/authorizes all post-order changes.
The OIC or Contract /IGSA equivalent has signed and
Il;'l
dated the last page of eve_ry section.
A review/updating/reissuing of post orders occurs
Il;'l
regularly and at a minimum, annually.
Procedures keep post orders and logbooks secure from
181
detainees at all times.
Every armed-post officer qualifies with the post
Il;'l
weapon(s) before assuming post duty.
Armed-post post orders provide instructions for escape
Il;'l
attempts.
The post orders for housing units track the event
Il;'l
schedule.
Housing-unit post officers record all detainee activity in. a
Il;'l
log. The post order include instructions on maintaining
the logbook.

(gj Acceptable

o Deficient

D
D
D

IT --u

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

52
G-324A Detention Inspection Fonn Worksheet for IGSAs . Rev: 01/04/05

__ .__.-

- - -Remarks
-....

o Repeat Finding

---------

•

··--------SECURITY INSPECTIONS-·-------·---·-·-- . _ -..,

Poli.cy:
Post assignments in the facility's high-risk areas, where special security procedures must be followed, ,
.
. will be restricted to experienced personnel with a thorough grounding in facility operations.
Components
Yes
No
NA
Remarks
- 0 ' ' - - " . - - - - " - - -.. - -.....- -...- - - . - - - - " ' - _.. - - ' . -The facility has a comprehensive security inspection
policy. The policy specifies:
• Posts to be inspected
• Required inspection forms
~
D D
• Frequency of inspections
• Guidelines for checking security features
• Procedures for reporting weak spots,
inconsistencies, and other areas needing
imQrovement
Every officer is required to conduct a security check of
~
D D
his/her assigned area. The results are documented.
Documentation of security inspections is kept on file.
~
D []
Procedures ensure that recurring problems and a failure to
take corrective action are reported to the appropriate
~
D D
manager.
The front-entrance officer checks the 10 of everyone
~
D D
entering or exiting the facility.
All visits officially recorded in a visitor logbook or
electronically recorded.
The facility has a secure visitor pass system.
Every Control Center officer receives specialized training.
The Control Center is staffed around the clock.
Poli<:yrestricts staff access to the Control Center.
Detainees do not have access to the Control Center.
Communications are centralized in the Control Center.
Officers monitor all vehicular traffic entering and leaving
the faCility.
The facility maintains a log of all incoming and departing
vehicles to sensitive areas of the facility. Each entry
contains:
• The driver's name
• Company represented
• Vehicle contents
• Delivery date and time
• Date and time out
• Vehicle license number
• Name of employee responsible for the vehicle
durillQ the facili!Y visit
Officers thoroughly search each vehicle entering and
leaving the facilitv.
The facility has a written policy and procedures to prevent
the introduction of contraband into the facility or any of its
components.
Tools being taken into the secure area of the facility are
inventoried before entering and prior to departure.
The SMU entrance has a sallyport.
Written procedures govern searches of detainee housing
units and personal areas.
Housing area searches occur at irregular times.

~
~

D
D
D
D
D
D

~
~
~
~
~

D
D
D
D
D
D
D
D
Sally port vehicle log.

D
D
D
D

[J
~
~

D
[J

53
G-324A Detention Inspection FOlm Worksheet for IGSAs - Rev: 01104/05

•

SECURITY INSPECTIONS

Policy: Post assignments in the facility's high-risk areas, where special security procedures must be followed,
: wiff be restricted to experienced personnel with a thorough grounding in facility operations.
Yes
NA
Components
No
Remarks
Every search of the SMU and other housing units
documented.
Storage and supply rooms; walls, light and plumbing
fixtures, accesses, and drains, etc. undergo frequent;
irregular searches. These searches are documented.
Walls, fences, and exits, including exterior windows, are
inspected for defects once each shift.
Daily procedures include:
• Perimeter alarm system tests.
• Physical checks of the perimeter fence.
Documenting the results.
Visitation areas receive frequent, irregular inspections.

o Deficient

~ Acceptable

[:gj

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c
.

"I -.J ~•.J j
..or:

•

~:';l

-="!l

54
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

o Repeat Finding

•

SPECIAL MANAGEMENT UNIT (SMU)
Administrative Segregation

Policy: The Special Management Unit required in every facility isolates certain detainees from the general
population. The Special Management Unit will consist of two sections. One, Administrative Segregation,
houses detainees isolated for their own protection; the other for detainees being disciplined for wrongdoing (see
the "Special Management Unit [Disciplinary Segregation)" standard).
Components
The Administrative Segregation unit provides
non-punitive protection from the general population and
individuals undergoing disciplinary segregation.
• Detainees are placed in the SMU
(administrative) in accordance with written
criteria.
In exigent circumstances, staff may place a detainee in
the SMU (administrative) before a written order has
been approved.
• A copy of the order given to the detainee within
24 hours.
The OIC (or equivalent) regularly reviews the status of
detainees in administrative detention.
• A supervisory officer conducts a review within
72 hours of the detainee's placement in the
SMU (administrative).
A supervisory officer conducts another review after the
detainee has spent seven days in administrative
segregation.
• Every week thereafter for the first month.
• Every 30 days after the first month.
• Does each review include an interview with the
detainee.
• Is a written record made of the decision and
the justification.
The detainee is given a copy of the decision and
justification for each review.
• The detainee is given an opportunity to appeal
the reviewer's decision to someone else in the
facility.
The OIC (or equivalent) routinely notifies the Field
Office Director (or staff officer in charge of IGSAs) any
time a detainee's stay in administrative detention
exceeds 30 days.
• Upon notification that the detainee's
administrative segregation has exceeded 60
days, the FD forwards written notice to HQ
Field Operations Branch Chief for DRO.
The OIC or equivalent) reviews the case of every
detainee who objects to administrative segregation
after 30 days in the SMU.
• A written record is made of the decision and
the justification.
• The detainee receives a copy of this record.
The detainee is given the right to appeal to the OIC (or
equivalent) the conclusions and recommendations of
any review conducted after the detainee has remained
in administrative segregation for seven consecutive
days.

IZl

55
G-324A Detention

~lspection

FOlm Worksheet for IGSAs - Rev: 01104/05

Remarks

SPECIAL MANAGEMENT UNIT (SMU')
Administrative Segregation

Policy: The Special Management Unit required in every facility isolates certain detainees from the general
population. The Special Management Unit will consist of two sections. One, Administrative Segregation,
houses detainees isolated for their own protection; the other for detainees being disciplined for wrongdoing (see
the "Special Management Unit [Disciplinary Segregation]" standard).
Administratively segregated detainees enjoy the same
general privileges as detainees in the general
The SMU well ventilated.
Adequately lighted.
• Appropriately heated.
Mal
condition.
are eqlJlp~Jeu
• Every bed securely fastened to the floor or
wall.
The number of detainees in any cell does not exceed
the occupancy limit.
• When occupancy exceeds recommended
capacity, do basic living standards decline?
• Do criteria for objectively assessing living
standards exist?
If yes, are the criteria included in the written
ures?
The segregated detainees do not have fewer
opportunities to exchange/launder clothing, bedding,
and linen than detainees in the
eral
receive three nutritious meals per day.
•
From the general population's menu of the day.
• Do detainees eat only with disposable utensils.
• Is food ever used as
ment.
Each detainee
a normal level of personal
hygiene in the SMU.
• The detainees have the opportunity to shower
and shave at least three times a week.
If
are
•
Barbering services.
•
Recreation privileges in accordance with the
"Detainee Recreation" standard.
• Non-legal reading material.
•
Religious material.
• The same correspondence privileges as
detainees in the general population.
• Telephone access similar to that of the general
population.
care
every
three times a week.
• The shift supervisor visits each detainee daily.
•
and
Procedures comply
standard.
• The detainee retains visiting privileges.
• The visiting room available during normal

56
G-324A Detention Inspection FOIlll Worksheet for IGSAs - Rev: 01104/05

SPECIAL MANAGEMENT UNIT (SMU)
Administrative Segregation
Policy: The Special Management Unit required in every facility isolates certain detainees from the general
population. The Special Management Unit will consist of two sections. One, Administrative Segregation,
houses detainees isolated for their own protection; the other for detainees being disciplined for wrongdoing (see
the "Special Management Unit [Disciplinary Segregation)" standard}.

SPC procedures include completing the SMU Housing
Record (1-888) immediately upon a detainee's
placement in the SMU.
Staff completes the form at the end of each
shift.
CDFs and IGSA facilities use Form 1-888 (or
local
Staff record whether the detainee ate,
exercised and took any medication during every shift.
• Logs record all pertinent information, e.g., a
medical condition, suicidal/assaultive behavior,
etc ..
• The medical officerihealth care professional
signs each individual's record during each visit
• The housing officer initials the record when all
detainee services are completed or at the end
of the shift.
new record is created for each week the detainee is
in Administrative Segregation.
• These weekly records are retained in the SMU
until the detainee's return to the general

•

~ Acceptable

o Deficient

[81

OAt-Risk

Remarks: (Record significant facts, obseNations, other sources used, etc.)

57
G-324A Detention Inspection F0l111 Worksheet for IGSAs - Rev: 0]/04/05

o Repeat Finding

•

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)

Policy: Each facility will establish a Special Management Unit in which to isolate certain detainees from the
general population. The Special Management Unit will have two sections, one for detainees in Administrative
Segregation; the other for detainees being segregated for disCiplinary reasons.
Components

Officers placing detainees in disciplinary segregation
follow written procedures.
The sanctions for violations committed during one
incident do not exceed 60 days.
completed
Disciplinary
Segregation
A
Order
accompanies the detainee into the SMU.
• The detainee receives a copy of the order
within 24 hours of placement in disciplinary
segregation.
Standard procedures include reviewing the cases of
individual detainees housed in disciplinary detention at
set intervals.
• After each formal review, the detainee receives
a written copy of the decision and reasons for it.
The conditions of confinement in the SMU are
proportional to the amount of control necessary to
protect detainees and staff.
Detainees in disciplinary segregation have fewer
privileges than those housed in administrative
segregation.
Living conditions in diSCiplinary SMUs modified to
reinforce acceptable behavior.
• If yes, does staff prepare written
documentation for this action.
• Does the OIG sign to indicate approval.
Every detainee in disciplinary segregation receive the
same humane treatment, regardless of offense.
The quarters used for segregation are:
Well-ventilated.
• Adequately lighted.
• Appropriately heated.
• Maintained in a sanitary condition.

[8;]

All cells are equipped with beds.
• The beds securely fastened to the floor or wall of
the cell.
The number of detainees confined to each cell or room
do not exceed the number for which the space was
designate.
• Does the OIG approve excess occupancy on a
temporary basis.
When a detainee is segregated without clothing,
mattress, blanket, or pillow, (in a dry cell setting) a
justification is made and the decision is reviewed each
shift. Items are returned as soon as it is safe.
Detainees in the SMU have the same opportunities to
exchange clothing, bedding, etc., as other detainees.

58
G-324A Detention Inspection Fonn WOlxsheel for IGSAs - Rev: 01104/05

Remarks

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)
Policy: Each facility will establish a Special Management Unit in which to isolate certain detainees from the
general population. The Special Management Unit will have two sections, one for detainees in Administrative
Segregation; the other for detainees being segregated for disciplinary reasons.

are
to maintain a
hygiene, including the opportunity to shower
at least three times/week.
The detainees receive, unless
to secu rity:
• Barbering services.
• Recreation privileges.
• Other·than·legal reading material.
• Religious material.
• The same correspondence privileges as other
detainees.

•
•
•

•
•

access.
Violent/uncooperative detainees retain access
to the law library unless adjudicated a security
threat in writing.
Legal material brought to individuals in the
SMU on a case·by·case basis.
Staff document every incident of denied
access to the law I

[gJ

59
G-324A Detention Inspection Form Worksheet for IGSAs • Rev: 01104/05

.:or<= ...."L

MANAGEMENT U IT
(Disciplinary Segregation)

records
exercised, took medication, etc.
•
Details about the detainee logged, e.g., a
medical condition, suicidal/violent behavior,
etc.
• The health care official sign individual records
after each visit.
• The housing officer initials the record when all
detainee services are completed or at the end
of the shift.
•
A new record is created weekly for each
detainee in the SMU.
• The SMU retains these records until the
the SMU.
~ Acceptable

Deficient

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

60
G·324A Detention Inspection FOim Worksheet for [GSAs • Rev: 01/04/05

Repeat Finding

•

TOOL CONTROL

Policy: It is the policy of all facilities that all employees shall be responsible for complying with the tool control
policy. The Maintenance Supervisor shall maintain a computer generated or typewritten Master Inventory list of
tools and equipment and the location in which tools are stored. These inventories shall be current, filed and
readily available for tool inventory and accountability during an audit.
Components
There is an individual who is responsible for developing
a tool control procedure and an inspection system to
insure accountability.
Department heads are responsible for implementing this
standard in their departments.
Tool inventories are required for:
0
Maintenance Department
0
Medial Department
0
Food Service Department
0
Electronics Shop
0
Recreation Department
0
Armory
The facility has a facility policy for the regular inventory
of all tools.
0
The policy sets minimum time lines for physical
inventory and all necessary documentation.
0
ICE facilities use AMIS bar code labels when
required.
The facility has a tool classification system. Tools are
classified according to:
0
Restricted (dangerous/hazardous)
0

j2g

Non Restricted (non-hazardous).

Department heads are responsible for implementing
tool-control procedures.
The facility has policies and procedures in place to
ensure that all tools are marked and readily identifiable.
The facility has an approved tool storage system.
0
The system ensures that all stored tools are
accountable.
0
Commonly used tools (tools that can be
mounted) are stored in such a way that
missing tool are readily notice.
Each facility has procedures for the issuance of tools to
staff and detainees.
The facility has policies and procedures to address the
issue of lost tools. The policy and procedures include:
0
Verbal and written notification.
0
Procedures for detainee access.
0
Necessary documentation/review for all
incidents of lost tools.
Broken or worn out tools are surveyed and disposed of
in an appropriate and secure manner.
All private or contract repairs and maintenance workers
under contract to the ICE, or other visitors, submit an
inventory of all tools prior to admittance into or departure
from the facility.

61
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

Remarks

TOOL CONTROL

~ Acceptable

(b )(6), (b )(7)~ -

- -

o Deficient

OAt-Risk

. nt facts, observations, other sources used, etc.)

62
G-324A Detention Inspection Fonl1 Worksheet for IGSAs - Rev: 01104/05

o Repeat Finding

•

.--.-... ------....- - - - - ..-------- TRANSPORTATION---···-------··-·--·····-.

(Land Transportation)

-l
I

. Policy The Immigration and Naturalization Service will take all necessary precautions to protect the lives,
safety and welfare of our officers the general public and those in ICE custody during the transportation of
detainees. Standards have been established for professional transportation under the supervision of
experienced and trained Detention Enforcement Officers or authorized contract personnel.

I2?J Standard NA: Check this box if all ICE Transportation are handled only by the ICE Field Office or
Sub-Office in control of the detainee case.
Components
Transporting officers ccihiply with -applicable local, state,
and federal motor vehicle laws and regulations. Records
support this finding of compliance.
Every transporting officer required to drive a commercial
size bus has a valid Commercial Driver's License (CDL)
issued by the state of emjJIoyment.
Supervisors maintain records for each vehicle operator.
Officers use a checklist during every vehicle inspection.
• Officers report deficiencies affecting operability.
• Deficiencies are corrected before the vehicle
goes back into service.
Transporting officers:
• Limit driving time to 10 hours in any 15 hour
period.
• Drive only after eight consecutive off-duty hours.
• Do not receive transportation assignments after
having been on duty, in any capacity, for 15
hours.
• Drive a 50-hour maximum in a given work week;
a 70-hour maximum during eight consecutive
days.
• During emergency conditions (including bad
weather), officers may drive as long as
necessary and safe to reach a safe
area-exceeding the 10-hour limit.
Two officers with valid CDLs required in any bus
transporting detainees.
• When buses travel in tandem with detainees,
there two qualified officers per vehicle.
• An unaccompanied driver transport an empty
vehicle.
Before the start of each detail, the vehicle is thoroughly
searched.
Positive identification of all detainees being transported is
confirmed.
All detainees are searched immediately prior to boarding
the vehicle by staff controlling the bus or vehicle.
The facility ensures that the number of detainees
transported does not exceed the vehicles manufacturers
occupancy level.
Protective vests are provided to all transporting officers.

Yes

[gJ

1 - . -1---- t-- . - _

63
G-324A Detention Inspection FOlm Worksheet for IGSAs - Rev: 01/04/05

...

Remarks
_-_
.. . _ -

--_.

No vehicles requiring a
CDL.

•

TRANSPORTATION
(Land Transportation)

Policy The Immigration and Naturalization Service will take all necessary precautions to protect the lives,
safety, and welfare of our officers, the general public, and those in ICE custody during the transportation of
detainees. Standards have been established for professional transportation under the supervision of
experienced and trained Detention Enforcement Officers or authorized contract personnel.

[;gJ Standard NA: Check this box if all ICE Transportation are handled only by the ICE Field Office or
: Sub-Office in control of .the detainee case.
Components

Yes

The vehicle crew conducts a visual count once all
passengers are on board and seated.
• Additional visual counts are made whenever the
vehicle makes a scheduled or unscheduled
stop.
Policies and procedures are in place addressing the use of
restraining equipment on transportation vehicles.
Officers ensure that no one contacts the detainees.
• One officer remains in the vehicle at all times
when detainees are present.
Meals are provided during long distance transfers.
• The meals meet the minimum dietary standards,
as identified by dieticians utilized by the Service.
The vehicle crew inspects all Food Service pickups before
accepting delivery (food wrapping, portions, quality,
quantity, thermos-transport containers, etc.).
• Before accepting the meals, the vehicle crew
raises and resolves questions, concerns, or
the
Food
Service
discrepancies
with
representative.
drinking-water
and
• Basins, latrines,
containers/dispensers are cleaned and sanitized
on a fixed schedule.
Vehicles have:
• Two-way radios.
• Cellular telephones.
• Equipment boxes stocked in accordance with the
Use of Force Standard.
The vehicles are clean and sanitary at all times.
Personal property of a detainee transferring to another
facility:
• Is inventoried.
• Is inspected.
• Accompanies the detainee.

!2J

[;gJ

!2J

[;gJ

!2J

64
G-324A Detention Inspection Fonn Worksheet for IGSA, - Rev: Oll04/05

Remarks

I
I

•

TRANSPORTATION
(Land Transportation)

Sub-Office in control of the detainee case.
Components
The following contingencies are included in the written
procedures for vehicle crews:
• Attack
• Escape
• Hostage-taking
• Detainee sickness
• Detainee death
• Vehicle fire
Riot
• Traffic accident
• Mechanical problems
• Natural disasters
• Severe weather
• Passenger list is not exclusively men or women
or minors

~ Acceptable

Yes

r8l

OAt-Risk

Deficient

65
G-324A Detention inspection Forn. Worksheet for IGSAs . Rev: 01/04/05

Remarks

o Repeat Finding

I
II
I

•

USE OF FORCE

Policy: The U.S. Department of Homeland Security authorizes the use offorce only as a last alternative after all
other reasonable efforts to resolve a situation have failed. Only that amount of force necessary to gain control
of the detainee, to protect and ensure the safety of detainees, staff and others, to prevent serious property
damage and to ensure institution security and good order may be used. Physical restraints necessary to gain
control of a detainee who appears to be dangerous may be employed when the detainee:
Components
Written policy authorizes staff to respond in an
immediate-use-of-force situation without a supervisor's
presence or direction.
When the detainee is in an area that is or can be
isolated (e.g., a locked cell, a range), posing no direct
threat to the detainee or others, officers must try to
resolve the situation without resorting to force.
Written policy asserts that calculated rather than
immediate use of force is feasible in most cases.
The facility subscribes to the prescribed Confrontation
Avoidance Procedures.
• Ranking detention official, health
profeSSional, and others confer before every
calculated use of force.
When a detainee must be forcibly moved and/or
restrained and there is time for a calculated use of force,
staff use the Use-of-Force Team Technique.
• Under staff supervision.
Staff members are trained in the performance of the
Use-of-Force Team Technique.
All use-of-force incidents are documented and reviewed.
Staff:
• Does not use force as punishment.
• Attempts to gain the detainee's voluntary
cooperation before resorting to force
• Uses only as much force as necessary to
control the detainee.
• Uses restraints only when other nonconfrontational means, including verbal
persuasion, have failed or are impractical.
Mecication may only be used for restraint purposes
when authorized by the Medical Authority as medically
necessal)'.
Use-of-Force Team follow written procedures that
attempt to prevent injury and exposure to communicable
disease(s).

Yes

I:8l

I:8l
I:8l

0
0

I:8l

66
G·324A Detention Inspection FOlm Worksheet for IGSAs . Rev: 01104/05

Remarks

USE OF FORCE
Policy: The U.S. Department of Homeland Security authorizes the use of force only as a last alternative after all
other reasonable efforts to resolve a situation have failed. Only that amount of force necessary to gain control
of the detainee, to protect and ensure the safety of detainees, staff and others, to prevent serious property
damage and to ensure institution security and good order may be used. Physical restraints necessary to gain
control of a detainee who appears to be dangerous may be employed when the detainee:
Standard procedures associated with using four-point
restraints include:
•
Soft restraints (e.g., vinyl)
•
Dressing the detainee appropriately for the
temperature.
• A bed, mattress, and blanket/sheet.
Checking the detainee at least every 15
minutes.
Logging each check.
• Turning the bed-restrained detainee often
enough to prevent soreness or stiffness.
•
Medical evaluation of the restrained
detainee twice per eight-hour shift.
• When qualified medical staff is not
immediately available, staff position the
detainee "face-u
supervisor monitors the detainee's
position/condition every two hours.
He/she allow the detainee to use the rest
room at these times under

use
weapons:
Medical staff is consulted before staff use
pepper spray/non-lethal weapons.
Medical staff review the detainee's medical
file before use of a non-lethal weapon is
authorized.
I precautions are taken when restraining pregnant
detainees.

is used. In other
(IGSAs / CDFs) this form or its equivalent is

67
G·324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

•

USE OF FORCE

Policy: The U.S. Department of Homeland Security authorizes the use of force only as a last alternative after all

other reasonable efforts to resolve a situation have failed. Only that amount of force necessary to gain control
of the detainee, to protect and ensure the safety of detainees, staff and others, to prevent serious property
damage and to ensure institution security and good order may be used. Physical restraints necessary to gain
control of a detainee who appears to be dangerous may be employed when the detainee:

Components

I:8l Acceptable

D Deficient

Yes

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

68
G-324A Detention Inspection Fonn Worksheet for raSAs • Rev: 01/04/05

Remarks

D Repeat Finding

... _....

_------_..

•

--. __..._ - - - - _ ...

.... -.

•

-- ....- - -

...._-

... __ ._-

STAFF DETAINEE COMM'UNICATIONS

Policy: Procedures must be in place to allow for formal and informal contact between key facility staff and
ICE staff and ICE detainee and to permit detainees to make written requests to ICE staff and receive an
, answer in an acceptable time frame.
, ..

-.,.

._ ... _ - - - y _ .

_.-._._-.---

Components
The ICE Field Office Director ensures that weekly
announced and unannounced visits occur at the IGSA.
Detention and Deportation Staff conduct scheduled
weekly visits with detainees held in the IGSA.
Scheduled visits are posted in ICE detainee areas.
Visiting staff observe and note current climate and
conditions of confinement at each IGSA.
ICE information request Forms are available at the
IGSA for use by ICE detainees.
The IGSA treats detainee correspondence to ICE staff
as Special Correspondence.
ICE staff respond to a detainee request from an IGSA
within 72 hours.
ICE detainees are notified ion writing upon admission to
the facility of their right to correspond with ICE staff
regarding their case or conditions of confinement.
~ Acceptable

D Deficient

-_ ......._..

_..•...

r:gJ

0
0
0

r:gJ

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6). (b)(7)c

69
G·324A Detention Inspeetion Fonn Worksheet for rGSAs - Rev: 01104/05

. .. _.-

Remarks

Weekly ICE visits.

Repeat Finding

•

,-.--.. -.. --._-.-.- ....- . ------.-- ··--D-ETAiNE-E-T-RA-NSFE-R-·-S-T-ANbA-R-D--·-·----······-----·-----Policy: ICE will make all necessary notifications when a detainee is transferred. If a detainee is being
: transferred via the Justice Prisoner Alien Transportation System (JPATS), ICE will adhere to JPATS
protocols. In deciding whether to transfer a detainee, ICE will take into consideration whether the detainee
is represented before the immigration court. In such cases, the Field Office Director will consider the
detainee's stage within the removal process, whether the detainee's attomey is located within reasonable
driving distance of the facility and where the immigration court proceedings are taking place
Components
Y
NA
N
Remarks
When a detainee is represented by legal counselor a
legal representative, and a G-28 has been filed, the
representative of record is notified by the detainee's
Deportation Officer.
~
0
0
• The notification is recorded in the detainee's file
• When the A File is not available, notification is
noted within DACS
Notification includes the reason for the transfer and the
~
0
0
location of the new facility,
The deportation officer is allowed discretion regarding
the timing of the notification when extenuating
~
0
0
circumstances are involved.
The attorney and detainee are notified that it is their
responsibility to notify family members regarding a
~
0
0
transfer.
Facility policy mandates that:
• Times and transfer plans are never discussed
with the detainee prior to transfer.
• The detainee is not notified of the transfer until
~
0
0
immediately prior to departing the facility.
• The detainee is not permitted to make any
phone calls or have contact with any detainee in
the qeneral population.
The detainee is provided with a completed Detainee
~
0
0
Transfer Notification Form.
Form
G-391
or
equivalent
authorizing
the
•
~
0
0
removal of a detainee from a facility is used.
For medical transfers:
ICE staff do all medical
and other transfers.
• The Detainee Immigration Health Service (or
IGSA)(DIHS) Medical Director or designee
approves the transfer.
~
0
0
• Medical transfers are coordinated through the
local ICE office.
• A medical transfer summary is completed and
accompanies the detainee.
Detainees in ICE facilities having DIHS staff and
medical care are transferred with a completed transfer
summary sheet in a sealed envelope with the detainee's
0
0
~
name and A-number and the envelope is marked
Medical Confidential.
For medical transfers, transporting officers receive
ICE would provide
0
0
~
instructions reqarding medical issues.
transport.
Detainee's funds and valuables and property are
returned and transferred with the detainee to his/her
~
0
0
new location.
Transfer and documentary procedures outlined in
0
~
0
Section C and D are followed.

70
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

•

DETAI~N=E=E~T=RA~N~S=F=E=R~S=T~A~N=D~A=R=D------------~~----~

Policy: ICE will make all necessary notifications when a detainee is transferred. If a detainee is being
. transferred via the Justice Prisoner Alien Transportation System (JPATS), ICE will adhere to JPATS
protocols. In deciding whether to transfer a detainee, ICE will take into consideration whether the detainee
is represented before the immigration court. In such cases, the Field Office Director will consider the
detainee's stage within the removal process, whether the detainee's attorney is located within reasonable
• driving distance of the facility, and where the immigration court proceedings are taking place.
Components
Meals are provided when transfers occur during
normally schedule meal times.
An A File or work folder accompanies the detainee when
transferred to a different field office or sub-office.
A Files are forwarded to the receiving office via
overnight mail no later than one business day following
the transfer.

o Acceptable

o Deficient

1:8]

OAt-Risk

Remarks: (Record Significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

71
G·324A Detention Inspection Fonn Worksheet for IGSAs . Rev: 01/04/05

Remarks

o Repeat Finding

•

The following items must be inspected for compliance with those Justice Core Standards not
covered by the ICE Detention Standards:
Standard - Policv Develooment and Monitoring

Item
1

2
3
4
5
6

7
8

Written Policy and Procedures are in place to provide staff with the necessary
information to operate and maintain the facility on a daily basis and in accordance
with local, state, and federal law
Written policy and procedure are reviewed annually and updated accordingly
Standard - ReoorUna Reauirement
The facility provides for a system of monitpring through internal audits and reviews
The internal administrative audit is separate from any external audits or reviews
Audit or inspection reports identity areas of concern, identity necessary corrective
action, and provide for a system follow-up
Audit and Inspection reports are maintained on file until at least the next review is
conducted
Standard - Direct SUQervision
To the extent Possible, physical plant design facilitates continuous personal contact
and interaction between staff and detainees in the housing unit and recreation /
leisure areas.
Written policies and procedures are in place that outline a comprehensive program
that promotes and encourages staff/detainee communications. A daily rotation
schedule should be established to ensure adequate staff coverage is provided
throughout the meal.
Standard - Cultural Diversitv
Staff are provided appropriate annual cultural diversity or sensitivity training. Such
training is designed and implemented in a fashion that will further enhance
staff members' ability to communicate with detainees in an effective manner.

DOJ Core Standards - Rating
IGSA's Only

~ Acceptable

Deficient

Repeat Deficiency

At-Risk

*Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c
l

'),? ~'7
/--·.")10

72
G-324A Detentiolllnspection Fonn Worksheet for IGSAs - Rev: 01104/05

[g)

[g)
[g)

[g)

0
0
0

[g)

OJ UetemlOn anrl I(emovat Uperations

lJYDepartment of Homeland Security
425 I St.reet, NW
Washington, DC 20536

January 23,2007

MEMORANDUM FOR:

John P. Torres
Director
Office Of Detention and Removal
(b)(6), (b)(7)c

FROM:
Deportation
cer
Memphis, Tennessee Sub-Office
SUBJECT:

CCA Mason, 2007 Annual Detention Review

The New Orleans Field Office, Office of Detention and Removal conducted a detention review of
the Blount County Jail on April!7, 2006. This review was conducted by
_
l1li This facility is used for detainees requiring housing over 72 hours.

Type of Review:
This review is a scheduled Operational Review to determine general compliance with established
Immigration and Customs Enforcement (ICE) National Detention Standards. The last review of this
facility was in December 2005.
Review Summary:
The facility is accredited by the American Correctional Association. CCA Mason serves the needs
of ICE officers for the Memphis, Tennessee Sub-Office. This facility received a good inspection
review in 2005.
Review Findings:
The following information summarizes those standards not in compliance. Each standard is
identified and a short summary provided regarding standards or procedures not currently in
compliance.
Compliant
Deficient
At-Risk
Non-Applicable -

37
0
0
1

>JUlJJv\...L •

.uvLvlll1Ull

.l.'\.t:;VH:~·~mmary

Kepon

Page 2

•

Standards Summary Findings:
This facility is compliance with all detention standards.
RIC Observations:
Facility Staff: The staff was extremely well versed in policy and procedure at this location. Staff
exhibited confidence and courtesy throughout the review. The team commends the efforts and
accomplishments of the Facility staff.
Security Staff: The staff exhibited professionalism. The staff was questioned regarding their policy
and procedures. The staff's initial orientation and continued training allows them to operate the
facility in a calm and orderly fashion. The Security staff was eager to display their abilities and
working knowledge of facility operations.

RI C Issues and Concerns
There are no concerns with this facility.

Recommended Rating and Justification:
It is the Reviewer in Charge recommendation that the facility receive a rating of "Good". The
facility fully implements ICE Detention Standards. The facility fully complies with all standards.

RIC Assurance Statement:
All findings of this review have been documented on Form G-324A and are supported by the written
documentation contained in the review file.

•

Department Of Homeland Security •
Immigration and Customs Enforcement
A. Type of Facility Reviewed
D I C E Service Processing Center
[ZJ
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

G. Accreditation Certificates
List all State or National Accreditation[s] received:
American Correctional Association
D Check box if facility has no accreditation[s]

B. Current Inspection
Type of Inspection
[ZJ Field Office 0 HQ Inspection
Date[s] of Facility Review
1-10-07 through 1-11-0~/

C. Previous/Most Recent Facility Review
Date[s] of Last Facility Review
12-21-05 through 12-22-05
Previous Rating
Superior [ZJ Good 0 Acceptable D Deficient 0 At-Risk

D. Name

Location of

Detention Facility Inspection Form
Facilities Used Over 72 hours

I .
(Coples
. must b e attached)
P ro blems IC ompJamts

The Facility is under Court Order or Class Action Finding
Court Order
D Class Action Order
The Facility has Significant Litigation Pending
Major Litigation
Life/Safety Issues
Check if None.

o
o
o

1 FaCllty
T H'lStory
Date Built
1990
Date Last Remodeled or Upgraded
1999
Date New Construction I Bedspace Added
1996
Future Construction Planned
DYes [ZJ No Date:
Current Bedspace
Future Bedspace (# New Beds only) .
600
Number:
Date:

Executive Officer

LJWJ'-''''U,-,,'

(List Office with oversight responsibilities)

Distance from Field Office

J. Total Facility Population
Total Facility Intake for previous 12 months
3,301
Total ICE Mandays for Previous 12 months
29,693

CIassl'filca f Ion L eveI (ICE SPCsand CDFs 0 my.
I )
L-2
L-1
L-3
I Adult Male
N/A
N/A
N/A
N/A
N/A
I Adult Female
N/A

L. Facility Ca pacity

Name of Team Member I Title I Duty Location
I I

my
F CDFIIGSA I n £onna f Ion 01
Contract Number
Date of Contract or IOSA
2-4-02
MS-02-D-07
Basic Rates per Man-Day
76,83
Other Charges: (If None, Indicate NI A)
42.02; ; ;
Estimated Man-days Per Year
29,693

Rated
Operational
Emergenq
Adult Male
520
520
800
Adult Female
80
80
100
Facility holds Juveniles Offenders 16 and older as Adults

'
M Average Dal'1Y P
opulatlOn

I Adult Male

I Adult Female

ICE
65.72
15.60

USMS
355.4
32.09

Other
57.08
0.40

Form G-324A (Rev. 8113/04) No Prior Version May Be Used After 10/1104

•
Significant Incident Summary Worksheet
For ICE to complete its review of your facility, the following information must be completed prior to the scheduled review dates. The
information on this form should contain data for the past twelve months in the boxes provided. The information on this form is used
in conjunction with the ICE Detention Standards in assessing your Detention Operations against the needs of the ICE and its detained
population. This form should be filled out by the facility prior to the start of any inspection. Failure to complete this section will
result in a delay in processing this report and the possible reduction or removal of ICE' detainees at your facility.

P
Assault:
Offenders on
Offenders l

With
WithoutW

Assault:
Detainee on
Staff

Number of Forced Moves,
incJ. Forced Cell moves 3

# Times Four/Fi ve Point
Restraints applied/used

N/A

Offender / Detainee Medical
Referrals as a result of
sustained.

N/A

# Medical Cases referred for

Outside Care
# Psychiatric Cases referred for
Outside Care

Escapes

Grievances:
# Received
# Resolved in favor of
Offender/Detainee
Reason (V=Vio!ent, I=IIIness,
S=Suicide, A=Attempted

Deaths

/
Psychiatric / Medical
Referrals

Any attempted physical contact or physical contact that involves two or more offenders
Oral, anal or vaginal penetration or attempted penetration involving at least 2 parties, whether it is consenting or non-consenting
Routine transportation of detainees/offenders is not considered "forced"
Any incident that involves four or more detainees/offenders, includes gang fights, organized multiple hunger strikes, work stoppages, hostage situations,
major fires, or other large scale incidents.

Form G-324A (Rev. 8/13/04) No Prior Version May Be Used After 10/1/04

•
1.

5.
6.
7.
8.
9.
10.
11.

12.
13.
14.
15.
16.
17.

Admission and Release
Classification System
Correspondence and Other Mail
Detainee Handbook
Food Service
Funds and Personal Property
Detainee Grievance Procedures
Issuance and Exchange of Clothing, Bedding. and Towels
Marriage Requests
Non-Medical Emergency Escorted Trip'
Recreation
Religious Practices
V
Work

Health Services
18.
19.
20.

22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.

Hunger Strikes
Medical Care
Suicide Prevention and Intervention
Terminal
Advanced Directives and Death

Detention Files
Disciplinary Policy
Emergency Plans
Environmental Health and Safety
Hold Rooms in Detention Facilities
Key and Lock Control
Population Counts
Post Orders
Security Inspections
Special Management Units (Administrative Segregation)
Special Management Units (Disciplinary Segregation)
Tool Control
Transportation (Land management)
Use of Force
Staff 1 Detainee Communication (Added August 2003)
Detainee Transfer (Added September 2004)

All findings (Deficient and At-Risk) require written comment describing the finding and what is necessary to meet compliance.

Form G-324A (Rev. 8113/04) No Prior Version May Be Used After 10/1/04

...

•
RIC Review Assurance Statement

By signing below, the Reviewer-In-Charge (RIC) certifies that all findings of noncompliance with policy or inadequate controls
contained in the Inspection Report are supported by evidence that is sufficient and reliable. Furthermore, findings of noteworthy
accomplishments are supported by sufficient and reliable evidence. Within the scope of the review, the facility is operating in
accordance with applicable law and policy, and property and resources are efficiently used and adequately safeguarded, except for the
deficiencies noted in the report.

s·

Reviewer-In-Charge: (Print Name)

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

•
J

Tennessee

uc:u

L.,

Print Name, Title, & Duty Location

Tennessee
Print N arne, Title, & Duty Location

Recommended Rating:

D Superior
IZJ Good
D Acceptable
D Deficient
D At-Risk

Comments:

Form G-324A (Rev. 8/13/04) No Prior Version May Be Used After 10/1/04

..
HEADQUARTERS EXECUTIVE REVIEW

I Review Authority
The signature below constitutes review of this report and acceptance by the
receipt of this report to respond to all findings and recommendations.
HQDRO EXECUTIVE REVIEW: (Please Print Name)

30 days from

Signature

Date

Final Rating:

D Superior
~Good

D Acceptable
D Deficient
D At-Risk
Comments:

The Review Authority concurs with the recommended rating of "Good". The Reviewer-In-Charge
has justified the rating.

Form G-324A (Rev. 8/1/01) No Prior Version May Be Used After 12/31/01

------------------------------------~

qlJice of Detention and Removal Operations
U.S. Department ofl-lomeland SeclII·ity
425 I Street, NW
Washington, DC 20536

M'li . ,~J
,

MEMORANDUM FOR:

I."

.' ,:;/

Trey Lund
Field Office Director
New Orleans Field
(b)(6), (b)(7)c

FROM:
Chief
Detention Standards
SUBJECT:

~VUlfJ.l.l,"l'"

West Tennessee Detention Facility

The annual review ofthe West Tennessee Detention Facility conducted on January 10,2007, in
Mason, Tennessee has been received. A final rating of Good has been assigned. No further action
is required and this review is closed.
The rating was based on the Reviewer-In-Charge (RIC) Summary Memorandum and supporting
documentation. The Field Office Director must now initiate the following actions in accordance
with the Detention Management Control Program (DMCP):

1) The Field Office Director, Detention and Removal Operations, shall notify the facility within
five business days of receipt of this memorandum. Notification shall include copies of the
Form G-324A, Detention Facility Review Form, the G-324A Worksheet, RIC Summary
Memorandum, and a copy of this memorandum.
2) The Field Office Director shall schedule the next annual review on or before
January 10,2008.
Should you or your staff have any questions regarding this matter, please contact
Detention and Deportation Officer, Detention Standards Compliance Unit
cc:

(b)(2)t.ow, (b)(6), (b)(7)c

The Habeas Citebook Ineffective Counsel Side