OffICe ofDetention and Removal Operations

U.S. DepartmeJIt of Homeland Seeurity
SOO 12- Street. SW
Washington, DC 20S36

u.s. Immigration
and Customs
Enforcement
MAR 1 S 2009
MEMORANDUM FOR:

FROM:
Director
SUBJECT:

Chatham County Detention Center Annual Review

The annual review of the Chatham County Detention Center conducted on July 8-10, 2008, in
Savannah, Georgia, has been received. A final rating of At-Risk has been assigned.
The CC-324A worksheets provided by the Reviewer-in-Charge (RIC) indicated the facility
was at-risk with the Environmental Health and Safety standard and deficient with the
Emergency (Contingency) Plans, and Key and Lock Control standards. A Plan of Action is
required to correct these deficiencies and the non-compliant areas in the Use of Force standard.
Additionally, the facility utilizes Electro Muscular Disruption Devices (EMDDs). The policy
regarding the use of EM DDs is currently being reviewed and no plan of action is required at
this time.
The facility should not be used until deficiencies are corrected prior to placement of
Immigration and Customs Enforcement (ICE) detainees.
The rating was based on the RIC Summary Memorandum and supporting documentation. The
Field Office Director must remedy the at-risk and deficient standards, and 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 ofthe Form CC-324A, Detention Facility Review Form, the CC-324A
Worksheet, RIC Summary Memorandum, and a copy of this memorandum.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE) 'tV'tVw.is;e,gQv

SUBJECT: Chatham County Detention Center Annual Review
Page 2

2) Based on the findings during the Annual Detention Review the Chatham County
Detention Facility is not to be utilized to confine ICE detainees and this review is
closed.
Should you or your staff have any questions regarding this matter, please contact
Yvonne Evans, Deputy Assistant Director, Detention Management Division at (202) 732-3470.
cc: Official File
b6,b7c
b2High

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE) www.ice.goy

I

~

I

ICE Detention Standards
Compliance Review
Chatham County Detention Center

July 8- 10, 2008

REPORT DATE - July 15, 2008

rea t iv e
c or r e c tiD n s

Contract Number: ODT-6-D-OOO 1
Order Number: HSCEOP-07-F-01016
b6

, Executive Vice President
Creative Corrections
6415 Calder, Suite B
Beaumont, TX 77706

, COTR
b6
U.S. Immigration and Custoins Enforcement
Detention Standards COinplianceUnit
801 I Street NW
Washington, DC 20536

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

.:; e r e a t i v e
~corrections

6415 Calder, Suite B • Beaumont, Texas 77706
409.866.9920 • www.correctionalexperts .com
Making aDifference!

July 15,2008
MEMORANDUM FOR:

FROM:

James. T. Hayes, Jr.
Acting Director
Office of Detention and Removal Operations
b6,b7c

Reviewer-In-Charge

~

'0 - ,

b6,b7c

-

Chatham County Detention Center Annual Detention Review

SUBJECT:

Creative Corrections conducted an Annual Detention Review (ADR) of the Chatham County
Detention Center, located in Savannah, Georgia, on July 8-10, 2008. The facility is operated by
the County of Chatham, which has a contract with Immigration and Customs Enforcement and
the United States Marshals Service. As noted on the attached documents, the team of Subject
Matter Experts included:
, Security;
, Health Services; b6,b7c
b6,b7c
b6
Safety and Environmental Health, and
Food Services.
b6,b7c
b6
b6,b7c
A review closeout was conducted With
, Jail Administrator, and b6,b7c
,
on
July
10,
2008,
and
included
a
discussion
of
all deficiencies and concerns noted
b6,b7c
review.

Life Safety Findine:s
There was a life safety finding at the Chatham County Detention Center that posed an immediate
danger for detainees and staff. The facility's smoke detector system was last tested in June 2007.
Thirty-nine of the smoke detectors failed that test. During this review the smoke detectors were
still inoperable. The situation in Housing Unit 5 is most critical as the smoke detectors are
inoperable and the unit does not have a sprinkler system. Additionally, the last comprehensive
facility test of the sprinkler system was conducted inJanuary 2007. The National Fire Alarm
Code NFPA 72 Testing and inspection r~uirements, Smoke Entry Testing-Table 1004.3, section
15(h) requires functional testing (smoke entry) upon initial and any subsequent reacceptance
testing, as well as annually thereafter. The Chatham County Detention Center is past due for the
b6,b7c
annual tests of these critical life-safety systems.
, Assistant Field Office Director, in
the Atlanta Field Office; was telephonically notified by the RIC on July 9, 2008.
Type of Review:
This review is an Annual Detention Standard Review to detennine general compliance with
established ICE National Detention Standards for facilities used for over 72 hours.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

. _. ..

1/4

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

Review Summary:
The facility is currently accredited by the American Correctional Association (ACA) and by the
National Commission on Correctional Health Care (NCCHC).

Standards Compliance:
The following inforination summarizes the standards reviewed and the overall compliance for
this review. The following statistical information outlined provides a direct comparison of the
2007 ADR and this ADR conducted for 2008.
July 10-12,2007 Review

July 8-10, 2008 Review

Compliant
Deficient
At-Risk
Not-Applicable

Compliant
Deficient
At-Risk
Not-Applicable

34

o
o
4

31
2
1
4

Environmental Health and Safety - At Risk
Every facility will contro,l flarruilable, 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 [NFP An, identification of incompatible materials, and safe-handling procedures.
•

•
•

The sprinkler and smoke detection system annual tests have expired. The last sprinkler
test was conducted in January, 2007. The last smoke detection system test was conducted
in June, 2007. The 39 smoke detectors which failed the previous test have not yet been
repaired.
Fire drills are only conducted and documented quarterly.
Sanitation standards are not posted in the barbering area.

Recommendations
•
•
•
•

Immediately repair all non-working smoke detectors.
Conduct the appropriate annual tests on the smoke detection and sprinkler systems, and
develop a plan to ensure future tests are conducted on schedule.
Schedule, conduct, and document monthly fire drills.
Post appropriate sanitation standards in the barbering area.

Emergency Contingency Plans - Deficient
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 SPCs and CDFs enter into agreement, via Memorandum ofUnderstanding
(MOU), with federal, local, and state agencies to assist in times of emergency.
•

There are no written procedures for staff to follow in relation to Internal Searches,
Detainee Transportation, and Civil Disturbances.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

2/4

•

There are no comprehensive plans to provide staff proper direction in the case of
Disturbances, Hunger Strikes, Hostage Situations, and Bom~ Threats.

•

The emergency procedures in place do not address the confidentiality and accountability
of the written plans; cooperative contingency plans with applicable agencies; preclusion
of detainees or detainee groups from exercising control or authority over other detainees;
and the locations of shut-off valves and switches for all utilities (water, gas, andlor
electric).

Recommendations
•

Establish comprehensive "stand:-alone" emergency plans for Internal Searches, Detainee
Transportation, Civil Disturbances, Disturbances, Hunger Strikes, Hostage Situations,
and Bomb Threats.

•

Provide specific direction within policy which addresses the confidentiality and
accountability.ofthe written plans.

•

Establish cooperative contingency plans with applicable agencies that can provide
emergency assistance to the facility.

•

Identify locations of shut-off valves and switches for all utilities (water, gas, andlor
electric) within the general section of the emergency plans.

Kev and Lock Control- Deficient
It is the policy of the ICE service to maintain an efficient system for the use, accountability, and
maintenance ofall keys and locks.
•

There is no single officer or department with overall responsibility for the control and
security of the facility's keys and locks.

•
b2High

•
•

b2High

All key rings do not·contain legible tags that identifying the key ring and denote the
number of keys on that ring. Additionally, the key rings are not crimped or soldered
which allows for the unauthorized removal of keys from the ring.

•
•

b2High

Broken keys are not immediately replaced and documentation is not maintained.

Recommendations
•

Establish a Security Officer position with the overall responsibility for the use,
accountability, and maintenance of all keys and locks in the facility. This person should

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)

3/4

complete an approved locksmith training program and should provide regular key and
lock accountability training to all staff.
•

•
b2High

•

•

Inspect keys daily to identify any broken keys. Immediately replace any broken or worn
keys and document their disposition and discontiriue the use of master keys.

Positive Programs and Services
The Chatham County Detention Center provides a number of educational, counseling, and selfhelp programs designed to prepare inmates and detainees for their return to the community.
These programs are taught be facility staff as well as contractors, and are valuable assets
in a correctional environment.
Recommended Rating and Justification

It is the Reviewer-in-Charge (RIC) recommendation that the facility receive a rating of "At Risk"
due to the previously noted Life Safety Issue. It is also recommended by the RIC that a Plan of
Action be requir.ed for this facility to identify and implement necessary corrective actions for the
deficiencies and RIC Concerns.

RIC Assurance Statement
All findings of this review have been <iocumented on the Det~ntion Review Worksheyt and are
supported by the written documentation contained in the review file .

.......

------------------------.---------~-------------

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

4/4

•......~

I C:_reative

~corrections

.

DETENTION FACILITY INSPECTION FORM
FACILITIES USED LONGER THAN 72 HOURS
A.

o
o
r8J

Other Charges: (If None, Indicate NIA)
,
; t8J N/A .
Estimated Man-days per Year
150

TYPE OF FACILITY REVIEWED
ICE'Service Processing Center
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

0

B. CURRENT INSPECTION

G. ACCREDITATION CERTIFICATES

Type of Inspection
Field Office t8J HQ Inspection
Date[s] of Facility Review
July 8-10, 2008

List all State or National Accreditation[s] received:
ACA and NCCHC

o
C.

o

D.

H. PROBLEMS / COMPLAINTS (COPIES MUST BE ATTACHED)

The Facility is under Court Order or Class Action Findmg
Court Order
0 ciass Action Finding
The Facility has Significant Litigation Pending .
Major Litigation
.
Life/Safetv Issues
r8J None

o
o

PREVIOUSfMOST RECENT FACILITY REVIEW

Date[s] of Last Facility Review
July 10-12, 2007
Previous Rating
Superior 0 Good 0 Acceptable. t8J Deficient

0

At-Risk

NAME AND LOCATION OF FACILITY

Name
Chatham County Detention Center
Address
1054 Carl Griffin Drive
City, State and Zip Code
Savannah, Georgia 31405
County
Chatham
Name and Title of Chief Executive Officer
(W arden/O rC/~uperintendent)
, Jail Administrator
b6, b7c
Telephone Number (Include Area Code)
912-652 b6,b7c
Field Office / Sub
ce (List Office with Oversight)
Atlanta 404-893- b6,b7c
Distance from Field Office
286
E.

J.

F.

K. CLASSIFICATION LEVEL (ICE SPCS AND CDFS ONLY)
~1

~3

L.

FACILITY CAPACITY
.~~~~-.~--------r----------Rated·
Operational
Emerg:ency
Adult Male
1356
1800 Plus
Adult Female
+ Portable
168
bunk
capability
[J Facility Holds Juveniles Offenders 16 and Older as Adults

M. AVERAGE DAILYFP;..:O;::P-:=U:::L=A:-:.T.::.:IO::o.Nr--=:::=-==--.__-=-___-,
Adult Male
Adult Female

CDFIIGSA INFORMATION ONLY

44.74

~2

Adult Male
Adult Female

I

13asicRates per Man-Day

TOTAL FACILITY POPULATION

Total Facility Intake for Previous 12 months
18,864
Total ICE Man Days for Previous 12 months
56

ICE INFORMATION

Contract Number
ACB4970017

0

I. FACILITY HISTORY
Date Built
1993
Date Last Remodeled or Upgraded
1994
Date New Construction / Bed Space Added
2007 Temporary Housing Unit 300 beds
Future Construction Planned
[81. Yes 0 No Date: 20 II Completion
Current Bed space
Future Bed Space (# New Beds only)
1524
Number: 768 Date: 2011

Name of Inspector (Last Name, Title and Duty Station)
/ Reviewer In Charge /
b6,b7c
Name of Team M!-!mber / Title / Duty LocatioJ?
SME / Security
b6,b7c
Name of Team Member / Title / Duty Location
b6
t / SME / HealthCare
Name of Team Member I Title I Duty Location
b6
SME / Food Service
Name of Team Member I Title / Duty Location
/ SME I Safety and Environmental Health
b6,b7c
Name of Team Member I Title I Duty Location

/

N/A

I Date of Contract or raSA

N.

October 1,1996

ICE

USMS

2
1

18
1

FACILITY STAFFING LEVEL

Security:
~

Other
1533
213

Support:
b2High

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 r,reative r,orrection~. TJ ,C (Rev. 12/&107)

______________~1 .

· SIGNIFICANT INCIDENT SUMMARY WORKSHEET
In order for Creative Corrections to complete its review of your facility, you must complete the following worksheet prior to your
scheduled review dates . This worksheet must contain data for the past twelve months. We will use this worksheet in conjunction with
the ICE Detention Standards to assess your detention operations with regard to the needs of ICE and its detainee population. Failure
to complete this worksheet will result ill a delay in processing this report, and may result in a reduction or removal of ICE detainees
from your facility.

p

Assault:
Offenders on
Offenders'

so-p 1-5

P

P

0

Assault:
Detainee on
Staff

Escapes
Grievances:

Psychiatric I Me<!ical Referrals
# Psychiatric Cases Referred
for Outside Care

49

51

70

54

p

p

P

P

0

0

3

2

4

o

0

0

0

o

0

0

0

o

0

0

0

o

0

0

0

Vv

V

3-M-V

V

2S-C

3S-C

17-C

10-C

o

0

0

0

o

0

0

0

o

0

0

0

757

710

882

825

Nrr

1'Iff

Nfl'

Nfl'

3-A

I-A

I-A 1-1

(I)

81

89

so

S5

13

5

s

12

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 detaineesfoffenders is not considered "forced"
.
Any incident that involves four or more detameesfoffenders, includes gang fights, organized multiple hunger strikes, work stoppages, hostage situations,
major fifes, or other large scale incidents.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 2 of5

DHSIICE DETENTION STANDARDS REVIEW SUMMARY REpORT
3. AT-RISK

7.
8.
9.
10.

22.
23.
24.
25.
26.
27.
28.
29.
30.
3 1.
32.
33.
34.
35.
36.
37.
38.

4. REPEAT

S.NOT

FINDING

APPLICABLE

Classificatipn 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

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 Detention)
Special Management Units (Disciplinary Segregation)
Tool Control
Transportation (Land management)
Use of Foree
Staff I Detainee Communication (Added August 2003)
Detainee Transfer (Added
2004)

ALL FINDlNGS OF DEFICIENT AND AT-RISK REQUIRE WRlITEN COMMENT DESCRmlNG THE FINDING AND
T IS NECESSARY TO REACH COMPUANCE.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 3 of5

RIC REVIEW AsSURANCE STATEMENT
By SIGNING BELOW, THE REVIEWER-IN-CHARGE (RIC) CERTIFIES THAT:
1.

ALL FINDINGS OF NON-COMPUANCE WITH POLICY OR INADEQUATE CONTROLS, AND FINDINGS OF NOTEWORTHY
ACCOMPLISHMENTS, CONTAINED IN THIS INSPECTION REPORT, ARE SUPPORTED BY EVIDENCE THAT IS SUFFICIENT AND
RELIABLE; AND
WITHIN THE SCOPE OF THIS REVIEW, THE FACILITY IS OPERATING IN ACCORDANCE WITH APPLICABLE LAW AND POLICY, AND
PROPERTY AND RESOURCES ARE BEING EFFICIENTLY UTILIZED AND ADEQUATELY SAFEGUARDED, EXCEPT FOR ANY
DEFICIENCIES NOTED IN THE REPORT.

2.

b6,b7c

b6,b7c

Title

Duty Location

Reviewer In Char e

'..-,;-.

.'

.... (

Jul 11,2008

"

..

..

,

"

Print Name, Title, & Duty Location
b6,b7c

',;

,'.

....,:

; TEAMl\'lE'~E~

, SME, Security

b6

. ,.

'.
-;.

SME, Food Service

Print Name, Title, & Duty Location

, SME, Health Services

RECOMMENDED RATING:

!, ,

Print Name, Title, & Duty Location
b6

Print Name, Title, & Duty Location

"

..

o
o
o
o

I:8J

b6,b7c

, SME, Safety and Environmtmtal Health

SUPERIOR
GOOD
ACCEPTABLE
DEFICIENT
AT-RISK

COMMENTS:
There were two deaths at the facility during the past year. Both deaths were the result of pre-existing illnesses prior to
incarceration and neither individual was an ICE detainee.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

40f4

HEADQUARTERS EXECUTIVE REVIEW

•

I Review Authority
The signature below constitutes review of this report and acceptance by the Review Authority. OIC/CEO will have 30 days from
receipt of this report to respond to all findings and recommendations.
IQDRO EXECUTIVE REVIEW: (please Print Name)
b6,b7c

Director

Final Rating:

D Superior
DGood

D Acceptable
D Deficient
C8J At-Risk

Comments:

The Review Authority concurs with the "At-Risk" rating. The facility is no longer authorized to confine
ICE detainees and this review is closed.

----------------------------------------------------------------------~~AA------

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

Creative Corrections
6415 Calder, Suite B
Beaumont, Texas 77706

Condition of Confinement Review Worksheet
(This document must be attached to each Inspection Form)

This Form to be used for Inspections of Facilities used longer than 72 Hours

reative
corrections
Detention Review Worksheet

IZI

o
o

Local Jail- IGSA
State Facility - IGSA
ICE Contract Detention Facility

Name
Chatham County Detention Center
Address (Street and Name)
1050 Carl Griffin Drive
City, State and Zip Code
Savannah, Georgia
County
Chatham
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
b6,b7c
Jail Administrator
Name and Title of Reviewer-In-Charge
b6,b7c

Date[sJ of Review
July 8-10, 2008
Type of Review
IZI Headquarters

o Operational
-

DSpecial Assessment

-

o Other

- ' ' - ' -- '-

FOR OFFICIALDsEONL Y (LAW ENFORCEMENT SENSITIVE)
C 2007 Creative Corrections, LLC (Rev. 12/8/07)

TABLE OF CONTENTS
-SECTION I. LEGAL ACCESS STANDARDS .............................................................................................................................. 3
ACCESS Td LEGAL MATERIALS .................................... ; ........................................................................................ : .................. .
GROUP PRESENTATIONS ON LEGAL RIGHTS ............................................................................................. ; ............................... .
VISITATION .................................................................... : ..................................... ; .................................................................... .
ACCESS TO TELEPHONES .............................................................................................. , ........................................................... .
SECTION II. DETAINEE SERVICES STANDARDS ................................................................................................................. 11
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 ESCORTED TRIPS ............................................................................................................................................ ..
RECREATION ..... : ............................................................ , .......................................................................................................... .
RELIGIOUS -PRACTICES ................................................................................................................................................. , ........... .
VOLUNTARY WORK PROGRAM ............................................................................................................................................... ..
SECTION fiI. HEALTH SERVICES STANDARDS ................................................................................................................... 33
HUNGER STRIKES .................................................................................................................................................................... ..
MEDICAL CARE .......................................................................................................................... : .............................................. .
SUICIDE PREVENTION AND INTERVENTION ........................................................................................................... _ ................. .
TERMINAL ILLNESS, ADVANCED DIRECTIVES AND DEATH .................................................................................................... ..
SECTION IV. SECURITY AND CONTROL STANDARDS ......................................................................................................... 41
CONTRABAND .......................................................................................................................................................................... ..
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 UNIT (ADMINISTRATIVE SEGREGATION) .......................................................................................... ..
SPECIAL MANAGEMENT UNIT (DISCIPLINARY SEGREGATION) ............................................................................................... ..
TOOL CONTROL ....................... :........................................ : ......................................... : ........................................ : .................... .
TRANSPORTATION (LAND) ....................................................................................................................................................... .
USE OF FORCE ............................................................................... : .......................................................................................... .
STAFFIDETAlNEE COMMUNICATIONS ....................................................................................................................................... .
DETAINEE TRANSFER STANDARD ................................................ ~ ............................................................................................ .

NOTE: 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 ACCEPTAB,LE WAS ACHIEVED.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 2

SECTION I. LEGAL ACCESS STANDARDS

I-----~-~--~-~

---~--

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
<0 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 3

ACCESS TO LEGAL MATERIALS
POLICY: FACILITIES HOLDING ICE DETAINEES SHALL'PERMIT DETAINEES AC<:;ESS TO A LAW r.,ffiRARX. AND PROVIDE LEGAL MATERIALS,
. FACILITIES, EQUll'MENT, DOCUMENTCOPYIN'G PIUViLEGES,ANb"TIffiOPPORTUNITY TO PREPARE LEGAL DOCUMENTS.
COMPONENTs

Y

N

NA

The facility provides a designated law library for detainee use.

[gj

0

0

0

[gj

0

[gj

0

0

[gj

0

0

[gj

0

0

0

[gj

0

[gj

0

0

[gj

0

0

[gj

0

0

[gj

0

0

[gj

0

0

[gj

0

0

The law library contains all materials listed in the "Access to Legal
Materials" Standard, Attachment A. The listing 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 typewriters and/or
computers and has sufficient supplies for daily use by the detainees.
In addition to the physical law library, detainees have access to the Lexus
Nexus electroniclaw library.
Where provided, the Lexus Nexus library is updated and is current.
Outside persons and organizations are permitted to submit published legal
material for incl~ion in the legal library. Outside published material is
forwarded and reviewed b'y ICE-'prior to inclusion.
There is a designated ICE or facility employee who inspects, updates, and
maintains/replaces legal materials and equipment on a routine basis.
Detainees are offered a minimum 5 hours per week in the law library.
D~tainees are not reQuired to for~go recreation time in liey of Iibr!!IY
~. Detainees facing a court deadline are given priority use of the law
library.
Detainees may request materials not currently in the law library. Each
request is reviewed and, where appropriate, an acquisition ,request is
Requests .for copies of court decisions are
timely initiated.
accommodated within 3 - 5 business days.
Detainees are permitted to assist other detainees, voluntarily and free of
charge, in researching and preparing legal documents, consistent with
security.
Illiterate or non-English-speaking detainees without legal representation
receive access to more than just English-language law books idler
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 ofa written request.

.125l

0

0

REMARKS

The Law Library is available to
inmates for legal research.
Upon receiving a request from
the inmate, research will be
conducted by Programs staff and
copies given to the inmates.
There is a log book of materials
provided and detainees sign for
all legal materials.
The facility's Law Library does
not contain all materials listed in
the "Access to Legal Materials"
Standard, Attachment A. The
listing of materials Standard,
Attachment A form is not posted
in the Law Library.

The Lexis Nexis is not updated,
and is not current.

Detainees are allowed to retain a
reasonable amount of personal
legal material in the general
population and in the Special
Management Unit.

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 4

ACCESS TO LEGAL MATERIALS

POLICY: FACll..ITIES HOLDING ICE DETAINEES SHALL PERMIT DETAINEES ACCESS TO A LAW LIBRARY, AND PROVIDE LEGAL MATERW.S,
FACILITIES, EQUIPMENT, DOCUMENT COPYING PRIVll..EGES, AND THE OPPORTUNITY TO PREPARE LEGAL DOCUM,ENTS ..
COMPONENTS

Detainees housed in Administrative Detention 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 libl"aIY fully documented.
Facility staff informs ICE Management when a detainee or group of
detainees is denied access to the law library or law materials.
Detainees who seek judicial relief on any matter are not subjected to
reprisals, retaliation, or penalties.

~ ACCEPTABLE

o DEFICIENT

Y

N

NA

~

0

0

~

[J

[}

~

0

0

~

0

0

OAT-RISK

REMARKS

o REPEAT FINDING

REMARKS:

The facility has legal materials for the ICE detainees, and provides documents and equipment when requested by detainees.
The facility's Law Library does not contain all materials listed in the "Access to Legal Materials" Standard, Attachment A. The listing
of materials on the Attachment A form is not posted in the Law Library.
1 July 10, 2008
b6,b7c
AUDlTOR'SSIGNATURE/DATE

r'

~

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

PageS

GROUP LEGAL RIGHTS PRESENTATIONS
-POLlGY~

FACILITIES HOUSING ICE DETAINEES SHALL PERMIT AUTHORIZED PERSONS TO MAKE PRESENTATIONS TO GROUPS OF DETAINEES FOR
THE PURPOSEOF INFORMING THEM OF U.S. IMMIGRATiON LAW AND PROCEDURES, CONSISTENT WITH THE SECURITY ANDORnERLYOPERATION
OF EACH FACILITY. ICE ENCOURAGES SUCH PRESENTATIONS, WlllCH INSTRUCT DETAINEES ABOUT THE IMMIGRATION SYSTEM AND THEIR
RIGHTS AND OPTIONS WITHIN IT.

!8'J CHECK HERE IF No GROUP PRESENTATIONS WERE CONDUCTED WITHIN THE PAST 12 MGNTHS. MARK STANDARD AS ACCEPTABLE
OVERAl.L AND CONTINUE ON Wlm NEXT PORTION OF WORKSHEET.
YES
No
NA
COMPONENTS
REMARKS
The Field Office is responsive to requests by attorneys and accredited
0
0
0
representatives for group presentations.
Upon receipt of concurrence by the Field Office Director, the facility or
authorized ICE Field Office ensures timely and proper notification to
0
0
0
attorneys or accredited representatives.
The facility follows policy and procedure when rejecting or requesting
modifications to objectionable material provided or presented by the
0
0
0
attorney or accredited representative.
Posters announcing presentations appear in common areas at least 48
0
0
0
hours in advance and sign-up sheets are available and accessible.
Documentation is submitted and maintained when any detainee is denied
0
0
0
pennission 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 provides a sufficient number of presentations so that all
0
0
0
detainees signed up may attend.
Detainees in segregation, unable to attend for security reasons, may
0
0
0
request separate sessions with presenters. Such requests are documented.
Interpreters are admitted when necessary to assist attorneys and other
0
0
0
legal representatives.
Presenters are afforded a minimum of one hour to make the presentation
0
0
0
and to conduct a Question-and-answer session.
Staff pennits presenters to distribute ICE-appr()ved materials.
0
0
0
Presenters are pennitted to meet with small groups of detainees to discuss
their cases after the group presentation. ICE or authorized detention staff
0
0
0
is 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 designee; and the reasons for
suspension are documented. The Headquarters Office for Detention and
0
D
0
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
0
0
0
at regular opportunities, at the request of outside organizations.
A copy of the Group Legal Rights Presentation policy, including
0
0
0
attachments, is available to detainees upon request
[8'J ACCEPTABLE

DDEFICIENT

D AT-RISK

D REPEAT FINDING

REMARKS:
There were no group presentations conducted within the past 12 months.

~

b6,b7c
(July 12. 2008
AUDITOR'SSIGNATURE/DATE /~ - '-

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 6

VISITATION
POUCY:ICESHALLPERMITDETAINEESTOVISITWITHFAMILY,FRIENDS,LEGALREPRESENfATIVES,SPEClALlNTERESTGROUPS,ANoTHENEWS
MEDIA.
y ..
·REMARKS .
..
.COMPONENTS
N
NA··
[8l
[]
[]
There is a written visitation schedule and hours for general visitation.
The visitation hours tailored to the detainee population and the demand
r8l
0
0
for visitation.
The visitation schedule and rules
are available to the public via
The visitation schedule and rules are available to the public.
r8l
0
0
television monitor in the
Visiting front lob~.
The hours for all categories of visitation are posted in the visitation
0
r8l
0
waiting area.
A written copy of the rules regulating visitation and the hours of
r8l
0
0
visitation is available to visitors.
A general visitation log is maintained.
r8l
0
0
The detainees are pennitted to retain personal property items specified
r8l
0
0
in the standard.
A visitor dress code is available to the public.
r8l
0
0
Visitors are searched and identified according to standard requirements.
r8l
0
0
Minors are allowed to visit if
The requirement on visitation by minors is complied with.
0
r8l
0
accompanied by an adult.
At facilities where there is no provision for visits by minors, ICE
arranges for visits by children and stepchildren, on request, within the
r8l
0
0
first 30 days.
After that time, on request, ICE considers a transfer, when possible, to a
facility that will allow minor visitation. At a minimum, monthly visits
r8l
0
0
are allowed.
Detainees in special housing are afforded visitation.
[8l
0
0
Legal :visitation is available seven (7) days a week, including holidays.
[8l
0
0
On regular business days legal visitation hours are provide for a
minimum of eight (8) hours per day, and a minimum of four hours per
r8l
0
0
day on weekends and holidays.
The detainees are given the
On regular business days, detainees are given the option of continuing a
option of continuing a meeting
r8l
0
0
meeting with a legal representative through a scheduled meal.
with a legal representative
through a scheduled meal.
Private consultation rooms are available for attorney meetings. There is
a mechanism for the detainee and his/her representative to exchange
r8l
0
0
documents.
[]
[8l
There are written procedures governing detainee searches.
[J
When strip searches are required after every contact visit with a legal
representative, the facility provides an option for non-contact visits with
r8l
0
0
legal representatives.
Prior to each visit, legal service providers and assistants are identified
r8l
0
0
per the standard.
The current list ofpro bono legal organizations is posted in the detainee
[8l
0
0
housing areas and other appropriate areas.
The decision to permit or deny a tour is not delegated below the level of
[8l
0
0
Field Office Director.
T"

-,

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 7

VISITATION

POLlcY:ICEsHALLPERMITDETAlNEESTOVISITWITHFAMILY,FRlENDS,LEGALREPRBSENrATIVES,SPECIALINTERESTGROUPS,ANDTHENEWS
MEDIA.

Provisions for NGO visitation, as stated in the Detention Standards, are
complied with.
Law enforcement officials who request to visit with a detainee are
referred to the ICE Field Office for approval.

[gJ

0

0

[gJ

0

0

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

[gJ

0

0

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

[gJ

0

0

o

[8J ACCEPTABLE

DEFICIENT

OAT-RISK

o

REPEAT FINDING

REMARKS:

Detainees are allowed to visit with friends, family, legal representatives, and members of the news media upon their requests.

b6,b7c

/ July 10. 2008

~

A

NATURE/DATE "{)---\.

--------.-.-----~-.

--,--"-

b6,b7c

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

~----------

-

--

---~

~---

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 8

- - - -- -- ---"---

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

..

DETAINEE TELEPHONE ACCESS
POUCy: ALL FACILITIES HOUSING ~9E DETAINEES WlLLPERMIT DETAINEES' REASONABLE AND EQUITABLE ACCESS TO TELEPHONES.
N
NA
REMARKS
COMPONENTS
Y
Detainees are allowed adequate
Detainees are allowed access to telephones during established facility
access to telephones during
~
0
0
waking hours.
facilit)' waking hours.
Policies, procedures and the
Upon admittance, detainees are made aware of the facility's telephone
detainee handbook indicate
~
0
0
access policy_
detainees are made aware of
their access to the telephones.
The access rules are posted in
Access rules are posted in housing units.
~
0
0
the 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
~
0
0
population.
Detainees are allowed to make
Telephones are provided at a minimum ratio of one telephone per 25
collect calls, and there are
~
0
0
detainees in the facility population.
adequate numbers of phones in
the housing units.
Telephones are inspected regularly by facility staff to ensure that they
~
0
0
are in good working order.
The facility administration promptly reports out-of-order telephones to
~
0
0
the facility's telephone service provider.
The facility administration monitors repair progress and takes
appropriate measures to ensure that required repairs are begun. and
~
0
0
completed timely.
Detainees are afforded a reason(lble degree ofprivacy for legal phone
r8l
0
0
calls.
A procedure exists to assist a detainee who is having trouble placing a
~
0
0
confidential call.
The facility provides the detainees with the ability to make non-collect
~
0
0
(special access) calls.
Special Access calls are at no charge to the detainees.
[J
~
0
The OIG phone number for
The OIG phone number for reporting abuse is programmed into the
detainees to report abuse is not
detainee phone system and the phone number was checked by the
programmed into the telephones,
0
~
0
.
inspector during the review.
and it is not posted in the
housing units.
The facility staff was aware of
the requirement for detainees to
In facilities unable to fully meet this requirement initially because of
have access to phone OIG
limitations of its telephone service, ICE makes alternate arrangements to
0
~
0
Within 24 hours of a request;
provide required aCcess within 24 hours of a request by a detainee.
however, there are no
arrangements made by ICE.
No restrictions are placed on detainees attempting to contact attorneys
and legal service providers who are on the approved "Free Legal
~
0
0
Services List".
Special arrangements are made to allow detainees to speak by telephone
0
~
0
with an immediate family member detained in another Facility.
(
]
Any telephone restrictions are documented.
J]
J81

------

- - - - - - --

- - - - ---

-- ---

-

--

- - - - - - - - - - - -- - - - - - -

- - - - ------

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 9

----~

--

-~-

DETAINEE TELEPHONE ACCESS
POLICY: ALL FAClLITIES HOUSING ICE DETAINEES WILL PERMIT DETAINEES' REASONABLE AND EQUITABLE ACCESS TO TELEPHONES.
COMPONENTS
The facility has a system for taking and delivering emergency detainee
telephone messages.

Y

N

NA

[8J

0
0

Emergency phone call messages are immediately given to detainees.

[8J

0
0

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.
Detainees in administrative detention and protective custody are
afforded the same telephone privileges as those in generalpo~ulation.
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.

[8J

d

0

[8J

0

0

[8J

0

0

[8j

0

0

[8j

0

0

£8l

0

0

~ ACCEPTABLE

o

DEFICIENT

OAT-RISK

REMARKS

o REPEAT FINDING

REMARKS:

The OIG phone number for detainees to report abuse is not programmed into the telephone system, and it is not posted in the housing
units.
The facility staffwas aware of the requirement for detainees to have the ability to phone OIG within 24 hours ofarequest; however,
ICE has not made arrangements to meet this requirement.
/July 10, 2008
b6,b7c
AUDITOR'SSIGNATURE/DATE

~~

n~

b6,b7c

1-------------- ---.-----------.--

---_ .. - - - -

- - - - - - - ------- - - -

------

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
C 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 10

SECTION II. DETAINEE SERVICES STANDARDS

- - - - - -- - - - -- - - - - - - - - - - - - - - -- - - - - - - -

--POR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page II

---~

-

----

ADMISSION AND RELEASE
POLICY: ALL DETAINEES WILL BE ADMJTI'E]) AND RELEASED IN A MANNER. THAT ENSURES THEIR: HEALTH, SAFETY, AND WELFARE. THE
~AbMISSlciNS PROCEDlrRE wILL, AMONG OTHER TIiINGS INCLUDE: MEDICAL SCREENING; A FILE-BASED ASSESSMENT AND CLASSIFICATION
PROCESS; A BODY SEARCH; AND A SEARCH OF PERSONAL BELONGINGS , WHICH WILL BE INVBNTORlED, DOCUMENTED, AND SAFEGUARDED AS
NECESSARY.

N

Y

COMPONENTS

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,
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, and the
detainee handbook.

t8J

0

0

Medical screenings are perfonned by medical staff or persons who have
received specialized training for the purpose of conducting an initial
health screening.
Each new arrival is classified according to criminal history and threat
levels. Criminal history is provided for each detainee by the ICE field
office.

t8J

0

0

t8J

0

0

All new arrivals are searched in accordance with the "Detainee Search"
~
U
standard. An officer of the same sex as the detainee conducts the search
and the search is conducted in an area that affords as much privacy as
possible.
Detainees are stripped searched only when cause has been established
!8l
0
and not as routine policy. Non-criminal detainees are not strip-searched
but are patted down, unless reasonable suspicion is established.
The "Contraband" standard governs all personal property searches.
f.:8J
0
IGSAslCDFs use or have a similar contraband 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 IGSAs for
t8J
0
every lost or missing property claim. Facilities forward all 1-387 claims
to ICE.
Detainees are issued appropriate and sufficient clothing and bedding for
~
0
the climatic conditions.
The facility provides and replenisheS personal hygiene items as needed.
t8J
0
Gender-specific items are available. ICE Detainees are not charged for
these items.
[]
All releases are properly coordinated with ICE using a Form 1-203.
!8l
[gI
(]
Staff completes paperwork/forms for release as required.
DEFICIENT
~ ACCEPTABLE
OAT-RISK

o

REMARKS
The detainees are processed
during Admission and
Orientation and they have the .
availability of pro bono legal
services, a schedule of program
services, visitation and
telephone usage. Additionally,
the detainees are issued a
detainee handbook that provides
sick call procedures, general
library and law library
procedures for access.
The detainees receive a medical
screening upon their arrival to
the facility.
Upon detainees arrival to the
facility they are classified
according to their criminal
history and threat levels. There
is an adequate classification
program at this facility.

NA

0
0
0

0

0
0
[
[

[J REPEAT FINDING

I~------------'----- -----.----------.~------.------.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 12

REMARKS:

Detainees are admitted and released in a manner that ensures their health, safety, and welfare. The A & 0 process covers a variety of
admission procedures to ensure the detainees are safe, to include a medical screening, classification, and a search of personal
belongings.

b6,b7c

/July 10, 2008

AUDITOR'SSIGNATURE/DATE

1'~.-b\ .

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 13

CLASSIFICATION SYSTEM

~~lt~iCA~~/~~ri:~~~=~~f~c~~: ~ !~~~ ~~~~~~:~~~~~Ri~::~ S=n:::~~;:
DETAINEES IN OTHER CATEGORJES

COMPONENTS
The facility has a system for classifying detainees. In CDFs and IOSAs,
an Objective Classification System or similar is used.

0

[gJ

The facility classification system includes:
• Classifying detainees upon arrival;
• Separating from the general popUlation those individuals who
cannot be classified upon arrival; and
• The first-line supervisor or designated classification specialist
reviewing every classification decision.
The intake/processing officer reviews work-folders, A-files, etc., to
identify and classify each new arrival.
Staff uses 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.
Housingassignments are based on classification-level.
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
IOSA's detainees may request 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 higher authority, such
as the Warden or ~quivalent.
The Detainee Handbook or equivalent for IGSAs explains the
classification levels, with the conditions and restrictions applicable to
each.

o DEFICIENT

[8] ACCEPTABLE

NA

N

Y

REMARKS

0

The facility has a viable system
for detainees to be classified.
The detainees are housed
appropriately and physically
separated from detainees in
other categories.
The classification of detainees is
computer-based and there are
adequate procedures to ensure
detainees are classified
appropriately.

[gJ

0

0

(gI

0

0

[gJ

0

0

I8J

[]

[J

[gJ

0

0

0

0

(gI

(gI

0

0

(gI

0

0

(gI

0

0

[gJ

0

0

[gJ

0

0

OAT-RISK

o

ICE detainees do not work at
this facility.

REPEAT FINDING

REMARKS:

ICE detainees do not work at this facility.

b6,b7c

/ July 10.2008

AUDITOR'S SIGNATURE I DATE

k 'i1-

1------------------

b6,b7c

- - - - - - --~----.--

- - - - - - - - - - - - - -- - - - - -

-----~-~--

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
@2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 14

CORRESPONDENCE AND OTHER MAIL
POLICY: ALL FACILITIES WILL ENSURE THAT DETAlNEF$ SEND AND RECEIVE CORRESPONDENCE IN A TIMELY MANNER, SUBJECf TO
LIMITATIONS REQUlRED FOR THE SAFETY, SECURITY, AND ORDERLYOPERATION OF TIm FACILITY. OTHER MAIL WILLim PERMITTED, SUBJECT TO
TIffi SAME LIMITATIONS. EACH FACILITY WILL WIDELY DISTRIBUTE ITS GUIDELINES CONCERNING CORRESPONDENCE AND OTHER MAIL.
YES
NA
REMARKS
COMPONENTS
No
The rules for correspondence and other mail are posted in each housing
The rules for correspondence
and other mail are provided to
or common area, or provided to each detainee via a detainee handbook.
l'8:I
0
0 each detainee via detainee
handbook.
The facility provides key infonnation in languages other than English; In
The detainee handbook is in
the language(s) spoken by significant numbers of detainees. List any
0
0 English and Spanish.
l'8:I
exc(')!)tions.
Incoming mail is distributed to detainees within 24 hours or 1 business
[8]
0
0
day~ after it is received and inspected.
Outgoing mail is delivered to the postal service within one business day
of its entering the internal mail system (excluding weekends and
0
l'8:I
0
holidays).
Staff does not open and inspect incoming general correspondence and
other mail (including packages and publications) without the detainee
l'8:I
0
0
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
0
0
l'8:I
Warden's prior written approval.
Staff does not inspect incoming special Correspondence for physical
contraband or to veritY the "special" status of enclosures without the
0
0
l'8:I
detainee present.
Staff is prohibited . from reading or copying incoming special
l'8:I
0
0
correspondence.
Staff is only authorized to inspect outgoing correspondence or other mail
without the detainee present when there is reason to believe the item
l'8:I
0
0
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
0
0
l'8:I
correspondence and is not read or copied.
The official authorizing the rejection of incoming mail sends written
The facility uses canines to
notice to the sender and the addressee.
inspect incoming mail on a daily
basis.
The mail room staff
l'8:I
0
sends Written notice to the
sender and the addressee.
The official authorizing censorship or rejection ofoutgoing mail provides
0
l'8:I
0
the detainee with signed written notice.
Staff maintains a written record of every item removed from detainee
0
l'8:I
0
mail.
The Warden or equivalent monitors staff handling of discovered
0
0
l'8:I
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
l'8:I
0
0
investigated. Standard procedure includes issuing a receipt to the
detainee.
Original identity documents (e.g., passports, birth certificates) are
immediately removed and forwarded to ICE staff for placement in Al'8:I
0
0
meso

0

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 15

CORRESPONDENCE AND OTHER MAIL

.POLICY: ALL FACILITIES WIIL ENSURE THAT DETAINEES SEND AND RECEIVE CORRESPONDENCE IN A TIMELY MANNER, SUBJECT TO
LWITATIONSREQUIRED FOR THE SAFETY, SECURITY, ANDORDERLYOPERATION OF 'i'HEFACILITY. OTHERMAlL wllLBE PERMIITED, SUBJECT TO
THE SAME LIMITATIONS. EACH FACILITY WILL WIDELY DISTRlDUTE ITS GUIDELINES CONCERNING CORRESPONDENCE AND OTHER MAlL.
Staff provides the detainee a copy ofhislher identity document(s) upon
[8'J
0
0
request
Staff disposes of prohibited items found in detainee mail in accordance
[8'J
with the "Control and Disposition of Contraband" Standard or the similar
0
0
prevailing policy in IGSAs.
Every indigent detainee has the opportunity to mail, at government
[8'J
expense, reasonable correspondence about a legal matter, in three one
0
0
ounce letters per week and packages deemed necessary by ICE.
The facility has a system for detainees to purchase stamps and for mailing
[8'J
all special correspondence and a minimum of 5 pieces of general
0
0
correspondence })er week.
The facility provides writing paper, envelopes, and pencils at no cost to
[8'J
0
0
ICE detainees.

o DEFICIENT

[8J ACCEPTABLE

OAT-RISK

o REPEAT FINDING

REMARKS:
The facility has an adequate procedure for detainees to send and receive correspondence in a timely manner.
I July 10, 2008
b6,b7c
AUDITOR'SSIGNATURE/DATE

~..

'0 .

b6,b7c

.

_ _ _ _ _ _ _--1

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 16

DETAINEE HANDBOOK
POLICY: EVERY OIC WILL DEVELOP A SITE-SPECIFIC DETAlNEE 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.
REMARKS
COMPONENTS
Y
N
NA
The detainee handbook is written in English and translated into
0
0
~
Spanish, or into the next most-prevalent Language(s).
The handbook is supplemented by the facility orientation video,
~
0
0
where one is provided.
All staffmembers receive a haridbook and training regarding the
~
0
0
handbook contents.
The handbook is revised as necessary and there are procedures in
place for immediately communicating any revisions to staff and
0
0 Page 1
~
detainees.
There an annual review of the handbook by a designated
0
0
~
committee or staff member.
The detainee handbook addresses the following issues:
Property taken during admission,
• Personal Items permitted to be retained by the detainee;
and
0
0 page 5. Items issued to inmate,
~
page 6
• Initial issue of clothes, bedding and personal hygiene
items.
The detainee handbook states in clear language the basic detainee
Rules and responsibilities of
~
0
0 inmates page 2
responsibilities.
The handbook clearly outlines the methods for classification of
detainees, explains each level, and explains the classification
~
0
0 Classification, page 6
appeals process.
The handbook states when a medical examination will be
0
0 Health care, page 21
~
conducted.
The handbook describes the facility, housing units, dayroorns, inpage 6
~
0
0 Classification,
dorm activities and special housing units.
Recreation. page 12
The handbook describes official count times and count
Counts, page 54
procedures; meal times and feeding procedures; procedures for
Food Service, page 20
medical or religious diets; smoking policy; clothing exchange
~
0
0 Tobacco, page 60
schedules; and, if authorized, clothes washing and drying
Laundry Services, page 24
procedures, and expected personal hygiene practices.
The handbook describe times and procedures for obtaining
,
disposable razors, and allow~ that detainees attending court will
0
0 Personal hygiene, page 27
18I
be afforded the ~rtunity to shave first.
The handbook describes barber hours and hair cutting
0
0 Haircuts, page 57
18I
restrictions.
The handbook describes the telephone policy; debit card
procedures; direct and free calls; locations oftelephones; policy
18I
0
0 Telephone, page 17 .
when telephone demand is high; .and policy and procedures for
.
emergency~hone calls.
The handbook addresses religious programming.
0
~
0 Religious Services, page 25
The handbook states times and procedures for commissary or
18I
0
0 COII1lllissary, page 16
vending machine usage, where available.
The handbook describes the detainee volun!<uy work program. .
[J
[ ] Work detail inmates. page 55
t8l
The handbook describes the library location and hours of
18I
0
0 Law library, page 19
operation and law lib@IYprocedures and schedules.
The handbook describes attorney and regular visitation hours,
18I
0
0 Visitation, page 13
. policies, and procedures.
[]
The handbook describes the facility contraband policy.
Searches, page 55
[J
t8l

FOR OFFICIAL USE ONL i (LAW ENFORCEMENT SENSITIVE)
(>

2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 17

DETAINEE HANDBOOK
POLICY: EVERY OIC WllL DEVELOP A SITE-SPECIFIC DETAINEE HANDBOOK TO SERVE AS AN OVERVillW OF, AND GUIDE TO, TIlE
DETENTION POLICIES, RULES, AND PROCEDURES IN EFFECT AT mE FACILITY. THE HANPBooK 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 TIlE FACILITY.
. _._.-- .
Y
N
NA
REMARKS
COMPONENTS
The handbook describes the facility visiting hours and schedule,
~
0
0 Visitation, page 13
and visiting rules and regulations.
The handbook describes the correspondence policy and
IZI
0
0 Mail, page 8
procedures.
The handbook describes the detainee disciplinary policy and
procedures, including:
• Prohibited acts and severity scale sanctions;
IZI
0
0 Disciplinary procedure, page 30
• Time limits in the Disciplinary Process; and
• Summary of the Disciplinary Process.
Grievance procedures, page 29.
The grievance section of the handbook explains all steps in the
grievance process - Including:
Staff/detainee availability to help
• Informal (if used) and formal grievance procedures;
during the grievance process is
not addressed
The
appeals
process;
•
In
CDF
facilities:
procedures
for
filing
an
appeal
of
a
•
Guarantee against staff retaliation
grievance with ICE.
for filing/pursuing a grievance is
• Staff/detainee availability to help during the grievance
not
addressed
0
IZI
0
process.
• Guarantee against staff retaliation for filing/pursuing a
How to file a complaint about
grievance.
officer misconduct with the
How
to
file
a
complaint
about
officer
misconduct
with
•
Department of Homeland
the Department of Homeland Security.
Security is not addressed
,-

~

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 assigrunents.
The handbook specifies the rights and responsibilities of all
detainees.

o DEFICIENT

I2SI ACCEPTABLE

~

0

0

Health care, page 21

IZI

0

0

Recreation, page 12

r8l

0

0

Personal hygiene, page 27

~

0

0

Rules and responsibilities, page 2

OAT-RISK

o REPEAT FINDING

REMARKS:
,

,

,

Staff/detainee availability to help during the grievance process, a guarantee against staff retaliation for filing/pursuing a grievance, and
procedures for filing a complaint about officer misconduct with the Department of Homeland Security are not addressed.

b6,b7c

1 July 10, 2008

AUDITOR'S SIGNATURE I DATE

~
0~ ~

b6,b7c

~

trr
fNl
'r--------:------mrR
OIT!F'VFlrl
C'l.IA[1["U
SEr:fruONL Y (LA W ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 18

FOOD SERVICE
POLICY: EVERY FAClLITYWILL PROVIDE DETAlNEES lNITSCAREWlTHNUTRITIOUS AND APPETlZlNG MEALS, PREPARED IN ACCORDANCEWlTH
THE HIGHEST SANITARY STANDARDS.
NA
REMARKS
COMPONENTS
Y
N
Food Service is under the direct
The food service program is under the direct supervISIon of a
supervision of Appleton,
professionallY trained and certified food service administrator.
Bresed, and Lawrence CABL)
Responsibilities of cooks and cook foremen are in writing. The Food
Management staff of Baton
Service Administrator (FSA) detennines the responsibilities of the Food
Rouge, LA. The staff consists
Service Staff.
0
tzJ
0
ofa Food Administrator, two
Assistants, five cooks, one
sanitation supervisor, and forty
detainee workers.
The Cook Supervisor is on duty on days when the FSA is off duty and
tzJ
0
0
vice versa.
The FSA provides food service employees with training that specifically
addresses detainee-related issues.

..

•

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 knives not in a secure cutting room are physically secured to the
workstation and staff directly supervises detainees using knives at these
workstations. Staff monitors the condition of knives and dining utensils.

Il?J

0

0

jgj

0

0

jgj

0

0

ot
b2High

When necessary, special procedures govern the handling offood items
that pose a security threat.
Operating procedures include daily searches (shakedowns) of detainee
work areas.

The FSA monitors staff implementation of the facility's population
counts procedures. Staff is trained in count 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 llP-to-date.
The Cook Foreman or equivalent instructs newly assigned detainee
workers in the rules and procedures of the food service department.
During orientation and training session(s), the CS explains and
demonstrates:
• Safe work practices and methods;
• . Safety features of individual products/pieces ofequipment; and
• Training covers the safe handling ofhazardous material[s] the
detainees are likel~ to encounter in their work.
The Cook Supervisor documents all training in individual detainee
detention meso

jgj

0

0

Il?J

0

0

18J

0

0

jgj

0

0

jgj

0

0

18J

0

0

tzJ

0

0

18J

0

0

Daily shakedowns of all food
service work areas are being
conducted. The shift
commander checks the area
daily prior to the detainees being
released.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
10 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 19

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
Y
N
NA
REMARKS

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 regulations regarding detainee pay.
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.

~

D

D

~

D

D

D

D

~

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.

~

D

D

~

D

D

~

D

D

The FSA has established procedures to ensure that items on the mastercycle menu are prepared and presented according to approved recipes.
The Cook Foreman has the al/thorityto change menu items ifnecessary.
• 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 line.
• Changes to the planned common-fare menu can be made atthe
facility level;
• Hot entrees are offered three times a week;
• The common-fare menus satisfy nutritional recommended daily
allowances (RDAs);
• Staff routinely providehoUvater for in~verages and
foods;
Common-fare meals are served with:
0
• Disposable plates and utensils .
• Reusable plates and utensils .
• Staff use separate cutting boards, knives, spoons, scoops, etc.,
to prepare the common-fare 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, provides the FSA a schedule of the ceretnonial meals for the
following calendar year.

~

D

D

~

D

D

~

D

D

~

D

D

0

~

D

~

D

D

~

D

D

This facility does not have a
cafeteria style operation other
than the Officers' Dining Room.
The facility has a 28-day menu
cycle.

A registered dietitian conducts a
nutritional analysis of the master
cycle menu.

There is no common-fare menu
available to detainees. All
religious diet requests are
referred to the chaplain for
approval. Facility offers a pork
free menu and lacto-ovo
vegetarian for religious diets.
There are currently fifteen
detainees on an alternate
vegetarian religious diet.

The chaplain provides the FSA
with a list of all ceremonial
meals.

I----------------__------------------------------------------------~
FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
10 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 20

FOOD SERVICE
POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CAREWITIINUTRITIOUS AND APPETIZING MEALS, PREPARED IN ACCORDANCE WITH
THE HIGHEST SANITARY STANDARDS.
-y
COMPONENTS
REMARKS
N
NA

The common-fare 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-Fate 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 Fridays during Lent.
The food service program addresses medical diets.

Satellite-feeding programs follow guidelines for proper sanitation.
Hot and cold foods are maintained at the prescribed, "safe"
temperature(s) while being served.

IZI

Standard operating procedures include weekly inspections of all food
service areas, including dining and food-preparation areas and
equipment.
• Who conducts the inspections?
Equipment is inspected for compliance with health and safety codes and
regu!ations.
• When was the most recent inspection?
• Which agency conducted the inspection?
Reports of discrepancies are forwarded to the Warden or designated
department head, and corrective action is scheduled and completed.

D

The Food Service Department
offers ten different medical diets
and currently has 214 detainees
on prescribed medical diets.

IZI

D

D

IZI

D

0

IZI
All meals are provided in nutritionally adequate portions.
Food is not used to punish or reward detainees based upon behavior.
The food service staff instructs detainee volunteers on:
• Personal cleanliness and hygiene;
• Sanitary techniques for preparing, storing, and serving food;
and
• The sanitary operation, care, and maintenance of equipment.
Everyone working in the food service department complies with food
safety and sanitation requirements.

D

There is no common fare
program available; however,
accommodations are made to
meet the detainees' religious
needs at prescribed times of the
year.

D

0

D

_l8i

[]

0
1]

IZI

D

0

IZI

IZI

D

0

IZI

0

0

IZI

D

0

IZI

D

0

Standard procedure includes checking and documenting temperatures of
all dishwashing machines after each meal.

IZI

D

0

On site observation of two meals
indicates foods are maintained at
prescribed safe temperatures and
served within one hour of tray
make-up.

On site observation during the
review confmned that all food
service staff and volunteer
workers were in compliance
with food safety and sanitation
requirements.

Facility was inspected by the
Georgia Department of Human
ResourceS in May 2008.

A review of two months logs
and onsite observation indicates
that dish machine temperatures
are being checked during each
meal.

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 21

FO.OD SERVICE
POLICY: EVERY FACILITY Wilt PROVIDE DETAINEES IN ITS CARE WITH NUTRITIOUS AND APPETlZlNG MEALS, PREPARED IN ACCORDANCE WITH
..
THE HIGHEST SANITARY STANDARDS.
COMPONENTS
Y
REMARKS
N
NA

Staff documents the results of every refrigerator/freezer temperature
check.

The cleaning schedule for each food service area is conspicuously
posted.
Procedures include inspecting all incoming food shipments for damage,
contamination, and pest infestation.
Storage areas are locked when not in use.

[8J ACCEPTABLE

o DEFICIENT

A review of two months of
temperature check logs indicates
that temperatures are being
checked and logged three times
per day. Temperatures where
within food service guidelines
during the review.

lZl

0

0

lZl

0

0

lZl
lZl

0
0

0
0

OAT-RISK

o REPEAT FINDING

REMARKS:

There is no common-fare menu available to detainees. The facility does offer a pork free menu and a lacto-ovo vegetarian menu for
religious diets.

b6,b7c

/July 10, 2008

AUDITOR'SSIGNATURE/DATE

'k
0-

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 22

FUNDS AND PERSONAL PROPERTY
POLICY: All FACILITIES WILL IMPLEMENT PROCEDURES TO CONTROL AND SAFEGUARD DETAINEES' PERSONAL
.. PROPERlY. PROCEDURES WlLL

PROYIDE'FOR THE SECURE STORAGE OF FUNDS, VALUABLEs, BAGGAGE AND OTHER PERSONAL PROPERlY; THE DOCUMENTATION AND
RECEIPTING OF SURRENDERED PROPERlY; AND THE INITIAL AND REGULARLY SCHEDULED INVENTORYING OF ALL FUNDS, VALUABLES, AND
01HER PROPERTY.

o STANDARD NA: (lGSA ONLy) CHECK TIDS BOX

IF ALL ICE DETAINEE FUNDS, VALUABLES AND PROPERTY ARE HANDLED ONLY
BY THE ICE FIELD OFFICE OR SUB-OFFICE lNCONTROL OF THE DETAINEE CASE.
NA
REMARKS
COMPONENTS
YES
No
Chatham County Detention
Detainee funds and valuables are properly separated, stored, and are
Center (CCDC) Policy 04-20-01
accessible only by designated supervisor(s).
Services, Inmate
0 Institutional
~
0
Personal Property insures that
detainee funds and valuables are
properly separated and stored.
The facility will not accept
Detainees' large valuables are secured in a location accessible to
designated supervisor(s) or processing staff only.
~
0
0 excess property or large
valuables
Staff itemizes the baggage and personal property of arriving detainees
(including funds and valuables). For IGSAs and CDFs, using a personal
~
0
0
~roperty inventory form that meets the ICE standard?
cg]
[1
[1
Staff forwards an arriving detainee's medication to the medical staff.
Audits of baggage and non-valuable property occur each quarter and
CCDC Post Orders or Policy did
audits are logged and verified.
not require a quarterly audit of
[2SJ
0 baggage and non-valuable
0
property. Policy was changed to
meet ICE Detention Standards.
Two officers are present during the processing of detainee funds and
Two officers are not present;
valuables during in-processing to the facility. Both officers verifY funds
however, funds. and property are
and valuables.
verified in the presence of the
transporting officer and the
0
I8J
0 funds are verified by the cashier.
Detainees sign and receive a
copy of the Inmate Property
Received Form
.
Staff searches arriving detainees and their personal property for
0
I8J
0
contraband.
Staffprocedures follow written policy for returning forgotten property to
I8J
0
0
detainees.
Property discrepancies are immediately reported to the COEO or Chiefof
I8J
0
0
Security.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 23

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, BAC',oAGE AND OTHER PERSONAL PROPER~Y; TIIE.DOCU},,!ENTATIO~ AND
RECEIPTING OF SURRENDERED PROPERTY; AND THE INITIAL AND REGULAIU.y 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 Sus-OFFICE IN CONTROL OF THE DETAINEE CASE.

Staff follows written procedures when returning property to detainees.

CDF/IGSA 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; and
•
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 property to ICE.

~ ACCEPTABLE

I:8J

o

o

o

o

o

o

o

o

o

o DEFICIENT

CCDC Policy did not contain
written procedures for returning
property to detainees. The
InmatelDetainee handbook
states that detainees must take
their property or make
arrangements to have 1t picked
up or shipped. Ifafter forty-five
days the property has not been
picked up the property will be
destroyed or donated. Policy
was changed to meet ICE
Detention Standards. Policy was
changed to contact ICE Field
Office.

Facility policy or post orders did
not outline procedures for
notification of an out-processed
detainee via certified mail that
he/she left property in the
facility. Policy was changed to
contact ICE Field Office.
There is no procedure for
forwarding abandoned property
to ICE. Policy does not address
the procedure for disposing of
abandoned property. Policy was
changed to contact ICE Field
Office.
REPEAT FINDING

REMARKS

.
.
.
.
.
Chatham County Detention Center (CCDC) Policy 04-20-0 I, Institutional Services, Inmate Personal Property, was changed during the
review to comply with ICE Detention Standards. The change requires staff contact the ICE Field Office with any problems that arise.
Facility management staff should continue to monitor implementation of this policy and procedure change.

b6,b7c

July 10, 2008

AUDITOR'S SIGNATURE I DATE

~
1·'

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev, 12/8/07)

Page 24

DETAINEE 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 PRESCRlBED TIME FRAME. AMONG OTHER THINGS, A
GRIEVANCE WILL BE PR,OCESSED, INV}:}STIGATED. AND DECIDED (SUBJEcT.TO APPEAL)'IN ACCORDANCE WITH THE SOPS; A GRIEVANCE
COMMrnE wiLL CONVENE AS PROVIDED IN THE SOPS. STANDARD PROCEDURE WILL lNCLUDE PROVIDING THE DETAlNEE WITH AWRITTEN
RESPONSE TO ANY FORMALGRIEVANCE, WHICH WILL lNCLUDE THE BASIS FOR THE DECISION. THE FACILITY \\IILLALSO ESTABLISH STANDARD.
PROCEDURES FOR HANDLING EMERGENCY GRIEVANCES. ALL GRIEVANCES WlLL RECEIVE SUPERVISORY REVffiW. REpRISAL AOAINSTTHE FILER
OF AORIEVANCE WILL NOT BE TOLERATED.
Y
N
NA
REMARI<S
COMPONENTS
Written procedures provide for the infonnal resolution of oral
grievances (Not mandatory).
3/19/08 Grievance Procedures,
0 section A
18l
0
If
yes,
the
detainee
has
up
to
five
days
within
which
to
make
•
his/her concern known to a member of the staff.
A detainee's right to seek help
Detainees have access to the grievance committee (or equivalent in
from other detainees or facility
IGSA), using fonnal procedures.
staff when preparing a grievance
• Detainees may seek help from other detainees or facility staff
is not addressed.
when preparing a grievance.
Illiterate,
disabled,
or
non-English-speaking
detainees
receive
0
~
0
•
Special assistance for illiterate,
special assistance when necessary.
disabled, or non-English-speaking
detainees is not addressed.
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
lodged a complaint:
• If yes explain.
Procedures include maintaining a Detainee Grievance Log.
• If not, an alternative "acceptable record keeping system is
maintained.
• "Nuisance complaints" are identified in the records.
• For quality control purposes, staff document nuisance
complaints received but not filed.
Staff is required to forward any grievance that includes officer
misconduct to a higher official or, in a CDF/IGSA facility, to ICE.

o

[8J ACCEPTABLE

DEFICIENT

18l

0

0

0

18l

0

18l

0

0

18l

0

0

OAT-RISK

3/19/08 Grievance Procedures, II
A2
No cases of staff harassing,
disciplining, or otherwise
retaliating against detainees for
filing grievances were reported.

o

REPEAT FINDING

REMARKS:

A detainee's right to seek help from other detainees or facility staff when preparing a grievance is not addressed.
" Special assistance for illiterate, disabled, or non-English-speaking detainees is not addressed.

b6,b7c

AUDITOR'S

1July 10. 2008
NATURE 1DATE

~-

/~.

b6,b7c

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page2S

ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS
POLICY: ICE REQUIRES THAT ALL FACILITIES HOUSING ICE DETAlNEES PROVIDE CLEAN CLOTHlNG, BEDDING, LINENS AND TOWElS TO EVERY
ICEDETAlNEE UPON ARRIVAL. FURTHER, FACILITIES SHALL PROVIDE ICE DETAlNEES WITH REGULAR EXCHANGES OF CLOTHING, LINENS, AND
TOWELS FOR AS LONG AS THEY REMAIN IN DETENTION.
....
No.
REMARKS
NA
YES
COMPONENTS
The facility has a policy and procedure for the regular issuance and
4123/04 Clothing and Bedding
exchange of clothing, bedding, linens, and towels.
0
t8I
0
Supplies
The
supply
of
these
items
exceeds
the
minimum
required
for
the
•
number of detainees.
All new detainees are issued clean, temperature-appropriate, presentable
clothing during in-processing. Detainees receive:
• One uniform shirt and one pair of uniform pants, or one
Socks and underwear are not
j).lmpsuit;
t8I
0
0 issued to detainees.
• One pair of socks;
• One pair of underwear (Daily change); and
• One pair of facility-issued footwear.
Additional clothing is available for changing weather conditions, or as
t8I
0
0
seasonallY aJlllfopriate.
New detainees are issued clean bedding, linens, and towels. They receive
at a minimum:
• One mattress;
• One blanket;
• Two sheets;
\Xl
0
0
• One pillowcase;
• One towel; and
• Additional blankets are issued based on local weather
conditions.
Detainees assigned to special work areas are clothed in accordance with
\Xl
0
0 4123/04 II A 10
the requirements of the job.
Detainees are provided clean clothing, linen and towels.
Socks and undergarments are
• Socks and undergarments - exchanged daily.
washed weekly.
• Outer garments - twice weekly.
[8]
0
0
• Sheets - weekly.
Outer garments are washed
• Towels - weekly.
weekly.
• Pillowcases - weekly.
Food service detainee volunteer workers are permitted to exchange outer
food services supervisor
[8]
0
0 The
garments daily.
indicated this was allowed.
Volunteer detainee workers are permitted to exchange outer garments
[8]
0
0
more frequently.
,

o DEFICIENT

[8J ACCEPTABLE

OAT-RISK

o REPEAT FINDING

REMARKS:

Socks and underwear are not issued to detainees
Socks and undergarments are washed weekly instead of daily
Outer garments are washed weekly instead of twice weekly

b6,b7c

/ July 10. 2008
NATURE/DATE

~l_
U

b6,b7c

-

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
CO 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 26

MARRIAGE REQUESTS
POLICY:· ALLDETAJNEE MARR1ACJE REQUEsTS WILL RECEIVE CASE-BY-CASE CONSIDERATION FROMICE MANAGEMENT.
. NA
REMARKS
Y
N
COMPONENTS

The Field Office considers detainee marriage requests on a case-by-case basis.

[8J
The Field Office Director reviews every marriage request rejected by a
Warden/OlC or IOSA. Rejections are documented.

It is standard practice to require a written request for pe_rmission to marry.
The written request includes a signed statement or comparable documentation
from the intended spouse, confirming marital intent.

0

0

[8J

0

0

J81

1J

[]

[8J

0

0

[8J

0

0

[8J

0

0

0

0

[8J

The Warden/OlC provides a written copy of his/her decision to the detainee
and his/her legal representative.

When permission is denied, the Warden/OlC states the basis for his/her
decision.

The Warden/OlC provides the detainee with a place and time to make
wedding arrangements.

t8l ACCEPTABLE

DOEFICIENT

D

At·RISK

The Atlanta Field Office will
consider detainee marriage
request on a case-by-case basis.
Facility does not allow
marriages per the facility
director. Requests for marriage
will be referred to the FOD
There is not a facility policy that
requires a signed statement from
the intended spouse, confmning
marital intent. Policy was
changed to contact the ICE Field
Office.
There is no policy or procedure
in place for marriage request
therefore notifications are not
made to the detainee's legal
representative. Policy was
changed to contact the Atlanta
Field Office.
There is no policy that requires
the Warden/OIC to state the
basis for his decision on
marriage request. Policy was
changed to contact ICE.
The Jail Administrator does not
provide a place and time to
make wedding arrangements.
Interview with supervisory staff
reveals that any request for
marriage would be denied. This
facility discourages marriages
and detainees would be
. transferred from this facility.
ICE would be contacted to make
the decision for transfer.

D REPEAT FINDING

REMARKS:

The facility does not have a policy or procedure that addresses marriage requests. Policy, 03-19-02, Inmate Rights, Access to Programs
and Services, was changed during the review to forward all detainees request for marriage to the appropriate federal authorities.

b6,b7c

I July 10, 2008
NATURE/DATE

L~
~ ~"-

b6,b7c

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
CO 2007 Creative Corrections, LLC (Rev. 1218/07)

Page 27

NON-MEDICAL EMERGENCY ESCORTED TRIPS
POPc:~:,THE I¥MIGRATIO.N ~ CUSTOMS Em-ORCEMENT(lCE) MAY ,PROVIDE DETAINEES WITH STAFF-ESCORTED TRIPS'INTOTHE
COMMUNITY FOR THE PURPOSE OF VISITING CRrI'ICALLYILL MEMBERS OF THE DETAINEE'S IMMEDIATE FAMILY, ORFORATIENDING FUNERALS.

[8j STANDARD N/A:

CHECK TIDS BOX IF ALL ICE NON-MEDICAL EMERGENCY ESCORTED TRIPS ARE HANDLED ONLY BY THE ICE
FIELD OFFICE OR SUS-OFFICE IN CONTROL OF THE DETAINEE CASE.
COMPONENTS
YES
No
NA
REMARKS
The Field Office Director considers and approves, on a case-by-case
basis, trips to an immediate family member's:
0
0
0
• Funeral; or
• Deathbed
The facility recognizes mother, father, brother, sister, spouse, child, step0
0
0
parent and foster parent as "immediate family".
The !GSA facility notifies ICE of all detainee requests for non-medical
0
0
0
escorts.
The detainee's Deportation Officer reviews the file before forwarding a
detainee's request, with recommendation, to the approving official. Each
0
0
0
recommendation addresses the individual's suitability for travel; e.g., 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
0
0
0
authority to issue instructions for completion of the trip.
Escorting officers have the discretion to increase or decreaSe minimum
restraints in accordance with written procedures and classification level of
0
0
0
the detainee.
Escort officers are precluded from accepting gifts/gratuities from a
0
0
0
detainee or detainee's relative or friend for any reason.
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;
0
0
• Do not purchase, possess, use, consume, or administer narcotics, 0
other drugs, or intoxicants;
• Make no unauthorized phone calls; and
• Know they are subject to search, urinalysis, breathalyzer, or
comparable test upon return.
Standard procedure requires the immediate return to the facility of any
0
0
0
detainee who violates trip rules.

Il

o

o ACCEPTABLE

DEFICIENT

OAT-RISK

[l

o

REPEAT FINDING

REMARKS:

All ICE non-medical emergency escorted trips are handled only by the ICE sub-office in control ofthe detainee case.

/ July 10. 2008
b6,b7c
AUDITOR'S SIGNATURE I DATE

-~ ""

r

b6,b7c

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 28

RECREATION
POLICY: IT IS ICE POLICY TO PROVIDE ACCESS TO RECREATIONAL PROGRAMS AND ACTNITrnS TO ALL ICE DETAINEES, TO THE EXTENT
POSSIDLE, UNDER CONDmONS OF SECURITY AND SUPERVISION THAT PROTECT THEIR SAFETY AND WELFARE.
y
COMPONENTS
NA
N
REMARKS
Chatham County Detention·
The facility has a recreation program and facility.
Center (CCDC) Policy 5-29-01
Inmate Programs, Recreation,
Activities, Equipment, and
0 Facilities, allows all detainees in
IZI
0
general housfng units
accessibility to recreational
opportunities and equipment at
least one hour per day.
A recreational specialist (for facilities with more than 350 detainees) tailors
Three recreational specialists
IZI
0
0
are assigned for Units 5 and 6.
the program activities and offerings to the detainee population.
Regular maintenance keeps recreational facilities and equipment in good
IZI
0
0
condition.
There are no detainee recreation
The recreational specialist or trained equivalent supervises detainee
[8J
0
0
recreation workers.
workers.
The recreational specialist or trainee equivalent oversees recreation
The recreational specialist
prograrris for special housing units (SHU) and special-needs detainees.
oversees recreation programs for
special housing units (SHU) and
special-needs detainees in Units
[8J
0
0
5 and 6. Detention Deputies
assigned to the living units
supervise recreation in Unit 2
SHU.
Dayrooms offer sedentary activities e.g., board games cards television.
IZI
[8J
Outside activities are restricted to limited-contact sports.
Each detainee has the opportunity to participate in daily recreation.
IZI
0
Detainees have access to recreation activities outside the housing units for
All units other than Unit 6 are
at least one hour daily, 5 days a week.
receiving at least one hour of
recreation
a minimum of 5 days
[8J
0 per week. Unit 6 receives
0
recreation 4 days per week for
one hour and fifteen minutes.
Staff checks all items for damage and condition when equipment is
[8J
0
0
retumed.
Staff conducts searches of recreation areas before and after use.
><
All recreation areas under constant staff supervision.
Supervising staff is equipped with radios.
><
The facility provides detainees in the SHU at least one hour of outdoor
Detainees in the SHU do not
receive
at least one hour of
recreation time daily, five times per week.
[8J
0
0
outdoor recreation time at least
five times.per week.
Detainees in disciplinary/administrative segregation receive a written
IZI
0
0
explanation when a ~anel revokes hislher recreation privileges.
[8J
Special programs or religious activities are available to detainees.
Volunteers are required to sign a waiver ofliability before entering a secure
[8J
0
0
portion of the facility where detainees are present.
[8J
Visitors, relatives or friends are not allowed to serve as volunteers.
!8l1f outdoor recreation is offered, check this bOL No further information is required when outdoor recreation is offered.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 29

RECREATION
POllCY: IT IS ICE POLICY TO PROVIDE ACCESS TO RECREATIONAL PROGRAMS AND ACTIVITIES TO ALL ICE DETAINEES, TO THE EXTENT
POSSmLE, UNDER CONDmONS OF SECURITY AND SUPERVISION THAT PROTECf THEIR SAFETY AND WELFARE.

If the facility has no outside recreation, are detainees considered for
transfer after six months?
• If yes, written procedures ensure timely review of all eligible
detainees.
Case officers make written transfer recommendations about every sixmonth detainee to the OlC.
The OIC documents all detainee-transfer decisions, whether yes or no.
The detainee's written decision for or against an offered transfer
documented in hislher A-file.
Staff notifies the detainee's legal representative of hislher decision to
accept/decline a transfer.
If no recreation is available, the ICE Districts routinely review transfer
eligibility for all detainees after 60 days.
The A-file of every detainee who is held more than 60 days without
access to recreation contains either a transfer-waiver signed by the
detainee, or the OlC's written detennination of the detainee's ineligibility
for transfer.
The detainee's legal representative is notified of the detainee'S/OIC's
decision.

o

l3J ACCEPTABLE

DEFICIENT

0

0

0

0

0

.0

[]

[]

[]

0

0

0

0

0

0

0

0

0

D

0

0

0

D

0

OAT-RISK

o REPEAT FINDING

REMARKS:

Detainees in the SHU do not receive at least one hour of outdoor recreation time at least five times per week.

1 July 10,2008
b6,b7c
AUDITOR'SSIGNATURE/DATE

L~

.... --

~

b6,b7c

USE ONL Y (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 30

RELIGIOUS PRACTICES
POLICY: FACILITIES WILL PROVIDE ICE DETAINEES OF ALL FAITHS WITH REASONABLE AND EQUrrABLE OPPORTUNITIES TO PARTICIPATE IN THE
PRACFICES
OF THEIR FAITH, LIMITED ONLY BY THE CONSTRAlN'rS OF
.
. SAFETY, SECUruTY, THE ORDERLY OPERATIONS OF THE FACILITY AND
BUDGETARY CONSIDERATIONS.
REMARKS
COMPONENTS
NA
Y
N
Chatham County Detention
Detainees are allowed to engage in religfous services.
Center (CCDC) Policy 5-32-01
Inmate Programs, Religious
Programs, allows detainees
unrestricted rights to practice
181
0
0 their religious beliefs.
Detainees can exercise their
belief in any manner that does
not cause a threat to the safety,
security or the good order of the
facility.
Space is available for detainees to conduct religious services.
[J
[J
~
The facility allows detainees to observe the major "holy days" of their
religious faith.
181
0
0
• List any exceptions.
The facility accommodates recognized holy-day observances by:
• Providing special meals, consistent with dietary restrictions;
0
IZI
0
• Honoring fasting requirements;
• Facilitating religious services; and
• Allowing activity restrictions.
Each detainee is allowed religious items in hlslher immediate possession.
Detainees may possess one
IZI
0
0 acceptable religious
medallion/symbol.
Volunteer's credentials are checked and verified before allowing
The facility provides two full
participation in detainee programs.
Chaplains and over 100
IZI
0
0 time
volunteers from the Coastal
Ministries.
Members offaiths not represented by clergy may c.onduct their own services
IZl
0
0
within security allowances.
Detainees in the Special Management Unit are allowed to participate in
religious practices unless otherwise documented for the safety and security
IZl
0
0
of the facility.

o DEFICIENT

I:8J ACCEPTABLE

OAT-RISK

o REPEAT

FINDING

REMARKS:
Chatham County Detention Center (CCDC) Policy 5-32-01 Inmate Programs, Religious Programs, allows detainees unrestricted rights
to practice their religious beliefs. Detainees can exercise their belief in any manner that does not cause a threat to the safety, security,
or the good order of the facility.
1 July 10, 2Q08
b6,b7c
AUDITOR'SSJGNATURE/DATE

lL.......

t-

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 1218/07)

Page 31

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

... - ..

VOLUNTARY WORK PROGRAM
POLICY: IN EVERY FACILITY OFFERING AVOLUNTARY WORK PROGRAM, ICE DETAINEES WILL HAVB THE OPPORTUNITY TO WORK AND EARN
MONEYBYPARTICIPATING~ WHILENOTLEGALLYREQUIRED,ICEAFFORDSDETAINEEWORKERSBASICOCCUPATIONALSAFETY AND HEALTH
. ADMINISTRATION (OSHA) PROTECTIONS.

[8J CHECK HERE iF ICE DETAINEES ARE NOTAUTRORIZED TO WORK AT THE IGSA FACILITY. MARKNAONFoRMG-324A,PAGE3
AND MOVE TO NEXT SECTION.
REMARKS
COMl'ONENTS
NA
Y
N
Does the facility have a voluntary work program?
0
0
0
• Do ICE detainees participate?
[]
[]
Detainee housekeeping meets neatness and cleanliness standards.
[J
Detainees have the opportunity to participate in special details, however,
0
0
0
are never allowed to work outside the secure perimeter.
Written procedures govern selection of detainees for the Voluntary Work
0
0
0
Program.
Where possible, physically and mentally challenged detainees participate
0
0
0
in the program.
The facility complies with work-hour requirements for detainees, not
exceeding:
0
0
0
• 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
0
0
0
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
0
0
D
the work program.
The voluntary work program meets:
0
0
D
• OSHA NFPA ACA standards
Medical staff screen and fonnally certify detainee food service
volunteers.
0
0
0
• Before the assignment begins; and
• As a matter of written procedure
[]
[]
Detainees receive safety equipment! training sufficient for the assignment
[J
Proper Qrocedure is fonowed when an ICE detainee is injured on thejob.
[J
0

o DEFICIENT

!ZJ ACCEPTABLE·

Jl

OAT-RISK

o REPEAT

FINDING

REMARKS

ICE Detainees are not authorized to work at the Chatham County Detention Center.

b6,b7c

/ July 10,2008
GNATURE/DATE

l_

1~\.

b6,b7c

.

-

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 32
.--...-- ....

------

SECTION ID. HEALTH SERVICES STANDARDS

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
10 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 33

HUNGER STRIKES
POLICY: ALL FACILITIES WILL FOLLOW STANDARD GUIDELlNES FOR THE MEDICAL AND ADMINISTRATNE MANAGEMENT OF ICE DETAINEES
ENGAGING IN HUNGER STRIKES. By MONITORING OF THE HEALTH AND WELFARE OF THE lNDIVIDUALDETAINEES, FACILITIES WILL STRIVE TO
SUSTAIN THEIR LIVES.

Y

N

NA

0

[8J

0

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

[8J

0

0

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

[8J

0

0

[8J

0

0

[8J

0

0

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

[8J

0

0

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

[8J

0

0

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

[8J

0

0

During a bunger strike, staff document and provide the hunger-striking
detainee three meals a day.

[8J

0

0

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

[8J

0

0

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

[8J

0

0

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.

~

0

0

The medical staff has written procedures for treating hunger strikers.

[8J

0

0

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

[8J

0

0

COMPONENTS

When a detainee has refused food for 72 hours, it is standard practice for
staff to refer himlher to the medical department.

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

•

. Staffhas received training in identification of hunger strikes. Medical staff
receives early training in hunger-strike evaluation and treatment. Staff
remains current in evaluation and treatment techniques.

0
[8] ACCEPTABLE

[ ] DEFICIENT

OAT-RISK

~

0

o

REMARKS.
J-F-02-b, ACA: IC-05: Hunger
Strike states the detainee will be
referred to Health Services when
helshe has completely refused
food or drink. There is no time
frame in the policy.

Policy:J-F-02-b, ACA: I C-05
TITLE: Hunger Strike

Policy: J-F-02-b, ACA: IC-05
TITLE: HUNGER Strike.
Intake Receiving and Screening
form issued by Prison Health
Services Inc.
TITLE: Right to Refuse
Treatment. J-I-06, ACA: 4D-15.
Number J-I-06.

TITLE: Hunger Strike, J-F-02-b,
and ACA: 1COOS.

There is" no Policy or Procedure
on training staff in the
identification of hunger strikes.
There is also no staff that
remains current in evaluation
and treatment techniques of
hunger strikers.
REPEAT FINDING

REMARKS:
b6,b7c

July 10, 2008

AUDITOR'S SIGNATURE I DATE

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
<02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 34

ACCESS TO MEDICAL CARE
r()LIcy:EVERYlACILITYWll..LESTABLISHANDMAINTAINANACCREDITED/ACCREDITATION-WORTHYHEALTHPROORAM,FORTHEGENERAL
WELL-BEING OF ICE DETAINEES.

COMPONENTS
Facilities operate a health care facility in compliance with state and local
laws and guidelines.

The facility's in-processing procedures for arriving detainees include
medical screening.
All detainees have access to and receive medical care.
The facility has access to a PHSIDIHS Managed Health Care
Coordinator.
The medical staff is large enough to provide, examine, and treat the
facility's detainee popUlation.

Y

N

NA

IZl

0

0

IZl
IZl

0

0

lJ

[J

[8J

0

0

IZl

0

0

[8J

0

0

[8J

0
[J
0

0
[J
0

The facility has sufficient space and equipment to afford detainee privacy
when receiving health care.

.The medical facility has its own restricted-access area. The restricted
access area is located within the confines ofthe secure perimeter.
The medical facility entrance includes a holding/waiting room.
The medical facility's holding/waiting room is under the direct
supervision of custodial staff.
Detainees in the holding/waiting room have access to a drinking fountain.

Medical records are kept apart from other files. They are:
• Secured in a locked area within the medical unit;
• With physical access restricted to authorized medical staff; and
• Procedurally, no copies made and placed in detainee files.
Pharmaceuticals are stored in a secure area.

IZl
[8J

0

[8J

0

[8J

0

0

[8J

0

0

REMARKS

This facility is ACA accredited
and contracted out to Prison
Health Services, Inc. This
facility also operates in
compliance with state and local
laws and guidelines.
TITLE: Intake Screening,
NUMBER J-E-02

At this present time this
institution is 2 RNs short. The
staff consists of one HSA, one
DON, one full time 40 hr. a
week doctor, one pit 20 hr.
psychiatrist, one 20 hr PA, one
20 hr nurse practitioner, two pit
20 hr RNs, 16 full time LPNs
and two pit dentists who provide
coverage 5-days a week. This
facility 23.3 FTE's and 30 PTE's
for a population of 1800.
This facility does have sufficient
space and equipment. Dialysis t
and x-ray equipment were
contracted out. TITLE:
Number J-0-03, Clinic Space,
Equipment and Supplies .

Officer escort
Staff stated there is no drinking
fountain available in the area but
access could be provided in
another area if needed.
,TITLE: Health Record Format
and contents NUMBER: J-H01, TITLE: Confidentiality of
, Health Records and Information.
NUMBER: J-D-Ol TITLE:
Pharmaceutical Operations.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 35

ACCESS TO MEDICAL CARE
POLICY: EVERY FACILITY WILL ESTABLISH AND MAINTAIN AN ACcimDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR THE GENERAL

WELL-BEING OF ICE DETAINEES.
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 hislher arrival at the facility; and
• Detainees not screened are housed separate from the general
population.
All detainees receive a mental-healtli screening upon arrival. It is
conducted:
By a health care provider or specially trained officer, and
• Before a detainee's assignment to a housing unit.
The facility health care provider promptly reviews all I-794s (or
equivalent) to identify detainees needing medical attention.
The health care provider physically examines/assesses arriving detainees
within 14 days ofadmissionlarrival at the facility.

•

•

Detainees in the Special Management Unit have access to health care
services.
Staff provides detainees with health services (sick call) request slips
daily, upon request.
• Request slips are available in languages other than English,
including every language spoken by·a sizeable number ofthe
facility's detainee population.
• Service-request slips are delivered in a timely fashion to the
health care provider.
The facility has a written plan for the delivery of 24-hour emergency
health care when no medical personnel are on duty at the facility, or when
irrunediate outside medical attention is required.
The plan includes an on-callprovider.
The plan includes a list of telephone numbers for local ambulance and
hospital services.
The plan includes procedures for facility staff to utilize this emergency
health care consistent with security and safety.
Detention staff is trained to respond to health-related emergencies within
a 4-minute response time.

~

0

0

Policy NUMBER: J-B-O I-a
Entitled Tuberculin skin test.

-TITLE: INTAKE
SCREENING NUMBER: J-E02. A Nurse is stationed in
intake screening.

~

0

0

~

0

0

~

0

0

~

0

0

I2J

0

0

TITLE: NONEMERGENCY
HEALTH CARE REQUESTS
AND SERVICES, NUMBER JE-07.

TITLE: EMERGENCY
SERVICES, NUMBER J-E-Q8.

-

I2J

0

0

1ZI
I2J

[]

[]

0

0

I2J

0

0

0

I2J

0

I2J

0

0

The medical unit keeps written records of medication that is distributed.
The Form 1-819 (or IGSA equivalent) is used to notify the
WardenlFacility of a detainee that has special medical needs.

[8J

[J

[J

I2J

0

0

A signed and dated consent form is obtained from a detainee before
medical treatment is administered.
Detainees use the 1-813 (or IGSA equivalent) to authorize the release of
confidential medical records to outside sources.

I2J

0

0

I2J

0

0

Where staff is used to distribute medication, a health care provider
properly trains these officers.

TITLE: HEALTH
ASSESSMENT NUMBER J-E04.
TITLE: SEGREGATED
INMATES NUMBERJ-E-09.

PHS has a policy (new) that
states detention staff is to
respond to health-related
emergencies within a 4-minute
response time. Staff members
were not able to show me a
copy.
TITLE: MEDICATION
ADMINISTRATION
TRAINING, NUMBER J-C-OS.
TITLE: COMMUNICATION
ON SPECIAL NEEDS
PATIENTS NUMBER J-A-08.
TITLE: INFORMED
CONSENT J-I-OS
TITLE: TRANSFER OF
HEALTH RECORDS,
NUMBER J-H-OS.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
~

2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 36

ACCESS TO MEDICAL CARE

POllCY: EVERY FACILITY WlLLESTABLISH AND MAINTAIN AN ACCREDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR THE GENERAL
WELL-BEING OF ICE DETAINEES.
The facility health care provider is given advance notice prior to the
.~
0
0
release transfer, or removal ofa detainee.
Detainee's medical records or a copy thereof, are available and
0
~
0
transferred with the detainee.
Medical records are placed in a sealed envelope or other container
TITLE: TRANSFER OF
labeled with the detainee's name and A-number and marked "MEDICAL
0 HEALH RECORDS NUMBER
t8l
0
CONFIDENTIAL" .
J-H-05.

t:8J ACCEPTABLE

o

DEFICIENT

OAT-RISK

o

REPEAT FINDING

REMARKS:

There should be a water fountain in the waiting room.
PHS has a policy (new) that states detention staff are to respond to a health-related emergencies within a 4-minute response time;
however, staff members were not able to show me a copy of the revised policy. Upon spot checking 40 charts all had verification a
PPD was given upon arrival. Grievances were found in the charts with documentation of plans of action and documentation was
located indicating physicals are given in health services within 14 days upon the detainee's arrival.

b6,b7c

/ July 10. 2008

AUDITOR'S SIGNATURE/DATE

~ ~
D- ,

b6,b7c

.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

to 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 37

SUICIDE PREVENTION AND INTERVENTION
POLICY: ALL DETENTION STAFF
WORKING. WITH ICE
DETAINEES WILL
BE
TRAINED 10r RECOGNIZE .'SUICIDE-RISK
INDICATORS.
STAFF
WILL
.
. ".
'
-. - ._'
.
".'
.
.' .
HANDLE POTENTIALLY SUICIDAL INDIVIDUALS WITH SENSITIVITY, SUPERVISION, AND REFERRALS. A CUNICALLY SUICIDAL DETAINEE WILL
RECEIVE PREVENTIVE SUPERVISION AND TREATMENT.
. COMPONENTS
NA
Y
N
REMARKS
Every new staff member receives suicide-prevention training. SuicideTITLE: TRAINING FOR
prevention training occurs during the employee orientation program.
0 CORRECTIONAL OFFICERS,
~
0
NUMBER: J-C-04.
Training prepares staff to:
• Recognize potentially suicidal behavior;
0
~
0
• Refer potentially suicidal detainees, . following facility
procedures; and
• Understand and apply suicide-prevention techniques.
A health-care provider or specially trained officer screens all detainees for
TITLE: INTAKE
suicide potential as part of the admission process.
[8J
SCREENING, NUMBER: J-E0
0
• Screening does not occur later than one working day after the
02
detainee's arrival.
Written procedures cover when and how to refer at-risk detainees to
[8J
0
0
medical staff and procedures are followed.
The facility has a designated isolation room for evaluation and treatment.
MENTAL HEALTH
[8J
0
0 TITLE:
SERVICES, NUMBER: J-G-DS.
The designated isolation room does not contain any structures or smaller
[8J
0
0
items that could be used in a suicide attempt.
Medical staff has approved the room for this purpose.
[J
lJ
~
Staff observes and documents the status of a suicide-watch detainee at
THERE ARE TWO LEVELS
least once every IS minutes.
~
0
0 OF MONITORING CONSTANT AND CLOSE.
~ ACCEPTABLE

o DEFICIENT

OAT-RISK

o REPEAT FINDING

REMARKS:
b6,b7c
July 10.2008
AUDITOR'S SIGNATURE I DATE

L1)--- \.

b6,b7c

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 38

TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATH
POUCY ALL FACILITIES HOUSING ICE DETAINEES SHALLHAVB POLICIES AND PROCEDURES ADDRESSING THE ISSUES OF TERMINAL ILLNESS OR

iNruRY, 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 ADETAlNEE BECOMINGTERMINALLYILL OR
INJURED OR DEATH OF ADETAINEE
OCCURS.
IN ADDmON, THE POLICY WILL COVER PROCEDURES TO BE TAKEN IF THE DEATH OF ADETAINEE
OCCURS WHILE IN TRANSIT.

IZICHECK THIS BOX IF THE FACILITY DOES NOT ACCEPT ICE DETAINEES WHO ARE SEVERELY OR TERMINALLY ILL. INDICATE NA IN
THE APPROPRIATE BOX FOR THIS PORTION OF THE WORKSHEET. ALWAYS COMPLETE ALL REFERENCES TO DETAINEE DEATH AND
RELATED NOTIFICATIONS.
COMPONENTS
N
Y
NA
REMARKS
Detainees who are chronically or tenninally ill are transferred to an
D
D
IZI
appropriate offsite medical facilhYThe facility or appropriate ICE office promptly notifies the next ofkin of
the detainee's medical condition, to include:
D
D
IZI
• The detainee's location; and
• The limitations placed on visiting.
There are guidelines addressing the State Advanced Directive Fonn for
Implementing Living Wills and Advanced Directives.
TITLE: END-OF-LIFE
The guidelines include instructions for detainees who wish to
DECISION MAKING,
D
D
IZI
have a living will other than the generic fonn the DIHS provides
NUMBER J-I-04.
or who wishes to appoint another to make advance decisions for
him or her.
The guidelines provide the detainee the opportunity to have a private
D
IZI
D
attorney prepare the documents.
There is a policy addressing "Do Not Resuscitate Orders"
TITLE: END -OF-LIFE
D
D DECISION MAKING,
IZI
NUMBER: J-I-04.
Detainees with a "Do Not Resuscitate" order in the medical record
DIZI
D
receive maximal therapeutic efforts short of resuscitation?
The facility notifies the DIHS Medical Director and Headquarters' Legal
Counsel ofthe name and basic circumstances of any detainee with a "Do
D
D
IZI
Not Resuscitate" order in the medical record. In the case ofIGSAs, this
notification is made through the local ICE representative.
The facility has written procedures to address the issues of organ
D
D
IZI
donation by detainees.
The facility has written procedures to notity ICE officials, deceased
D
D
IZI
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
TITLE: INMATE
while in transport.
TRANSPORT OUTSIDE THE
IZI
D
D FACILITY, NUMBER
03/15/07.
At all ICE locations the detainee's remains disposed of in accordanc~
IZID
D
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.
D
0
IZI
• If the detainee's is a U.S. military veteran, is the Department of
Veterans Affairs notified?
An original or certified copy ofa detainee's death certificate is placed in
0
0
IZI
the subject's a-file.

-.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 39

TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATH
POLICY ALL FACILITIES HOUSING ICE DETAINEES SHAlL HAVB POLICIES AND PROCEDURES ADDRESSING TIlE ISSUES OFTER:MINAL ILLNESS OR
INJURY, MEDICAL ADVANCED DIRECTIVES, AND DETAINEE DEATH, TO INCLUDE THE PROCEDURES TO ENSURE PROPER NOTIFICATION IS
.. PROVIDEDTO ICE OFFICIALS~ FAMILY MEMBERS AND OTIffiRINTERESTED PARTIES IN THE EVENT OF ADETAJNEEBECOMING TERMINALLY ILL OR
INJURED OR DEATH OF A DETAINEE OCCURS. IN ADDITION, THE POLICY WILL COVER PROCEDURES TO BE TAKEN IF TIlE DEATH OF ADETAINEE
occURs WHILE IN TRANSIT.

[gI CHECK THIS BOX IF THE. FACILITY DOES NOT ACCEPT ICE DETAINEES WHO ARE SEVERELY OR TERMINALLY ILL. INDICATE NA IN
THE APPROPRIATE BOX FOR THIS PORTION OF THE WORKSHEET. ALWAYS COMPLETE ALL REFERENCES TO DETAINEE DEATH AND
RELATED NOTIFICATIONS.
REMARKS
COMPONENTS
Y
N
NA
The facility follows established policy and procedures describing when to
contact the local coroner regarding such issues as:
TITLE; PROCEDURE IN THE
• Performance ofan autopsy;
[gI
EVENT OF AN INMATE
0
0
• Who will perform the autopsy;
DEATH, NUMBER; J~A-lO.
• Obtaining state approved death certificates; and
• Loca.l transportation of the body.
ICE staff follows established procedures to properly close the case ofa
[gI
deceased detainee.
0
0
~ ACCEPTABLE

o DEFICIENT

OAT-RIsK

o REPEAT

FINDING

REMARKS:

/ July to. 2008
AUDITOR'S SIGNATURE/DATE
b6,b7c

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections,LLC (Rev. 1218/07)

Page 40

SECTION IV. SECURITY AND CONTROL

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
C 2007 Creative Corrections, LLC (Rev. 1218/07)

Page 41

CONTRABAND
POLICY: ALL DETENTION FACILITIES WILL ENSURE
~ CONTRABAND DESTRUCTION IS REQUIRED.

THE

PROPER HANDLING AND DISPOSAL OF ALL CONTRABAND. Doc~NTATION OF

COMPONENTS
The facility follows a written procedure for handling illegal contraband.
Staff inventory, hold, and report it when necessary to the proper authority
for action/possible seizure.

Y

N

NA

18I

0

0

18I

0

0

~

0

0

~

0

0

~

0

0

~

0

0

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 orc or designated investigator
contacts a religious authority.

Staff follows written procedures when destroying hard contraband that is
,illegal.

REMARKS

The facility's policy, Facility and
Inmate Searches, 03/15/10,
dated February 6, 2008, page
11, section S, addresses
evidence handling and the chain
of custody for contraband.
The policy does not specifically
address the disposition oflocal
goverinnent property.
Interviews and documentation
reviewed indicate county
contraband is retained for
potential disciplinary action.
The policy does not reference
returning property not needed as
evid~nce to the proper authority.
Interviews and documentation
reviewed indicate property not
needed as evidence is turned
over to the proper authority.
The policy does not specifically
address altered property.
Interviews and documentation
reviewed indicate altered
property is destroyed using
established procedures.
The policy does not specifically
address contacting a religious
authority before confiscating
religious items. There has been
no history ofreJigious items
being confiscated and no
documentation available.
Interviews indicate a religious
authority would be contacted
regarding any questionable
religious items confIScated.
The policy does not specifically
address pro~dures for
destroying hard contraband
Interviews and documentation
reviewed indicate hard
contraband is destroyed
following written procedures.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
@

2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 42

CONTRABAND
POLICY: ALL DETENTION FACILrITES WILL ENSURE TIlE PROPER HANDLINO.AND DISPOSAL OF ALL CONTRABAND. DOCUMENTATION OF
CONTRABAND DESTRUCTION IS REQUIRED.
COMPONENTS
N
NA
REMARKS
Y
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.

[8J ACCEPTABLE

o

DEFICIENT

~

OAT-RISK

0

0

o

The policy does not specifically
address retaining illegal hard
contraband for training
purposes. Interviews with the
Training Director indicate hard
contraband, on occasion, is
passed on to him for use in
trainin..&
REPEAT FINDING

REMARKS:

A review of documentation and facility practice regarding the control and disposition of contraband reveals the procedures set forth
within the Contraband Policy are being followed.

b6,b7c

/ July 10.2008
ATURE/DATE

L 'U

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
C> 2007 Creative Corrections, LLC (Rev. 1218/07)

Page 43

DETENTION FILES '
POLICY: EVERY FACILITY WILL CREATE A DETENTION FILE FOR EVERY ICE DETAINEE BOOKED INTO THE FACILITY, EXCLUDING ONLY
. DETAINEEs SCHEDULED TO DEPART WITHIN24 HOURS. THE DETENTION FILE'WILL CONTAIN COPIES AND, IN SOME CASES,
ORIGINAL OF
SPECIFIED DOCUMENTS CONCERNING THE DETAINEE'S STAY IN THE FACILITY: CLASSIFICATION SHEET, MEDICAL QUESTIONNAIRE, PROPERTY
INVENTORY SHEET DISCIPLINARY DOCUMENTS ETC.
COMPONENTS
Y
N
NA
REMARKs

TIm

.'

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 secure area. Ifnot, the
cabinets are lockable and distribution ofthe keys is limited to supervisors.

•

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

•
•

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 properly
requested by supervisory personnel at the receiving facility or office.
Appropriate staffhas 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.

[8] ACCEPTABLE

o

DEFICIENT

OAT-RIsK

o

There is a detention file created
for every new arrival whose stay
will exceed 24-hours. During
the review the files were
observed in a locked secure
cabinet.

The detainee detention files
contain documents generated
during the detainee's stay that
include: special requests,
grievances, complaints and
disciplinary forms.
The detention files are located
and maintained in Unit 3A in
locked secure cabinets.
The active files are maintained
during the detainee's stay.
When the detainee is released
from the facility, staff place
copies of completed release
documents and close out
receipts for property and
valuables.

REPEAT FINDING

REMARKS:

The facility creates a file on detainees upon their arrival. These detention files contain classification information.

b6,b7c

/ July 10. 2008

AUDITOR'S SIGNATURE/DATE

kb~ '-

b6,b7c

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
C 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 44

DISCIPLINARY POLICY
POLICY: ALL FACiLrnEs HOUSING ICE DETAINEBS ARE AUTHORIZED TO IMPOSE DISCIPLINE ON DETAINEES WHOSE BEHAVIOR IS NOT IN
COMPLIANCE WITH FACILITY RULES AND REGULATIONS.

COMPONENTS
The facility has a written disciplinary system using progressive levels of
reviews and appeals.

The facility rules state that disciplinary action shall not be capricious or
retaliatory.

Written rules prohibit staff from imposing or permitting the following
sanctions:
• corporal punishment
• deviations from normal food service
• clothing deprivation
• bedding deprivation
• denial of personal hygiene items
• loss of correspondence privileges
• deQfivation of})hysical exercise
The rules of conduct, sanctions, and procedures for violations are defmed
in writing and communicated to all detainees verbally and in writing.

The following items are conspicuously posted in Spanish and English,
and other dominate languages used in the facility:
• Rights and Responsibilities
Prohibited Acts
• Disciplinary Severity Scale
Sanctions
When minor rule violations or prohibited acts occur, informal resolutions
are encouraged.
Incident reports and Notice of Charges are promptly forwarded to the
designated supervisor.
Incident reports are investigated within 24 hours of the incident. The
Unit Disciplinary Committee (UDC) or equivalent does not convene
before an investigation ends.

•

Y

N

NA

t8l

D

D

D

t8l

D

D

!ZJ

REMARI{S

Policy Disciplinary Procedures,
03/17/02, dated February 6,
2008, addresses the disciplinary
system utilized by the facility.
The policy does not specifically
state that disciplinary action
shall not be capricious or
retaliatory.

D

The policy does not specifically
prohibit staff from imposing
corporal"punishment; deviation
from normal food service;
clothing deprivation; bedding
deprivation; denial of personal
hygiene items; loss of
correspondence privileges; or
deprivation of physical exercise.
The Inmate Handbook provides
a detailed description of the
rules of conduct. Sanctions and
procedures for violations are
well defmed.

!ZJ

D

D

t8l

D

D

!ZJ

D

0

t8l

D

D

•

An intermediate disciplinary process is used to 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;
• Hears pleadings by detainees and staff representatives;
• Bases its findings on the preponderance of evidence; and
• Imposes only authorized sanctions
A staff representative is available if requested for a detainee facing a
disciplinary hearing.

!ZJ

D

D

D

!ZJ

D

!ZJ

D

D

!ZJ

D

D

The disciplinary policy states an
investigation is to begin within
twenty-four (24) hours of the
violation.
The facility does not incorporate
an intermediate disciplinary
process (Unit Discipline
Committee Hearin~.
The policy states the
Disciplinary Hearing Board
(DHB) is to be comprised of
trained and experienced staff'.
Interviews revealed each Unit
has a DHB who adjudicates
infractions in-house.

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
«:> 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 45

-

DISCIPLINARY POLICY
POLICY: ALL FACILITIES HOUSING

ICE DETAINEES ARE AUTIIORlZED TO IMPOSE DISCIPLINE ON DETAINEES WHOSE BEHAVIOR IS NOT IN

COMPLIANCE WITH FACILITY RULES AND REGULATIONS.
..

-

COMPONENTS

-

The facility pennits hearing postponements or continuances when
conditions warrant such a continuance. Reasons are documented.

The duration of punishment set by the OIC, as recommended by the
disciplinary panel, does not exceed established sanctions. The maximum
time in disciplinary segregation is limited to 60 days for a single offense.
Written procedures govern the handling of confidential-informant
information. Standards include criteria for recognizing "substantial
evidence"

All forms relevant to the incident, investigation, committee/panel reports,
etc., are completed and distributed as required.

o DEFICIENT

[8J ACCEPTABLE

Y

N

NA··

~

0

0

I25J

0

0

0

I25J

0

I25J

0

0

OAT-RISK

REMARKS

The policy addresses
postponement or continuance of
the hearing for a reasonable
period with good cause.

The policy does not specifically
address the handling of
confidential-informant
information; however, it does
address the recognition of
substantial evidence.

o REPEAT FINDING

REMARKS:

The policy and procedures of this facility endorses informal discipline, but does not formaMy incorporate an intermediate disciplinary
process (Unit Discipline Committee Hearing) which includes a due process hearing. The facility does employ a Discipline Hearing
Committee. The Disciplinary Policy and the Detainee Handbook were reviewed. Neither of these documents addressed that
disciplinary action shall not be capricious or retaliatory, nor do they prohibit corporal punishment, deviations from normal food
serVice, clothing and bedding deprivation, denial of personal hygiene items, loss of correspondence privileges, or the deprivation of
physical exercise. Additionally, the policy does not specifically address the handling of confidential-informant information.

b6,b7c

1 July 10.2008

AUDITOR'S SIGNATURE I DATE

kr~-

b6,b7c

.

\.

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
to 2007 Creative Corrections, LLC (Rev. 1218/07)

Page 46

EMERGENCY (CONTINGENCy) PLANS
POUCy ALL FACILITIES HOLDING ICE DETAINEES WILL RESPOND TO EMERGENCIES wrrn APREDETERMINED STANDARDIZED PLAN TO MINIMIZE
THIHIARMING OF HUMAN LlFE AND THE DESTRUCTION OF PROPERTY. Ins RECOMMENDED THAT SPCs AND CDFs ENTER INTO" AGREEMENT,
VIA MEMORANDUM OF UNDERSTANDING (MQU), WITH FEDERAL...1. LOCAL AND STATE AGENCIES TO ASSIST IN TIMES OF EMERGENCY.
NA
REMARKS
COMPONENTS
Y
N
Facility policy - Threats to
Policy precludes detainees or detainee groups from exercising control or
Security, 03/16/08, dated
authority over other detainees.
February 6; 2008, does not
D
I8l
0 address the prohibition of
detainees or detainee groups
from exercising control or
authority over other detainees.
Detainees are protected from:
• Personal abuse
• Corporal punishment
I8l
0
0
• Personal injury
• Disease
• Property damage
• Harassment from other detainees
Staff is trained to identify signs of detainee unrest.
D
0
I8l
• WhatJY1l.e of training and how often?
Staff effectively disseminates information on facility climate, detainee
I8l
D
D
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
0
I8l
D
group for development and implementation of the plans.
The plans address the following issues:
The policy does not address
confidentiality or
Confidentiality
accountability. It does indicate
• Accountability (copies and storage locations)
I8l
0
D procedures will be reviewed
• Annual review procedures and schedule
annually and updated as
• Revisions
needed.
Contingency plans include a comprehensive general section with
The policy addresses
procedures applicable to most emergency situations.
I8l
D
D procedures applicable to most
emergency situations.
The facility has cooperative contingency plans with applicable:
No cooperative contingency
• Local law enforcement agencies
D
I8l
D plans exits.
• State agencies
• Federal agencies
All staff receives copies of Hostage Situation Management policy and
I8l
0
0
procedures.
Staff is trained to disregard instructions from hostages, regardless ofrank.
The policy states any person
taken hostage, regardless of
Within 24 hours after release, hostages' are screened for medical and
psychological effects.
I8l
0
0 position or rank is deemed to
have relinquished all power and
authority.
Emergency plans include emergency medical treatment for staff and
I8l
0
0
detainees during and after an incident.
Food service maintains at least 3 days' worth of emergency meals for staff
r8l
0
0
and detainees.

•

1 - - - - - - - - - - - - - - - - - - - - - - - -"---"-----------"-------------"---"-----"-~

I

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
to 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 47

EMERGENCY (CONTINGENcy) PLANS

POLICY ALL FACILITIES HOLDING ICE DETAINEES WILL RESPOND TO EMERGENCIES WITH APREDETERMINED STANDARDIZED PLAN TO MINIMIZE
THE HARMING OF HUMAN LIFE AND THE DESTRUCTION OF PROPERTY. IT IS RECOMMENDED THAT SPCS 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.
..
Written plans identify locations of shut-off valves and switches for all
. Written plans do not identify
utilities (water, gas, electric).
locations of shut-off valves and
switches for all utilities (water,
~as and/or electric).
Written procedures cover:
Four often emergency
standards have written
• WorkJF ood Strike
procedures· (Work Strike,
• Disturbances
Escapes, Adverse Weather, and
• Escapes
Evacuation). Internal Searches,
Bomb
Threats
•
Detainee Transportation, and
Adverse
Weather
•
Civil Disturbances do not have
Internal
Searches
•
any written procedures.
Facility
Evacuation
•
Disturbances, FIunger Strikes,
• Detainee Transportation System Plan
FIostage Situations, and Bomb
• InternalFIostages
Threats are addressed within
• Civil Disturbances
the Threats to Security policy;
however, they are not addressed
in the form of a comprehensive
plan which provides proper
direction and guidance to
remedy the situation. Rather,
they are descriptions of an
incident, i.e. "FIostage Situation
-- A hostage situation exists
when a person is held under
force, by violence or the threat
of violence, regardless of the
hostage taker being armed or

o

o

o

o

o

not"

rg] DEFICIENT

ACCEPTABLE

OAT-RISK

o REPEAT FINDING

REMARKS:

Four often emergency standards have written procedures (Work Strike, Escapes, Adverse Weather, and Evacuation). Internal
Searches, Detainee Transportation, and Civil Disturbances do not have any written procedures. Disturbances, FIunger Strikes, Hostage
Situations, and Bomb Threats are addressed within the Threats to Security policy; however, they are not addressed in the form ofa
comprehensive plan which provides proper direction and guidance to remedy the situation. Rather, they are descriptions of an
incident, i.e. "Hostage Situation -- A hostage situation exists when a person is held under force, by violence or the threat of violence,
. regardless of the hostage taker being armed or not." Additionally, emergency procedures do not address the following mandated
standards: confidentiality and accountability of the written plans; cooperative contingency plans with applicable agencies; preclusion
of detainees or detainee groups from exercising control or authority over other detainees; and written plans do not identify locations of
shut-off valves and switches for all utilities (water, gas and/or electric).

b6,b7c

1 July 10.2008
TURE/DATE

l_

~ .....,

b6,b7c

-------'---- -------

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
© 2001 Creative Corrections, LLC (Rev. 12/8/01)

Page 48

ENVIRONMENTAL HEALTH AND SAFETY
POLICY.: EvERY FACILlTYWILL CONTROL FLAMMABLE, TOXIC, AND CAUSTIC MATERIALS THROUGH AHAZARDOUS MATERIALS PROGRAM.1HE
PROGRAM WILL INCLUDE, AMONG OTHER TIIlNGS, THE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN ACCORDANCE WITH
APPLICABLE STANDARDS (E.G., NATIONALFIRE PROTECTION ASSOCIATION [NFPA]); IDENTIFICATION OF INCOMPATffiLE MATERIALS, AND
SAFE-HANDLING PROCEDURES
NA
COMPONENTS
Y
N
REMARKS
The facility has a system for storing, issuing, and maintaining inventories
3/16/02
Flammable,
[8J
0 toxic, materials. caustic, and
0
of hazardous materials.
Constant inventories are maintained for all flammable, toxic, and caustic
[8J
0
0
substances usedlstored 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 files list all storage areas, and include a plant diagram and [8J
0
0
legend.
• The MSDSs and other information in the files are available to
personnel managing the facility's safetypmgr8Il!.
All personnel using flammable, toxic, andlor caustic substances follow
Engineering department staff
the prescribed pmcedures. They:
[8J
receives
training during their
0
0
• Wear personal protective equipment; and
academy period.
• Report hazards and spills to the designated official.
The MSDSs are readily accessible to staffand detainees in work areas.
[8J
0
0
Hazardous materials are always issued under proper supervision.
[8J
0
0
• Quantities are limited; and
• Staff always supervises detainees using these substances.
All "flammable" and "combustible" materials (liquid and aerosol) are
[8J
0
0
stored and used according to label recommendations.
Lighting fixtures and electrical equipment installed in storage rooms and
[8J
0
0
other hazardous areas meet National Electrical Code requirements.
The facility has sufficient ventilation, and provides and ensures clean air
[8'J
0
0
exchanges throughout all buildings.
Vents, return vents, and air conditioning ducts are not blocked or
[8'J
0
0
obstructed in cells or anywhere in the facility.
Living units are maintained at appropriate temperatures in accordance
[8J
with industry standards. (68 to 74 degrees in the winter and 72 to 78
0
0
degrees in the summer.)
Shower and sink water temperatures do not exceed the industry standard
[8J
0
0
of 120 degrees.
All toxic and caustic materials are stored in their original containers in a
service chemical storage
[8'J
0
0 Food
room was inspected
secure area.
Excess flammables, combustibles, and toxic liquids are disposed of
[8J
D
0
properly and in accordance with MSDSs.
Staff directly. supervise and account for products with methyl alcohol.
A review of material safety data
Staff receives a list of products containing diluted methyl alcohol, e.g.,
sheets did not indicate any
[8J
shoe dye. All such products are clearly labeled. "Accountability"
0
0
products containing methyl
includes issuing such products to detainees in the smallest workable
alcohol.
quantities.
Every employee and detainee using flammable, toxic, or caustic materials
Detainees in food service
[8'J
receives advance training in their use, storage, and disposal.
0
0 receive training prior to
working.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 49

ENVIRONMENTAL HEALTH AND SAFETY
POLICY: EVERY FACILITY WILL CONTROLFI.AMMABLE, TOXIC, AND CAUSTIC MATERIAlS THROUGH AHAZARDOUS MATERIAlS PROGRAM. THE
PROGRAM WILL INCLUDE, AMONG OTHER THINGS, THE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN ACCORDANCE WITH
APPLICABLE STANDARDs (E:O., NATIONAL FIRE PROTECfION ASSOCIATION [NFPA]); IDENTIFICA110N OF INCOMPATmLE MATERIALS, AND
SAFE-HANDLING PROCEDURES
COMPONENTS .
Y
N
NA
REMARKS
The facility complies with the most current edition of applicable codes,
The sprinkler and smoke
detection systems annual tests
standards, and regulations of the National Fire Protection Association and
the Occupational Safety and Health Administration (OSHA).
have expired. The last sprinkler
test was conducted in January
The last smoke alann test
0- fZI
0 2007.
was conducted in June 2007.
The test results indicated 39
smoke detectors failed the test.
.
These have not been repaired at
this time.
A technically qualified officer conducts the fire and safety inspections.
0
[]
The Safety Office (or officer) maintains files of inspection reports.
[]
The facility has an approved fire prevention, contro~ and evacuation plan.
Policy 3/16/01 Fire Safety
The plan requires:
• Monthly fife inspections;
• Fire protection equipment strategically located throughout the
facility;
fZI
0
0
• Public posting of emergency plans with accessible
building/room floor plans;
• Exit signs and directional mows; and
• An area-specific exit diagram conspicuously posted in the
diagrammed area.
Fire drills are conducted and documented monthly.
Fire drills are conducted and
0
fZI
0 documented quarterly
A sanitation program covers barbering operations.
4123/05 Hair care
fZI
0
0 Policy
services
The barber shop has the facilities and equipment necessary to meet
t8J
0
0
sanitation reqilirements.
The sanitation standards are conspicuously posted in the barbershop.
Sanitation standards are not
0
fZI
0 posted
in the barbering area
Written procedures regulate the handling and disposal of used needles
Policy 4124/08 Serious
t8J
0
0 infectious diseases, IV- A
and other sharp objects.
All items representing potential safety or security risks are inventoried
Inventory of
t8J
D
0 J-D-03-A
and a designated individual checks this inventOI)' weekly.
instruments, tools, and sharps
Standard cleaning practices include:
• Using specified equipment; cleansers; disinfectants and
detergents.
fZI
D
0
• An established schedule of cleaning and follow-up inspections.

•

The facility follows standard cleaning procedures.

fZI

D

0

Spill kits are readily available.

fZI

D

0

Policy 4124/08 IV F

A licensed medical waste contractor dispos~s ofinfectiouslbio-hazardous
waste.
Staff is trained to prevent contact with blood and other body fluids and
written procedures are followed.

fZI

D

0

Policy 4123/03 Waste disposal
Stericycle has the contract

fZI

D

0

Policy 4/24/08 III A

-------------------

FOR OFFICIAL USE ONtY (LAW ENFORCEMENT SENSITIVE)
C> 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 50

ENVIRONMENTAL HEALTH AND SAFETY
POLICY: EvERY FACILITY WILL CONTROL FLAMMABLE, TOXIC, AND CAUSTIC MATERIALS THROUGHAHAZARDOUS MATERIALS PROGRAM. nm
PROGRAM WiLL INCLUDE, AMONG OTHER TIlINGS, TIlE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN ACCORDANCE WITH
APPI,ICABLE STANDARDS (E.G., NATIONAL FIRE PROTECTION AsSOCIATION [NFPA]); IDENTIFICATION OF INCOMPATIBLE MATERIALS, AND
SAFE-HANDLING PROCEDURES
NA
.REMARKS
COMPONENTS
Y
N
Do the methods for handling/disposing of refuse meet all regulatory
t8J
0
0 Policy 4/23/03 Waste disposal
requirements?
A licensediCertifiedfTrained pest-control professional inspects for
rodents, insects, and vennin.
0
t8J
0
• At least monthly.
• The pest-control program includes preventative spraying for
indigenous insects.
Drinking water and wastewater is routinely tested according to a fixed
t8J
0
0 Policy 4/23/02 Water supply
schedule.
Emergency power generators are tested at least every two weeks.
Policy 3/16/03 Emergency
• Other emergency.systems and equipment receive testing at least
[81
quarterly.
0
0 power generators and
communications
• Testing is followed-up with timely corrective actions (repairs
and replacements).

o ACCEPTABLE

o DEFICIENT

[8] AT-RISK

o REPEAT FINDING

REMARKS:
The sprinkler and smoke detection systems annual tests have expired. The last sprinkler test was conducted in January 2007. The last
smoke alarm test was conducted in June 2007. The test results indicated 39 smoke detectors failed the test. The smoke detectors have
not been repaired at this time.
Fire drills are conducted and documented quarterly instead ofmontWy.
Sanitation standards are not posted in the barbering area

/ July 10, 2008
b6,b7c
AUDITOR'SSIGNATURE/DATE

~
~-

b6,b7c

...

- - - ----- - - - - - - - - - - - - - - - - -

-

----------

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 51

HOLD ROOMS IN DETENTION FACILITIES
HOLD ROOMS WILL BE USED ONLY FOR TEMPORARY DETENTION OF DETAlNEES AWAITING REMOVAL, TRANSFER, EOIR HEARINGS,
MEDICAL TREATMENT iNTRA-FACIllTY MOVEMENT, OR OTIlER PROCESSING INTO OR OUT OF THE FACIllTY.
N
REMARKS
Y
NA
COMPONENTS
[J
The hold rooms are situated within the secure perimeter.
[J
~
The hold rooms are well ventilated, well lighted, and all activating switches
0
0
~
are located outside the room.
Each hold room has sufficient
The hold rooms contain sufficient seating forthe number of detainees held.
[8J
seating in the form of benches
0
0
which are attached to the wall.
Bunks, cots, beds, or other related make-shift sleeping apparatus are
[8J
0
0
~recluded from use inside hold rooms.
[]
The walls and ceilings of the hold rooms are tamper and escape proof.
IZI
LJ
Interviews with Receiving and
Individuals 'are not held in hold rooms for more than 12 hours.
Discharge staff revealed that
[8J
detainees are housed, on
0
0
occasion, more than twelve
hours within the hold rooms.
[8J
Male and females are segregated from each other.
lJ
0
Detainees under the age of 18
Detainees under the age of 18 are not held with adult detainees.
are housed with adults.
[8J
However, in the state of Georgia
0
0
individuals are considered lin
adult at the age of 17.
Detainees are provided with basic personal hygiene items such as water,
[8J
0
0
soap, toilet paper, cups for water feminine hygiene items diapers and wipes.
In older facilities, officers are within visual or audible range to allow
[8J
0
0
detainees access to toilet facilities on a regular basis.
All detainees are given a pat down search for weapons or contraband before
[8J
0
0
being placed in the room.
Officers closely supervise the detention hold rooms using direct supervision
(Irregular visual monitoring.).
[8J
0
0
• Hold rooms are irregularly monitored every 15 minutes .
• Unusual behavior or comj)laints are noted .
When the last detainee has been removed from the hold room, it is given a
[8J
0
0
thorough inspection.
There is a written evacuation plan that includes a designated officer to
[8J
remove detainees from hold rooms in case of fire and/or building
0
0
evacuation.
An appropriate emergency service is called immediately upon a
[8J
0
0
determination that a medical emergency may exist. POllCY:

[8J ACCEPTABLE

o DEFICIENT

OAT-RISK

o REPEAT FINDING

REMARKS:

Hold rooms are used only for temporary detention of detainees awaiting removal, transfer, court hearings, medical treatment, intrafacility movement, or other processing into or out of the facility. These hold rooms meet every required standard except one.
Interviews with receiving and discharge staff revealed that detainees are housed, on occasion, more than 12 hours in the hold rooms.

I July 10.2008.0 AUDITOR'SSIGNATURE/DATE ~
b6,b7c

b6,b7c

1 - - - - - - - - - - - - - - - - - - - - - - - - . - - - - - - - - - - - - -.. - -- - - --- - - --- - - - - - - - - - - - - -

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 52

KEY AND LOCKCONTROL
(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

Y

N

NA

0

IZJ

0

IZJ

0

0

IZJ

0

0

The security officer[s], or equivalent in IGSAs, 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.

f - - - - - - - - - - - - - - - - - - - --- --------------- ---- - - - -

REMARKS
The facility does not endorse the
use of a "stand alone" security
officer. The Engineering and
Custody Department share this
responsibility. The Engineering
Department completes lock
repairs and the Custody
Department assigns a Sergeant
the responsibility of key control
and accountability. The
Accreditation Lieutenant cuts
new keys when needed.
Interviews with these staff
revealed none of them has
attended an approved locksmith
training program.
Policy Controlled Access and
Use of Keys, 03/15/11, February
6,2008 Page 1, Section A. 1.
states the Assistant
Administrator or designee is
responsible for implementation
and audit of the key control
system, training of staff, storage,
issuance, maintenance, and
inventories of locks and keys.
Training in Key Control occurs
during basic techniques training
and again during annual
refresher training.

- - - - - - - - - --- ------- -- --- -

--- - - - - - - - - - - - - - - - - - - - -

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 53

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, ACCOUNTABn.xrY AND MAINTENANCE OF ALL
KEYS AND LOCKS.
N
NA
REMARKS
COMPONENTS
Y
The security officer, or equivalent in IGSAs, maintains inventories of all
keys, locks and locking devices.
-

0

[8J

0

b2High

Staff interviews with the
Engineering Department
revealed they do not follow any
preventive maintenance program
or maintain any documentation.

The security officer follows a preventive maintenance program and
maintains all preventive maintenance documentation.

0

[8J

0

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.

[8J

0

0

0

[8J

0

Only dead bolt or dead lock functions are used in detainee accessible
areas.
Only authorized locks (as specified in the Detention Standard) are used in
detainee accessible ateas.
Grand master keying systerus are prohibited.

[gI

0

0

[gI

0

0

0

[8J

0

l - - - - - - - - - ---. - - - - - - - - - - -

----------- - - - - - - - - - - - - - -

b2High

b2High

-----------------------------

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 54

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, ACCOUNTABIUlY AND MAINTENANCE OF ALL
~YSAND LOCKS.
N
NA
REMARKS
COMPONENTS
Y
A review of key rings within the
All worn or discarded keys and locks are cut up and properly disposed of.
Main Control Center revealed a
broken key on key ring 20.
~
0 There was no documentation
0
available to indicate when this
key was broken or how long it
had been broken.
Padlocks and/or chains are prohibited from use on cell doors.
0
0
J8J
The entrance/exit door locks to detainee living quarters, or areas with an
occupant load of 50 or more people, conform to:
~
0
0
• Occupational Safety and Environmental Health Manual, Ch. 3;
National
Fire
Protection
Association
Life
Safety
Code
101.
•
The operational keyboard is sufficient to accommodate all the facility key
0
0
~
rings including keys in use and is located in a secure area.
Procedures are in place to ensure that key rings are:
• Identifiable;
• The numbers of keys are cited; and
• Keys cannot be removed.

Emergency keys are available for all areas of the facility.
The facilities use a key accountability system.

0

~

0

~

0

0

~

0
0

~

0

0

~

0

0

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.

•

b2High

The key accountability system is
flawed as described above.
The policy states restricted keys
are issued only under the
authority of supervisory
personnel.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
<C 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 55

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
Poucy IT IS THE POLICY OF THE ICE SERVICE TO MAINTAIN AN EFFICIENT SYS1EMFOR TIIEUSE, ACCOUNTABILITY AND MAINTENANCE OF AIL

KEYS AND LOCKS.

.
N

Y

COMPONENTs

NA

REMARKS

D

b2High

The facility has a key accountability policy and procedures to ensure key
accountability. The keys are physically counted daily.

D

All staff members are trained and held responsible for adhering to proper
procedures for the handling of keys.
• Issued keys are returned 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 pennitted to handle keys assigned to staff.

o ACCEPTABLE

~DEFICIENT

D

OAT-RIsK

D

o REPEAT FINDING

REMARKS:

The facility does not endorse the use of a "stand alone" security officer. The Engineering and Custody Department share this
responsibility. The Engineering Department completes lock repairs, the Custody Department assigns a Sergeant the responsibility of
key control and accountability, and the Accreditation Lieutenant cuts new keys when needed. Interviews with staff revealed these staff
members have not attended an approv~ locksmith training program.
It was determined the facility was not following several of their policy and standard requirements.

b2High

b2High

b2High

a broken key was found on a key ring with no documentation available to indicate when this key was broken or how long it had been
broken.,

b6,b7c

/ July 10.2008

AUDITOR'SSIGNATURE/DATE

- .-------

/1.,.

If-----

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

b6,b7c

-------------

- - - ---

---_._---

-- -- --- -

-

- - ._--

---'~'--'

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
(:) 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 56

POPULATION COUNTS
POLICY: -ALL DETENTION FACILITIES SHALL ENSUREAROUNl)-THE-CLOCK ACCOUNTABILITY FOR ALL DETAINimS. THIs REQUIRES TIIATTHEY
CONDUCT AT LEAST ONE FORMAL COUNT OF THE DETAINEE POPUlATION PER SHIFT, wrrn ADDmONAL FORMAL AND INFORMAL COUNTS
CONDUCTED AS NECESSARY.
REMARKS
Y
NA
COMPONENTS
N
Staff conduct a fOlmal count at least once each shift.
Activities cease or are strictly controlled while a fOlmal count is being
conducted.

~

lJ

LJ
Policy Inmate Counts, 03/15/05,
February 6, 2008, Page 3,
Section 3, addresses controlled
activity. Observations of count
procedures indicate activities do
not cease or are strictly
controlled within Unit 5 and 6.
Detainees were observed sitting
in day rooms, using telephones,
and watching television during
fOlmal counts.
All movement does not cease for
the duration of a fOlmal count as
evidenced by relocation boards
being updated during count
procedures.
Policy Inmate Counts, 03/15/05,
February 6,2008, Page 3,
Section 4, addresses
simultaneous counts.

0

~

0

0

~

0

0

r8J

0

~

0

0

~

0

[J

Certain operations cease during fOlmal counts.

All movement ceases for the duration of a fOlmal count.

FOlmal counts in all units take place simultaneously.

Detainee participation in counts is prohibited.
A face-to-photo count follows each unsuccessful recount.

Officers positively identify each detainee before counting himlher as
present.
Written procedures cover informal and emergency counts.
They are followed during infolmal counts and 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.

•

o

[8J ACCEPTABLE

DEFICIENT

0

~

0

!81

0

0

~

0

0

!81

0
0

0
0

[8J

OAT-RISK

o

The policy does not address the
use of a face-to-photo count
following each unsuccessful
recount. Additionally, staff
interviews revealed a face-tophoto count rarely occurs and no
ID picture cards are maintained
within the Units to complete
such a count.
The policy addresses positive
identification of detainees.

REPEAT FINDING

REMARKS:

Around the clock accountability of detainees does occur at this facility; however, several policy and standard requirements are not
being followed. Activities do not cease and are not strictly controlled during formal counts as detainees were observed sitting in day
rooms, using telephones and watching television; movement does not cease for the duration of a formal count as evidenced by
relocation boards being updated during count procedures; face-to-photo counts following each unsuccessful recount does not occur as
observed during an emergency count conducted the first day of the review.
b6,b7c

/July 10.2008

AUDITOR's SIGNATURE/DATE

L
~

'-

b6,b7c

J - - - - - - - - - - - --------

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 57

POST ORDERS
POLICY: ICE PROVIDES OFFICERS ALL NECESSARY GUIDANCE FOR CARRYlNG OUT THElRDUTIES. TIns GUIDANCE INCLUDES TIIE 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.
Each set contains the latest inserts (emergency memoranda, etc.) and
revisions.
One individual or department is responsible for keeping all post-orders
current with revisions that take place between reviews.
The IGSA maintains a complete set (central file) of post orders.
The central file is accessible to all staff.
The orc or Contract/ IGSA equivalent initiates/aut40rizes all post-order
changes.
The orc or Contract 1 IGSA equivalent has signed and dated the last
page of every section.

Y
[gI

[]

NA
[J

[8J

0

0

[8J

0

0

LJ

l8J

[1

[]
[]

[8J

0

D·

~

N

0

[8J

0

[8]

0

0

[8J

0

0

0

0

181

0

0

181

~

[J

181

0

0
0

A review/updating/reissuing of post orders occurs regularly and at a
minimum, annually.

Procedures keep post orders and logbooks secure from detainees at all
times.
Every armed-post officer qualifies with the post weapon(s) before
assuming post duty.
Anned-post post orders provide instructions for escape attempts.

The post orders for housing units track the event schedule.
Housing-unit post officers record all detainee activity in a log. The post
order includes instructions on maintaining the logbook.

o DEFICIENT

[8J ACCEPTABLE

..

OAT-RISK

REMARKS

The Administrator and Assistant
Administrators for Security and
Operations sign the last page of
every post order; however, these
pages are not dated.
Facility policy - Security
Manual, Post Orders, Signature
Sheets, 03115/01, dated
February 6, 2008, Page 3,
Section 4, addresses the review,
updating, and reissuing of post
orders.

The facility has no armed posts;
therefore, no armed post orders
have been established.
The facility has no armed posts;
therefore, no armed post orders
have been established.

o REPEAT FINDING

REMARKS:

The post order system in place meets the standard requirements for legibility and relevance, chronological duties in sequence, duties,
expectations and responsibilities of the post, and they emphasize the safety, security, and supervision of detainees. The Administrator
and Assistant Administrators for Security and Operations sign the last page of every post order; however, these pages are not dated.

b6,b7c

I July 10. 2008
TURE/DATE

~

'j .

b6,b7c

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 58

-,

SECURITY INSPECTIONS

POLICY: POST ASS[GNMENTS IN TIlE FACILITY'S IDGH-lusK AREAS, WHERE SPECrAL SECURITY PROCEDURES MUST BE FOLLOWED, WILL BE
RESTRlCTED TO EXPERIENCED PERSONNEL WITH A THOROUGH GROUNDING IN FACILITY OPERATrONS.
COMPONENTS
No
NA
.REMARKS
YES
The facility has a comprehensive security inspection policy. The policy
specifies:
Policy Patrols and Inspections,
• Posts to be inspected;
03/15104, dated February 6,
• Required inspection forms;
0
t8J
0
2008, addresses security
Frequency
of
inspections;
•
inspections of the facility.
Guidelines
for
checking
security
features;
and
•
Procedures
for
reporting
weak
spots,
inconsistencies,
and
other
•
areas needing improvement
Every officer is required to conduct a security check ofhislher assigned
0
t8J
0
area. The results are documented.
Documentation of security inspections is kept on file.
Security reports within housing
. areas are maintained on file .
0
0 Outside Perimeter Checks are
t8J
logged in the Shift Commanders
Bound Log Book.
Procedures ensure that recurring problems and a failure to take corrective
The policy does not address
action are reported to the appropriate manager.
0
t8J
0 procedures regarding recurring
problems and corrective actions.
The front-entrance officer checks the ID of everyone entering or exiting
0
t8J
0
the facility.
.'

All visits are officially recorded in a visitor logbook or electronically
recorded.
The facility has a secure visitor pass system.
Every Control Center officer receives specialized training.

t8J

0

0

[8J

[J

[J

t8J

0

0

t8J

0

0

Staff interviews with the Shift
Commander revealed that
formal (specialized) training
does not occur with every
Control Center Officer. Control
Center Officers receive OJT
only with a Field Training
Officer prior to placement
within the Control Center.

The Control Center is staffed around the clock.

Policy restricts staff access to the Control Center.
b2High

0
Detainees are restricted from access to the Control Center.
Communications are centralized in the Control Center.
Officers monitor all vehicular traffic entering and leaving the facility.

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

--

-

--_. -

----

jgJ

0

[]

~-

[J

[J
[J

jgJ

0

D

-

- - - - - --

t8J

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

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

b2High

-

.. -

- - --_ ...

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 59

_-_._

..

---

SECURITY INSPECTIONS
POLICY: POST ASSIGNMENTS IN TIm FACILITY'S HIGH-RISK AREAS, WHERE SPECIAL SECURITY PROCEDtlRES MUST BE FOLLOWED, WIi.L BE
RESTRICTED TO EXPERIENCED PERSONNEL WITH A THOROUGH GROUNDING IN FACILITY OPERATIONS.
..
. REMARKS
COMPONENTS
YES
No
'NA
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;
b2High
[8J
0
0
• Vehicle contents;
Delivery
date
and
time;
•
• Date and time out;
• Vehicle license number; and
Name of employee responsible for the vehicle during the visit ~
Officers thoroughly search each vehicle enteriIig and leaving the facility.
[8J
~

•

0

0

~

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 sally port.
Written procedures govern searches of detainee housing units and
personal areas.

[8J

0

0

[8J

0

[8J

[]

0
[J

[8J

0

0

[8J

0

0

IZI

LJ

[J

[8J

0

0

0

[8J

0

Housing area searches occur at irregular times.

Every search of the SMU and other housing units is 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.

b2High

Official visitors as well as other
visits are subjected to a walkthru metal detector search as
well as bag search.

The facility policy - Facility and
Inmate Searches, 03/15/10,
dated February 6, 2008
addresses searches of detainee
housing units and personal
areas.
Policy 03/15/10 addresses
housing unit searches occurring
at irregular times and
documentation supports this
procedure occurs.

b2High

Daily procedures include:
• Perimeter alarm system tests;
• Physical checks of the perimeter fence; and
• Documenting the results.

0

[8J

0

Visitation areas receive frequent irregular inspections.

t8J

[J

[]

t8J ACCEPTABLE

o DEFICIENT

OAT-RISK

o REPEAT FINDING

FOR OFFICIAL USE ONLY (LA WENFORCEMENT SENSITIVE)
(i)

2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 60

REMARKS:

Current written procedures fail to be specific regarding recurring problems and. corrective actions and procedures for reporting weak
spots, inconsistencies, and other areas needing improvement. Observations in concert with staff interviews revealed the following
regarding Security Inspections:
b2High

b2High

b6,b7c

!../.!!.Ju,,-!1J..-.A.vlO~2~00~8,,--_~;bi__L-t

b6,b7c

AUDlTOR'SSIGNATURE/DATE

...

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
to 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 61

--

SPECIAL MANAGEMENT UNIT (SMU)
ADMINISTRATIVE SEGREGATION
POLICY: THE SPECIAL MANAGEMENT UNIT REQUIRED IN EVERY FACU,ITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL POPULATION.

Tfrn SPECIALMANAGBMENT 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
fDISCIPLINARY SEGREGATION1" STANDARD).
Y
NA
REMARKS
COMPONENTS
N
The Administrative Segregation unit provides non-punitive protection
from the general population and individuals undergoing disciplinary
segregation.
0
!8J
0
• 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.
!8J
0
0
• A copy of the order given to the detainee within 24 hours.
The facility policyThe OIC (or equivalent) regularly reviews the status of detainees in
Administrative Segregation,
administrative detention.
03/18/02,
dated February 6,
A
supervisory
officer
conducts
a
review
within
72
hours
of
the
•
2008, Page 4, Section D. 2,
detainee's placement in the SMU (administrative).
states detainees placed in AS
0
!8J
0
will have their status reviewed
by a member of the
Classification Staff within 3
working days.
A supervisory officer conducts another review after the detainee has
spent seven days in administrative segregation, and:
The policy states detainees
placed in AS will be reviewed
• Every week thereafter for the first month; and
!8J
0
0
weekly by the Classification
• Every 30 days after the first month.
Committee.
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 decisionandjustification for each
review.
0
0
• The detainee is given an opportunity to appeal the reviewer's !8J
decision to someone else in the facility.
The OIC (or equivalent) routinely notifies the Field Office Director (or
The policy does not address
notification of the OIC ofICE
staff officer in charge of IGSAs) any time a detaineers stay in
any time a detainee's stay in AS
administrative detention exceeds 30 days.
!8J
0 exceeds 30 days. Interviews
• Upon notification that the detainee's administrative segregation 0
with staff support this does not
has exceeded 60 days, the FD forwards written notice to HQ
happen as they only hold an ICE
Field Operations Branch Chief for DRO.
detainee for less than 72 hours.
The policy does not address
The OIC or equivalent) reviews the case of every detainee who objects
to administrative segregation after 30 days in the SMU;
reviewing the case of every
detainee who objects to AS after
• A written record is made of the decision and the justification. !8J
0
0
30 days in the SMU. Interviews
• The detainee receives a copy of this record.
indicate the Classification
Committee conducts this review.
The detainee is given the right to appeal to the OIC (or equivalent) the
conclusions and recommendations of any review conducted after the
!8J
0
0
detainee have remained in administrative segregation for seven
consecutive days.
Administratively segregated detainees enjoy the same general privileges
0
0
~
as detainees in the general population.

FOR OfFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
<C 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 62
_._----------------'

SPECIAL MANAGEMENT UNIT (SMU)
ADMlNISTRATIVE SEGREGATION
POLlCY: THE SPECIAL MANAOEMENT UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL POPULATION.
THE SPECIAL MANAGEMENT UNIT WILL CONSIST OF TWO SEG1JONS. 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
REMARKS
Y
N
NA
The SMU is:
• Well ventilated;
0
~
0
• Adequately lighted;
• Appropriately heated; and
• Maintained in a sanitary condition.
All cells are equipped with beds.
0
~
·0
• Every bed is 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 ~
0
0
living standards decline?
• Do criteria for objectively assessing living standards exist?
• If yes are the criteria included in the written procedures?
The segregated detainees have the same opportunities to
exchange/launder clothing, bedding, and linen as detainees in the
~
0
0
general population.
Detainees receive three nutritious meals per day, from the general
population's menu of the day.
0
~
0
• Do detainees eat oniy with disposable utensils?
• Is food ever used as punishment?
Each detainee maintains a normal level of personal hygiene in the SMU.
• The detainees have the opportunity to shower and shave at ~
0
0
least three times a week.
• If not, explain.
The detainees are provided:
• Barbering services;
• Recreation privileges in accordance with the "Detainee
Recreation" standard;
• Non-legal reading material;
0
0
~
• Religious material;
• The same correspondence privileges as detainees in the general
popUlation;
• Telephone access similar to that of the general population; and
• Personal legal material.
A health care professional visits every detainee at least three times a
A nurse visits the unit each day
week.
and their visit is logged within
0
0
~.
the bound log maintained in the
• The shift supervisor visits each detainee daily.
SMU Control Center.
• Weekends and holidays.
Procedures comply with the "Visitation" standard.
0
~
0
• The detainee retains visiting privileges; and
• The visiting room is available during normal visiting hours.
Visits from clergy are allowed.
[J
[J
l?:$J
Detainees have the same law-library access as the general population.
Legal materials are brought to
• Are they required to use the Jaw library OSeparatyly, or
~
0
0
them.
OAs a group?
Are
legal
materials
brought
to
them?
•

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 63

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).
.
NA
N
REMARKS
COMPONENTS
Y
This is maintained in a bound
The SMU maintains a permanent log of detainee-related activity, e.g.,
logbook maintained within the
meals served, recreation, visitors etc.
0
181
0
SMU Control Center.
The facility does not use Form ISPC procedWes include completing the SMU Housing Record (I-888)
888 or a local equivalent to
immediately upon a detainee's placement in the SMU.
[gJ
document
individual recreation,
Staff
completes
the
form
at
the
end
of
each
shift.
0
0
•
meals,
showers,
medical
CDFs
and
IGSA
facilities
use
Form
1-888
(or
local
equivalent).
•
attention etc.
A review of the bound logbook
Staffrecord whether the detainee ate, showered, exercised, and took any
maintained in the SMU Control
applicable medication during every shift.
Center revealed that staff does
• Staff logs record all pertinent information, e.g., a medical
record whether the detainee ate,
condition, suicidaVassaultive behavior, etc;
showered, or exercised.
• The medical officerihealth care professional signs each
However, the log does not
individual's record during each visit; and
specify which meal was eaten,
The
housing
officer
initials
the
record
when
all
detainee
•
[gJ
or the time of day showers or
0
0
services are. completed or at the end of the shift.
recreation took place. The
administration of medication
was also not recorded. The
medical professional does not
sign each individual record
during each visit as there is none
to sign.
A new record is created for each week the detainee is in Administrative
Segregation.
A new record is not created for
[gJ
0
each week the detainee is in AS.
• The weekly records are retained in the SMU until the 0
detainee's return to the general population.

o DEFICIENT

I2J ACCEPTABLE

OAT-RISK

o REPEAT FINDING

REMARKS:
Current policy does not address the notification oftbe OIC ofICE any time a detainee's stay in Administrative Detention exceeds 30
days. Interviews with staff indicate this does not happen, as ICE detainees are generally housed for less than 72 hours. The facility
does not use Form 1-888 or a local equivalent to document individual recreation, meals, showers, medical attention, etc., and as such
there is no individual record for a medical professional to sign daily.

b6,b7c

L

r / July 10,2008
NATURE/DATE \

Y

b6,b7c

.

\

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 64

SPECIAL MANAGEMENT UNIT
DISCIPLINARY SEGREGATION
POLICY: EACH FACILITY WILL ESTABLISH A SP!,!CIAL MANAGEMENT UNIT IN WInCH TO ISOLATE CERTAIN DETAINEES FROM THE GENERAL
POPULATION. THE SPECIAL MANAGEMENT UNIT WILL HAVE TWO SECTIQNS, ONE FOR DETAINEES IN ADMINISTRATIVE SEGREGATION; THE
OTHER FOR DETAINEES BEING SEG~ATED FOR DISCIPLINARY REASONS.
COMPONENTS
N
NA
Y
REMARKS
Officers placing detainees in disciplinary segregation follow written
0
~
0
procedures.
The sanctions for violations committed during one incident are limited
0
0
~
to 60 days.
A completed Disciplinary Segregation Order accompanies the detainee
into the SMU.
0
0
• 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 de~ention at set intervals.
0
0
• After each formal review, the detainee receives a written copy of ~
the decision and supporting reasons.
The conditions of confmement in the SMU are proportional to the
·0
~
0
amount of control necessary to protect detainees and staff.
Detainees in disciplinary segregation have fewer privileges than those
~
0
0
housed in administrative segregation.
Living conditions in disciplinary SMUs remain the same regardless of
behavior.
0
0
• Ifno, does staff prepare written documentation for this action? ~
• Does the OlC sign to indicate approval.
Every detainee in disciplinary segregation receives the same humane
~
0
0
treatment, regardless of offense.
The quarters used for segregation are:
• Well-ventilated.
• Adequately lighted.
0
0
~
• Appropriately heated.
• Maintained in a sanitary condition.
AU cells are equipped with beds that are securely faStened to the floor or
~
0
0
wall of the cell.
The number of detainees confined to each cell or room is limited to the
number for which the space was designate.
~
0
0
• Does the orc approve excess occupancy on a temporary basis?
When a detainee is segregated without clothing, mattress, blanket, or
The facility policy - Disciplinary
pillow (in a dry cell setting), a justification is made and the decision is
Detention, 03/18/04, dated
reviewed each shift. Items are returned as soon as it is safe.
February 6, 2008, Page 4,
Section 11, states anytime
beddmg, clothing, etc. must be
removed from the detainee to
0
0
~
protect the detainee from selfinflicted injuries or to prevent
acts of destruction, and the
circumstances will be
documented.
Detainees in the SMU have the same opportunities to exchange clothing,
~
0
0
bedding, etc. as other detainees.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 65

SPECIAL MANAGEMENT UNIT
DISCIPLINARY SEGREGATiON

EACH FACILITY WILL ESTABLISH A SPECrAL MANAGEMENT UNIT INWHICH.TO ISOLATE CERTAIN DETAINEES FROM THE GENERAL
POPULATION. THE SPECrAL MANAGEMENT UNIT WnL HAVE TWO SECTIONS. ONE FOR DETAINEES IN ADMINlSTRATIVESEGREGATION; THE
OTHER FOR DETAINEES BEING SEGREGATED FOR DISCIPLINARY REASONS.
NA
REMARKS
COMPONENTS
Y
N
Detainees in the SMU receive three nutritious meals per day, selected
from the Food Service's menu of the day.
0
~
0
• Food is not used as punishment.
Detainees are allowed to maintain a normal level of personal hygiene,
0
0
~
including the opportunity to shower and shave at least three times/week.
Detainees receive, unless documented a threat to security:
• Barbering services;
• Recreation privileges;
0
~
0
• Other-than-Iegal reading material;
• Religious material;
• The same correspondence privileges as other detainees; and
• Personal legal material.
When phone accesS is limited by number or type ofcalls, the following
areas are exempt:
• Calls about the detainee's immigration case or other legal
matters;
~
0
0
• Calls to consular/embassy officials; and
• Calls during family emergencies (as determined by the
OIC/Warden) ..
A health care professional visits every detainee in disciplinary
segregation every week day.
0
0
~
• The shift supervisor visits each segregated detainee daily
• Weekends and holidays,
SMU detainees are allowed visitors, in accordance with the "Visitation"
0
0
~
standard.
SMU detainees receive legal villits, as provided in the "Visitation"
standard.
0
0
• Legal service providers are notified of security concerns ~
arising before a visit.
Visits from clergy are allowed.
• The clergy member is given the option ofvisitinglnot visiting
the segregated detainee.
~
0
0
• Violent/uncooperative detainees are denied access to religious
services when safety and securi~would otherwise be affected.
SMU detainees have law library access.
• Violent/uncooperative detainees retain access to the law library
unless adjudicated a security threat in writing.
Legal materials are brought to
detainees on a case-by-case
D
0
• 'Legal material brought to individuals in the SMU on a case:-by- [8J
basis.
case basis.
Staff
documents
every
incident
of
denied
access
to
the
law
•
library.
This is maintained in a bound
All detainee-related activities are documented, e.g. meals served,
recreation activities, visitors, etc.
logbook maintained within the
[8J
0
0
SMU Control Center.

POLICY:

as

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
10 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 66

SPECIAL MANAGEMENT UNIT
DISCIPLINARY SEGREGATION
POllCY: EACH FACILI1Y WilL ESTABUSH A SPECIAL MANAGEMENT UNIT IN WHICH TO ISOLATE CERTAIN DETAINEES FROM TI-IE GENERAL
PoPULA'UpN. THE SPECIAL MANAGEMENT UNIT WilL HAVE TWO SECTIONS, ONE FOR DETAINEES IN ADMINISTRATIVE SEGREGATION; TIm
OTHER FOR DETAINEES BEING SEGREGATED FOR DISCIPLINARY REASONS.
Y
COMPONENTS
N
NA
REMARKS
The ~ the Special Management Housing Unit Record (I-888or
The facility does not use Form 1equivalent), is prepared as soon as the detainee is placed in the SMU.
888 or a local equivalent to
document individual recreation,
All
1-888s
are
filled
out
by
the
end
of
each
shift.
•
D
I2SI
D meals, showers, medical
The
CDFIIGSA
facility
use
Form.
•
attention, etc.
• 1-888 (or equivalent local form).
SMU staff record whether the detainee ate, showered, exercised, took
medication, etc.
• Details about the detainee logged, e.g., a medical condition,
suicidaVviolent 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 detainee leaves the
SMU.

o DEFICIENT

~ ACCEPTABLE

D

OAT-RISK

!8J

D

A review of the bound logbook
maintained in the SMU Control
Center revealed that staff does
record whether the detainee ate,
showered, or exercised.
However, the log does not
specifY which meal was eaten,
or the time of day showers or
recreation tookplace. The
administration of medication
was also not recorded The
medical professional does not
sign each individual record
during each visit as there is none
to sign.

o REPEAT FINDING

REMARKS:

b6,b7c

/ July 10, 2008
ATURE / DATE

1L-"

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 1218/07)

Page 67

TOOL CONTROL
POLICY: IT IS THE POllCY OF ALL FACILITIES THAT ALL EMPLOYEES SHALL BERESPONSlBLE FORCOMPLYING WTI1ITHE TOOL CONTROL POUCY.

THE MAINTENANCE SUPERVISOR SHALL MAINTAIN A COMPUTER GENERATED OR TYPEWRfITEN MAsTER INvENTORY UST OF TOOLS AND
EQUIPMENT AND THE LOCATION IN WHICH TOOLS ARE STORED. THEsE INVENTORIES SHALL BE CURRENT, FILED AND READILY AVAILABLE FOR
:rooL INVENTORY AND ACCOUNTABILITY DURING AN AVDIT.
COMPONENTS
Y
N
NA
REMARKS

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 the:
Maintenance Department;
Medial Department;
• Food Service Department;
• Electronics Shop;
• Recreation Department; and
• Armory.
The facility has a policy for the regular inventory of all tools.
• The policy sets minimum time lines for physical inventory and
all necessary documentation.
• ICE facilities use AMIS bar code labels when required.

•
•

The facility has a tool classification system. Tools are classified
according to:
• Restricted (dangerous/hazardous); and
Non-Restricted (non-hazardous).

•

Department heads are responsible for implementing tool-control"
procedures.

lZ?J

0

0

lZ?J

0

0

lZ?J

0

0

lZ?J

0

0

0

lZ?J

0

lZ?J

0

0

0

lZ?J

0

The facility haS policies and procedures in place to ensure that all tools
are marked and readily identifiable.

Facility policy - Tool and
Equipment, 03/15/12, dated
February 6, 2008, Page 1,
Section A, 2, states the
Maintenance Supervisor is
responsible for ensuring
compliance with the tool policy.

The policy addresses regular
inventories of all tools. The
policy does not set minimum
time lines for physical inventory
and all necessary
documentation. Tools are
inventoried weekly and
documentation is available
verifying weekly inventories.
The policy does not address a
tool classification system.
Interviews revealed the facility
does not have a tool
classification system.
The Medical, Food Service and
Maintenance Department are
tasked with this responsibility.
The policy does not address
marking tools to ensure they are
readily identifiable.
Observations of tools revealed
tools are not marked and readily
identifiable.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 68

TOOL CONTROL
POLlCY: IT IS THE POLICY OF ALL FACILITIES THAT ALL EMPLOYEES SHALL BE RESPONSIBLE FORCOMPLYING WIrnTHE TOOL CON1ROLPOLICY.
THE MAlNTENANCE SUPERVISOR SHALL MAINTAIN A COMPUTER GENERATED OR TYPEWRlTIEN 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.
Y
N
NA
REMARKS
COMPONENTS
Tools are stored within a Central
The facility has an approved tool storage system.
Tool Room located inside the
• The system ensures that all stored tools are accountable .
secure perimeter. Some tools
Commonly
used
tools
(tools
that
can
be
mounted),
are
•
are hung on hooks and
stored in such a way that missing tool is readily notice.
surrounded by a black outline.
~
0
0 Other tools are stored within
large tool storage carts. b2High
b2High

Each facility has procedures for the issuance of tools to staff and
detainees.

The facility has policies and procedures to address the issue oflost tools.
The policy and procedures include:
• Verbal and written notification;
• . Procedures for detainee access; and
• 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
ICE, or other visitors, submit an inventory of all tools prior to admittance
into or departure from the facility.

[g] ACCEPTABLE

o DEFICIENT

0

~

0

~

0

0

~

0

0

~

OAT-RISK

0

0

The policy only addresses that
food service utensils will be
signed out and in. The policy
does not address issuance of
tools to detainees in any area. .

Contractors submit an inventory
of all tools prior to coming to
the facility. That inventory is
checked by staff and maintained
on file upon the contractor's
departure.

o REPEAT FINDING

REMARKS:

Policy does not address the need for a tool classification system, marking tools to ensure they are readily identifiable, and the issuance
of tools to detainees in any area.
b2High
.
b2High

b6,b7c

(July 10. 2008

AUDITOR'S SIGNATURE I DATE

~
11"""
.

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 69

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

TRANSPORTATION
LAND TRANSPORTATION
POLICY: THE IMMIGRATION AND NATURALIZATION SERVICE WILL TAKE ALL NECESSARY PRECAUTIONS TO PROTBCT TIlE LIVES, SAFETY, AND
WELFARE OF OUR OFFICERS, TIlE GENERAL PUBUC, AND THOSE IN ICE CUSTODY DURING TIlE TRANSPORTATION OF DETAINEES. STANDARDS
HAVE BEEN ESTABLISHED FOR PROFESSIONAL TRANSPORTATION UNDER TIlE SUPERVISION OF EXPERIENCED AND TRAINED DETENTION
ENFORCEMENT OFFICERS OR AUTHORIZED CONTRACT PERSONNEL.
~ STANDARD NA: CHECK TIllS BOX IF ALL ICE TRANSPORTATION IS HANDLED ONLY BY TIlE ICE FIELD OFFICE OR SUB-OFFICE IN
CONTROL OF THE DETAINEE CASE.
COMPONENTS
YES
NA
REMARKS
NO
Transporting officers comply with applicable local, state, and federal
mot'or vehicle laws and regulations. Records support this finding of
D
D
0
compliance.
Every transporting officer required to drive a commercial size bus has a
valid Commercial Driver's License (CDL) issued by the state of
D
D
D
employment
[]
[]
Supervisors maintain records for each vehicle operator.
[J
Officers use a checklist during every vehicle inspection.
• Officers report deficiencies affecting operability; mid
D
D
• Deficiencies are corrected before the vehicle goes back into D
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;
D
D
• Drive a 50-hour maximum in a given work week; a 70-hour D
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 are two D
D
D
qualified officers per vehicle.
• An unaccompanied driver may transport an empty vehicle.
[]
[]
Before the start of each detail the vehicle is thoroUghly searched.
[J
[]
Positive identification of all detainees being transported is confirmed.
[J
LJ
All detainees are searched immediately prior to boarding the vehicle by
D
D
D
staff controlling the bus or vehicle.
The facility ensures that the number of detainees transported does not
D
D
0
exceed the vehicles manufacturer's occupancy level.
[ ]
[]
[]
Protective vests are provided to all transporting officers.
The vehicle crew conducts a visual count once all passengers are on
board and seated.
0
0
• Additional visual counts are made whenever the vehicle makes a 0
scheduled or unscheduled stop.
Policies and procedures are in place addressing the use of restraining
D
0
0
equipment on transportation vehicles.
Officers ensure that no one contacts the detainees.
0
0
• One officer remains in the vehicle at all times when detainees D
are present

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 70

TRANSPORTATION
LAND TRANSPORTATION
POLICY: THE IMMIGRATION AND NATURALIZATION SERVICE WlLL 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.

f2J STANDARD NA: CHECK THIS BOX IF ALL ICE TRANSPORTATION IS HANDLED ONLY BY THE ICE FIELD OFFICE OR SUB-OFFICE IN
CONI:ROL OF THE DETAINEE CASE.
REMARKS
YES
No
NA
COMPONENTS
Meals are provided during long distance transfers.
0
0
• The meals meet the minimum dietary standards, as identified by 0
dieticians utilized by ICE.
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
0
0
0
questions, concerns, or discrepancies with the Food Service
representative;
• Basins, latrines, and drinking-water containers/dispensers are
cleaned and sanitized on a fixed schedule.
Vehicles have:
• Two-way radios;
0
0
0
• Cellular telephones; and
• Equipment boxes stocked in accordance with the Use of Force
Standard.
The vehicles are clean and sanitary at all times.
0
0
Personal property of a detainee transferring to another facility is:
• Inventoried;
0
0
0
• 'Inspected; and
• Accompanies the detainee.
The following contingencies are included in the written procedures for
vehicle crews:
• Attack
• Escape
• Hostage-taking
• Detainee sickness
• Detainee death
0
0
0
• Vehicle fire
• Riot
• Traffic accident
• Mechanical problems
• Natural disasters
• Severe weather
Passenger list includes women or minors

rl

·

'

~ ACCEPTABLE

DDEFICIENT

D AT-RISK

D REPEAT FINDING

REMARKS:
All ICE transportation is handled only by the ICE sub-office in the control of the detainee's case.

/ July 10. 2008
b6,b7c
AUDITOR'SSIGNATURE/DATE

~
'ij -

b6,b7c

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
<02007 Creative Corrections, LLC (Rev. 1218/07)

Page 71
.

,,---"'-'

_.--,-----

USE OF FORCE
POLICY: THE U.S. DEPARTMENT OF HOMELAND SECURITY AUTIIORIZES TIlE USE OF FORCE ONLY AS ALAST ALTERNATIVE AFTER AIL OTIIER

REASONABLE EFFORTS TO RESOLVE A SITUATION HAVE FA.ILED. ONLY THAT AMOUNT OF FORCE NECESSARY TO GAIN CONTROL OF uiE
DETAINEE, TO PROTECT AND ENSURE TIlE SAFETY OF DETAINEES, STAFF AND OTIlERS, TO PREVENT SERIOUS PROPERTY DAMAGE AND TO
ENSUREINSTmJfION SECURITY AND GOOD ORDER MAYBE USED. PHYSICAL RESTRAINTS NECESSARYTO GAIN CONTROL OF ADETAINEE WHO
APPEARS TO BE DANGEROUS MAYBE EMPLOYED WHEN TIlE DETAINEE:
COMPONENTS

YES

No

NA

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 uses the Use-of-Force Team
Teclmique.
• Under staff supervision.

Staff members are trained in the performance of the Use-of-Force Team
Technique.

l'8l

D

D

t8J

D

D

D

l'8l

D

D

t8J

D

D

l'8l

D

l'8l

D

D

l'8l

D

D

All use-of-force incidents are documented and reviewed.

REMARKS

The facility endorses and uses
the Sheriffs Department Policy
Use of Fireanns, Use of Force,
03/15/15, dated February 6,
2008, which addresses staff
response in an immediate use of
force situation. It states the
deputies may use only the
degree of force which is
reasonable and immediately
necessarytoprotectthernsel(
The policy addresses resolving
the situation without resorting to
force if possible.
The policy does not specifically
assert that calculated rather than
immediate use of force is
feasible in most cases.
The policy does not specifically
subscribe to prescribed
Confrontation Avoidance
Procedures. Interviews verified
that a ranking detention official,
a health professional, and others
confer before every calculated
use offorce.
The policy does not endorse or
address the Use of Force Team
technique. Interviews and
documentation reviewed
indicate staff does not always
use the Use of Force Team
Technique under a supervisor's
direction.
All staff receives training in the
Use of force Team Teclmique
and CERT receives additional
training in the technique.
A Use of Force Incident Form is
utilized for this purpose and
reviewed by the Captain over
Security and the Assistant
Administrator of Security.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
to 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 72

USE OF FORCE
POLICY: THE U.S. DEPARTMENT OF HOMELAND SECURTIY AUTHORIZES THE USE OF FORCE ONLY AS ALAST ALTERNATIYE AFfERALL OTHER
RI;:ASONADLE EFFORTS TO RESOLVE A SITUATION HAVE FAlLED. ONLy THAT AMOUNT OF FORCE NECESSARY TO GAIN CONTROL OF THE
DETAINEE, TO PROTECf AND ENSURE THE SAFETY OF DETAINEES, STAFF AND OTHERS, TO PREVENT SERIOUS PROPERTY DAMAGE AND TO
ENSURE INSTrrUrION SECURITY AND GOOD ORDER MAY BE USED. PHYSlCALlrnSTRAlNTS NECESSARY TO GAIN CONTROL OF ADETAINEE WHO
APPEARS TO BE DANGEROUS MAY BE EMPLOYED WHEN THE DETAINEE:
NA
REMARKS
COMPONENTS
YES
No
Staff:
• Do not use force as punishment;
• Attempt to gain the detainee's voluntary cooperation before
resorting to force;
[8J
0
0
• Use only as much force as necessary to control the
detainee; and
• Use restraints only when other non-confrontational means,
including verbal persuasion, have failed or are impractical.
Medication may only be used for restraint purposes when authorized by
[8J
0
0
the Medical Authority as medically necessary.
Use-of-Force Team follows written procedures that attempt to prevent
Universal precautions are used
[8J
0
0
injury and exposure to communicable disease(s).
.
routinely.
Standard procedures associated with using four-point restraints include:
• Soft restraints (e.g., vinyl);
Facility policy - Use of
Restraints 03/15/08, dated
• Dressing the detainee apprQpriately for the temperature;
February 6, 2008, addresses
• A bed, mattress, and blanket/sheet;
standard procedures associated
• Checking the detainee at least every 15 minutes;
with using four-point restraints.
• Logging each check;
[8J
0
0
However,
interviews with staff
Turning
the
bed-restrained
detainee
often
enough
to
prevent
•
indicate four-point restraints are
soreness or stiffuess;
not used within the facility.
• Medical evaluation of the restrained detainee twice per
Fixed restraints only occur with
eight-hour shift; and
use of the restraint chair.
the
• When qualified medical staff is not immediately available,
staff position the detainee "face-up".
The shift supervisor monitors the detainee's position/condition every two
The restraint policy does not
hours.
address the Shift Commander's
[8J
role in monitoring the detainee's
0
• He/she allows the detainee to use the rest room at these 0
times under safeguards.
position and use of the rest room
at these times.
[8J
All detainee checks are logged.
[J
[J
In immediate-use-of-force situations, staff contacts medical staff once the
The restraint policy addresses
[8J
detainee is under control.
contacting medical staff and
0
0
their role.
When the OlC authorizes use of non-lethal weapons:
The Use of Force policy does
not address the use of non-lethal
• Medical staff is consulted before staff use pepper
weapons. Interviews and
spray/non-lethal weapj)ns.
[8J
Medical
staff
reviews
the
detainee's
medical
file
before
use
.0 documentation indicate medical
0
•
staff is not routinely consulted
of a non-lethal weapon is authorized.
before staffuse chemical
munitions.
Special precautions are taken when restraining pregnant detainees.
The restraint policy does not
addresses special precautions
• Medical personnel are consulted
[8J
0
0 when restraining pregnant
detainees.
Protective gear is worn when restraining detainees with open cuts or
Universal precautions are
[8J
0
0 routinely used.
wounds.
Staff documents every use of force andlor non-routine application of
[8J
0
0
restraints.

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
10 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 73

. USE OF FORCE
POLICY: THE U.S. DEPARTMENT OF HOMELAND SECURITY AUTHORIZES THE USE OF FORCE ONLY AS ALASTALTERNATIVEAFTERALLoiHER.
REASONABLE EFFORTS TO RESOLVE A SITUATION HAVE FAILED. ONLY THAT AMOUNT OF FORCBNECESSARY TO GAIN CONTROL OF THE
DETAINEE, TO PROTECT AND ENSURE TIlE SAFETY OF DETAINEES, STAFF AND OTHERS, TO PREVENT SERIOUS PROPERTY DAMAGE AND TO
ENSURE INSTITUTION SECUlUTY AND GOOD ORDERMAY BE USED. PHYSICAL REsTRAINTS NECESSARY TO GAIN CONTROL OF A DETAINEE WHO
APPEARS TO BE DANGEROUS MAY BE EMPLOYED WHEN THE DETAINEE:
COMPONENTS
No
NA
REMARKS
YES

It is standard practice to review any use of force and the non-routine
a lication of restraints.
All officers receive training in self-defense, confrontation-avoidance
techniques and the use of force to control detainees.
• Specialized training is given and Officers are certified in all
devices they use.
In §PCs. is the Use of Force fonn is used? In other facilities (IGSAs 1
CDFs is this fonn or its equivalent used?

0

k8J ACCEPTABLE

DEFICIENT

OAT-RISK

o

o

o

o

D

o
D REPEAT FINDING

REMARKS:

The Use of Force policy does not address the following: that calculated rather than immediate use of force is feasible in most cases;
specifically subscribes to prescribed confrontation avoidance procedures where the ranking detention official, a health professional,
and others confer before every calculated use offorce; the use of special precautions when restraining pregnant detainees; the Shift
Commander's role in monitoring the detainee's position and use of the rest room when prolonged use of restraints occurs; and when the
use of non-lethal weapons is imminent that medical staff must be consulted before correctional staff uses chemical munitions.

b6,b7c

1 July 10, 2008

AUDITOR'SSIGNATURE/DATE

~--.-

..

I

~
'

~

b6,b7c

~

.... - ...

2
FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
"'" 007 Creative Corrections, LLC (Rev. 12/8/07)

Page 74

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

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

STAFF DETAINEE COMMUNICATIONS
POLley: 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.

COMPONENTS
The ICE Field Office Director ensW'es 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 llosted in ICE detainee areas.
Visiting staff observe and note current climate and conditions of
confmement 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 responds to a detainee request from an IGSA within 72 hours.
ICE detainees are notified in writing upon admission to the facility of
their right to correspond with ICE staff regarding their case or conditions
of confinement.

o

t8l ACCEPTABLE

DEFICIENT

Y

N

NA

~

0

0

~

~

0
0
0

0
0
0

~

0

0

~

0

0

ILSl

LJ

[]

~

~

OAT-RISK

D

0

o

REMARKS

Detainees are notified in writing
upon admission to the facility of
their right to correspond with
ICE staff regarding their case or
conditions of confinement.
REPEAT FINDING

REMARKS:

The detainees are allowed formal and informal contact with key ICE staff, and are provided means for communication with ICE
representatives via written requests. They receive adequate answers from ICE in a timely manner.

b6,b7c

JulyIQ,2Q08

AUDlTOR'SSIGNATURE/DATE

k

,.,~ -

b6,b7c

\.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
<02007 Creative Corrections, LLC (Rev. 12/8/07)
--

Page 75

.-------------------------"

DETAINEE TRANSFER STANDARD
POLICY: ICE WILL MAKE ALL NECESSARY NOTIFICATIONS WHEN ADETAINEE IS TRANSFERRED. IF ADETAINEE IS BEIl':lGTRANSFERRED VIA TIiE
JUSTI9B PRISONER ALIEN TRANSPORTATION· SYSTEM (JPATS), ICE WIIi ADHERE TO JPATS PROTOCOLS. IN ])ECIDING WHETHER TO
TRANSFER ADETAINEE, ICE WD.L TAKE INTO CONSIDERATIONWHETIiER TIiE DETAINEE IS REPRESENrEo BEFORE THE IMMIGRATION COURT. IN
SUCHCASES, TIiE FrnLD OFFICE DIRECTOR WILL CONSIDER THE DETAINEE'S STAGE WITHINTHEREMOVALPROCBSS, WHEfHER THE DETAINEE'S
ATIORNEY IS LOCATED WITHIN REASONABLE DRIVING DISTANCE OF THE FACILITY, AND WHERE THE IMMIGRATION COURT PROCEEDINGS ARE
TAKING PLACE.
RE~KS·
COMPONENTS
Y
N
NA
When a detainee is represented by legal counselor a legal representative,
and a G-28 has been flled, the representative of record is notified by the
detainee's Deportation Officer.
[8J
0
0
• The notification is recorded in the detainee's file; and
• When the A File is not available, notification is noted within
DACS
Notification includes the reason for the transfer and the location of the
[8J
0
0
new facility.
The deportation officer is allowed discretion regarding the timing of the
[8J
0
0
notification when extenuating circumstances are involved.
The attorney and detainee are notified that it is their responsibility to
[8J
0
0
notify family members reKarding a transfer.
Facility policy mandates that:
• Times and transfer plans are never discussed with the detainee
prior to transfer;
0
0
• The detainee is not notified of the transfer until immediately [gJ
prior to departing the facility; and
• The detainee i~ not permitted to make any phone calls or have
contact with any detainee in the general population.
The detainee is provided with a completed Detainee Transfer Notification
[gJ
0
0
Form.
FOIm G-391 or equivalent authorizing the removal of a detainee from a
[gJ
0
0
facility is used.
For medical transfers:
• The Detainee Immigration Health Service (or rGSA) (DIHS)
Medical Director or designee approves the transfer;
0
0
• Medical transfers are coordinated through the local rCE office; [gJ
and
• 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
[gJ
0
0
with the detainee's name and A-number, and the envelope is marked
Medical Confidential.
For medical transfers, transporting officers receive instructions regarding
[8]
0
0
medical issues.
Detainee's funds, valuables, and property are returned and transferred
[8]
0
0
with the detainee to hislher new location.
Transfer and documentary procedures outlined in Section C and D are
[gJ
0
0
followed.
Meals are provided when transfers occur during normally schedule meal
[8]
0
0
times.
An A File or work folder accompanies the detainee when transferred to a
[gJ
0
0
different field office or sub-office.

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
\0 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 76

DETAINEE TRANSFER STANDARD

,
POLICY: ICE WILL MAKE ALL NECESSARY NOTIFICATIONS WHEN ADETAINEE IS TRANSFERRED. IF ADETAINEE IS BEING TRANSFERRED VIA THE
JUSTICE PRISONER ALIEN' TRANSPORTATION SYSTEM (JPATS), ICE WILL ADHERE TO JPATS PROTOCOLS. lNbECIDING WHETHER TO
TRANSFERADETAINEE, ICE WILL TAKE INTO CONSIDERATION WHETHER THE DETAINEE IS REPRESENfED BEFORE THE IMMIGRATION COURT. IN
SUCH CASES, THEFrnLD OFFICE DIRECTOR WILL CONSIDER THE DETAINEE'S STAGE WITIIINTHEREMOVALPROCESS, WHETHER THE DETAINEE'S
ATTORNEY IS LOCATED WITHIN REASONABLE DRIVING DISTANCE OF THE FACILITY, AND WHERE THE IMMIGRATION COURT PROCEEDINGS ARE
TAKING PLACE.
NA
COMPONENTs
Y
N
REMARKS
Files are forwarded to the receiving office via overnight mail no latedhan
[8J
one business day following the transfer.

0

~ ACCEPTABLE

DDEFICIENT

D

AT-RISK

0

D REPEAT FINDING

REMARKS:

The facility has good procedures in place to ensure that ICE makes all appropriate notifications when a detainee is transferred.

b6,b7c

1July 10. 2008

~

b6,b7c

AUDITOR'SSIGNATURE/DATE'f .

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 77