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ICE Detention Standards Compliance Audit - El Centro Service Processing Center, El Centro, CA, ICE, 2004

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Office ofDetention and Removal Operations
U.S. Department of Homeland Security
425 I Street, NW
Washington, DC 20536

•

~

:s

~1Iii

Sti

U.S. Immigration
and Customs
Enforcement

t-'lt>.R \ 6 2.005
MEMORANDUM FOR:

FROM:

SUBJECT:

b6, b7C

I Centro Service Processing Center

This office is in receipt of the Plan of Action (POA) for the El Centro Service Processing Center in
response to the detention review conducted on July 27-29, 2004. The POA is accepted and this
review is considered closed.

(

The Field Office Director must initiate the following action in accordance with Detention
Management Control Program (DMCP):
The Field Office Director, Detention and Removal Operations, shall notify the facility within
five business days of receipt of this memorandum, that the POA has been accepted and the
review closed. Notification shall include a copy of this memorandum.
Should you or your staffhave any questions regarding this matter, please contact
Deputy Assistant Director, Detention Management Division at (202) 305 b2 high

I

\.

b6, b7C

Detention & Removal Operations

U.S. Department of Homeland Security
880 Front Street Ste. 2242
San Diego, CA 9210 I

u.s. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

b6, b7C

Acting De ty Assistant Director
Dete .
.vision
FROM:

a .
1
Field Office Director

SUBJECT:

Follow-up Action Plan/Headquarters Review National
Detention Standards.

Hold Rooms - Repeat Deficiencv:
•

(

Detainees are held in Hold Rooms for more than 12 hours.

The facility has been able to dedicate a dormitory to function as a pre-housing staging area for
new arrivals. This initiative has allowed the facility to drastically reduce the number of
instances wherein a detainee would be held in hold rooms in excess of 12 hours. In the event
the 12 hour rule is exceeded, a memorandum must be prepared and forwarded through
channels by the on duty Supervisory Immigration Enforcement Agent (SIEA) to the OIC citing
reasons for infraction.

Food Service - Deficient:
•
•
•
•

Poor sanitation conditions
Staff and detainees consume food in preparation areas
Detainees' shoes are stored throughout food service area
Broken refrigeration unit in use

The sanitation conditions pointed out by the review team were immediately corrected.
The consumption of food in the Dining Facility's food preparation area is strictly prohibited.
Employees as well as detainee workers are aware (through continuous training provided) that it
is a health code violation to deviate from this policy. Food service and operations staff will
continuously monitor this situation to ensure adherence. Additionally, signs will be posted
throughout the food preparation area as a constant reminder. It has also been emphasized that
any deviation from this policy will be dealt with immediately- no exceptions.
The facility has provided the food service department with a shoe rack located in the utility
area. The shoe rack provides detainees an appropriate location to store their shoes, eliminating
the need of leaving footwear in the dried food storage area.
The broken refrigeration unit identified has been removed from the facility. The food service
department has installed Dixon digital thermometers and recorders in every refrigerator and

SUBJECT: Follow-up Action PlanlHeadquarters Review - National Detention Standards
Page 2
freezer. The thennometer and recorder continually records temperatures, providing record of
temperature fluctuations. The thennometers and recorders are continually checked through out
the day. A log sheet is maintained in an effort to record dates/times employees conduct
refrigerator and freezer inspections.
Collapsible Steel Batons:

Collapsible steel batons are no longer pennitted inside the facility. All staff members have
been advised by memorandum, and are presently in compliance with this mandate.

(

Office ofDetentiOil aJ1d Removal Opera/jom
C.S. Department of Homeland Security

425 I Street NW
Washington, DC 20536

U. S. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

b6, b7C

FROM:

SUBJECT:

(

Review Summary Report for EI Centro Service Processing Center

The Headquarters Office of Detention and Removal Operations (HQDRO) performed a detention
operations review of the EI Centro Service Processing Center on July 27 - 29,2004, at El Centro,
California. A rating of Acceptable has been assigned.
This rating was based on the Reviewer-In-Charge (RIC) Summary Memorandum and supporting
documentation. The San Diego Field Office must correct the deficiencies noted in the RIC
memorandum and initiate the following actions in accordance with the Detention Management
Control Program:
1) The Field Office Director, Detention and Removal Operations, shall notifY the facility within
five business days of receipt of this memorandum. Notification shall include copies of the
Form G-324A, Detention Facility Review Form, the G-324A worksheet, RIC Summary
Memorandum, and a copy of this memorandum.
2) The Field Office Director is responsible for ensuring that the facility responds to all findings
and a plan of action is submitted to the Review Authority (RA) within 30 days.
3) Once a plan of action is approved, the Field Office Director shall schedule and follow up on
the above noted deficiencies within 90 days of receipt of the facility's plan of action.
Should you or your staff have any questions regarding this matter, please contact
b6, b7C
, Acting Deputy Assistant Director, Detention Management Division at
(202) 305 b2 high
cc: Deputy Assistant Director, Field Operations Division

(

Auice ofDe lenti011 and Remo>'ai OperatjOl~~
. S . Department of Homeland Security
425 J Street, NW
Washington, DC 20536

U.S. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

b6, b7C

Acting Director
b6, b7C

FROM:

b6, b7C

Detention and De
Detention Compliance Branch
SUBJECT:

(

Headquarters Detention Review - El Centro Service Processing Center

The Detention Compliance Unit performed a review ofthe EI Centro Service Processing Center
(SPC) on July 27-29,2004. This review was performed under the supervision of
b6, b7C
b6, b7C
Reviewer-In-Charge (RIC) with team members,
,
b6, b7C
b6, b7C
and
. The Detention Compliance Unit last performed a review of the facility on
January 27,2003.

,

Type of Review:
This review is a scheduled Headquarters Review and was conducted to determine overall
compliance with the Immigration and Customs Enforcement (ICE) National Detention standards.
Review Summary:
The American Correctional Association (ACA) does not currently accredit the El Centro SPC. The
facility is accredited by the National Commission on Correctional Health Care and the Joint
Accreditation Commission for Healthcare.
The following information summarizes those standards not in compliance. Each standard is
identified and a short summary provided regarding standards or procedures not currently in
compliance.

www.ice.gov

(

Subject: EI Centro Service Processing Center Review Sununary Report
Page 2

January 2004 Review

July 2004 Review

Acceptable 33
Deficient 2
Repeat Deficiency - 2
At-Risk 0

Acceptable 35
Deficient 1
Repeat Deficiency - 1
At-Risk 0

Hold Rooms - Repeat Deficiency:

•

Detainees are held in Hold Rooms for more than 12 hours.
Hold Rooms have been a repeat deficiency at the facility for the past few years. The
processing area Hold Room logs document that in some cases detainees are being
held past the permitted 12 hours. The auditors were told the reason for the delay was
due to current staffing levels. A review of the current vacancies does indicate the
facility is not currently up to its authorized staffing level. The Officer in Charge
(OIC) was aware ofthe problem and requires the Detention Management staff to
write a memorandum of explanation every time detainees are in the processing Hold
Rooms for more then 12 hours. The OIC aggressively pursues filling facility
vacancies through the San Diego Field Office.

(

Food Service - Deficient:
•
•
•
•

Poor sanitation conditions
Staff and detainees consume food in preparation areas
Detainees' shoes stored throughout food service area
Broken refrigeration unit in use
The Food Service Department is extremely busy, on average preparing and serving
approximately 1500 well balanced meals a day. The Food Service staff is to be
commended for their success. However, the review team felt the sanitation levels in
the kitchen were not up to standards. Poor sanitation conditions were observed on
food service equipment, kitchen floors, and in floor drains. A review of the ·freezer
temperature logs revealed that on one occasion the temperature of a freezer had risen
to 64 degrees. When questioned, the Food Service Department was unable to
determine how long the freezer had been above the acceptable temperature of 32
degrees. The review team was advised the food had been relocated to another
working freezer rather than throwing it away.

Subject: El Centro Service!cessing Center Review Summary Re!

(

Page 3
Staff and detainees were observed consuming food in the food preparation areas and
during the review numerous detainees' shoes were found stored throughout the food
storage areas. The facility took immediate action to correct all deficiencies found by
the reviewers.
Other Issues:

•

Collapsible Steel Batons:
Collapsible steel batons are still carried by officers inside the facility as authorized by the
OIC. OIC
stated that these batons were needed for the safety of his officers and
b6, b7C
that he has never seen nor received any written directive preventing the practice. The OIC
advised that consistent with policy, only fully qualified officers are authorized to carry the
collapsible steal batons.

•

American Correctional Association (ACA) Accreditation:
The facility currently has a three-man team, working full time preparing the facility for
accreditation. The team, headed by Supervisory Immigration Enforcement Agent b6, b7C
b6, b7C
has completed 122 files and of those 66 have been reviewed, approved and signed
into policy by the OIC. The team advised that they report monthly to the HQDRO ACA
b6, b7C
liaison,
and are confident with her assistance the facility will attain
accreditation.

(
•

Construction:
The administration area ofthe facility is currently under construction. The estimated
completion date is scheduled for September. Four ofthe facility pods (Limo, Kilo, Nancy
and Mike) were recently painted to improve the quality of life for detainees. There are no
major renovation projects scheduled for the EI Centro spc.

RIC Observations:
•

Overall Cleanliness of the Facility:
The overall sanitation ofthe facility (outside Food Service) was very good. Detainees were
continuously observed cleaning throughout the review.

•

Staff Cooperation and Professionalism:
The OIC and staffwere very professional and all information requested was immediately
provided. Staff was knowledgeable about their assigned posts and presented very
b6, b7C
professional demeanor. Mr.
and Mr.
were extremely helpful
b6, b7C
and assisted the team members throughout the review. Their knowledge ofthe National
Detention Standards is an asset to the facility.

(

Subject: El Centro Service Processing Center Review Summary Report
Page 4
Recommended Rating and Justification:
It is the RIC recommendation that the facility receive a rating of "Acceptable." The El Centro SPC
has made significant improvements since the last HQ review. These improvements have greatly
improved the quality of life for detainees. The facility now fully complies with 35 of37 standards.
RIC Assurance Statement:
It is the opinion of this RIC that the findings of compliance and non-compliance are documented on
the G-324a inspection form and that it is supported by documentation in the review file.

(

tit Detention Facility Review Form

u.s. Department Of Homeland securi'
U.S. Immigration and Customs Enforcement
( J

Facilities Used Over 72 hours
E.
Accreditation Certificates
Accredited By:
NCCHC: [gI JCARO: [8J
ACA: 0
Date:
Date: lf2003
Date: 3/2003

ICE Service Processing Center
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

o
o

A. Current Inspection
Type of Review
Field Office [8J HQ Review
Date[s] of Review
July 27-29,2004

o

o
o

PreviousIMost Recent Review
Date[s] of Last Review
January 27 - 29th, 2004
Previous Rating
S~or 0 Good 0 Acceptable [8J Deficient 0 At-Risk

o

B.

(

'I

Name and Location of Facility

Name
EI Centro Service Processin2 Center
Address (Street and Name)
1115 N. Imperial Ave.
City, State and Zip Code
EI Centro CA.
92243
County
Imperial
Name and ntle of Chief Executive Offi~er (Warden/OIC/Superintendent)
,Officer-ln-Charee
b6, b7C
Telephone # (Include Area Code)
(760) 33 b6, b7C
'strict
.mDiego
Distan~e from District Office
120 miles

G. Facility History
Date Built
1975
Date Last Remodeled or Upgraded
Ongoing
Date New Construction / Bedspace Added
None
Future Construction Planned
[8J Yes 0 No Date:
Current Bedspace
Future Bedspace
Operational Level 500
544

I

H. Total Facility Population
Total Intake for previous 12 months
8,637
Total Mandays for Previous 12 months
12.20

r.

Facility Capacity
Rated
I Adult Male
544
I Adult Female

D C DF/IGS A Intiormation 0 nly
Contract Number
Date of Contract or IGSA

I

o

CI assl'fiIcaf IOn L eve I (ICE SPC sand CDFs 0 nIYJ
1)
L-l
L-2
L-3
I Adult Male
173
26
219
r Adult Female
0
0
0

C. ICE Information
Name of Reviewer (Last Name, Title and Duty Station)
b6, b7C / DDO / HQDRO
Last Name I Title of Team Members (Reviewers)
(b)(6), (b)(7)c / DO; Ramos / DO; Vachon / PHS
Controlling Field Office
SND
Nearest Field or Sub-Office
120 miles

.

F.
Problems I Complaints (Copies must be attached)
The Facility is under Court Order or Class Action Finding
Court Order
0 Class Action Order
The Facility has Significant Litigation Pending
Life/Safety Issues
Maior Litigation
Checked Box above reQuires a detailed written memornndum.

Average D aily Population
ICE
I Adult Male
430
0
I Adult Female

Operational
450

USMS

Emergency
560

Other

Basic Rates per Man-Day
Other Charges: .(IfNone, Indicate N/A)

,

,

,

Staffing Level
Security:
b2 high

b2 high

Estimated Man-days Per Year

Form G-324A (Rev. 9/25/03) No Prior Version MayBe Used After 12/31/03

(
Significant Incident Summary Worksheet
\ ~. -.lr ICE to complete its Review of your facility, the following information must be completed prior to the scheduled review dates.
The information on this form should contain data for the past twelve months in the boxes provided. The information on this form is
used in conjunction with the ICE Detention Standards in assessing your Detention Operations against the needs of the ICE and its
detained population. This form should be filled out by the facility prior to the start of any inspection.

2
Assault:
Offenders on
Offenders l

Assault:
Detainee on
Staff

0

0

o

o

2

2

o

o

0

o

0

o

o

0

o

o

0

0

o

o

0

0

o

o

0

0

o

o

0

0

o

o

0

0

o

o

0

0

o

o

0

# Times Four/Five Point
straints applied/used
Offender I Detainee Medical
Referrals as a result of injuries

2

0

0

o

o

0

0

o

o

7

21

9

3

18

8

I-I

o

o

o

o

7

27

43

0

3

Escapes

Grievances:

0

Deaths

0
Psychiatric / Medical Referrals

4

(

# Medical Cases referred for
Outside Care
# Psychiatric Cases referred for
Outside Care

2

5

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

Form G-324A (Rev. 9/25/03) No Prior Version MayBe Used After 12/31/03

6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.

Admission
Release
Classification System
Correspondence and Other Mail
Detainee Handbook
Food Service
Funds and Personal Property
Detainee Grievance Procedures
Issuance and Exchange of Clothing, Bedding, and Towels
Marriage Requests
Non-Medical Emergency Escorted Trip
Recreation
Religious Practices
V"llllnjr<>rvWork .... r",ar"·rn

23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.

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

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

(
Form G-324A (Rev. 9/25/03) No Prior Version May Be Used After l2/31103

(

RIC Review Assurance Statement

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

Signature

Reviewer-In-Cbarge: (Print Name)

b6, b7C
b6, b7C

Title & Duty Location

Date

Detention &

08/03/04

ortation Officer- HQDRO

Print Name & Duty Location
b6, b7C

Print Name & Duty Location

DO- Sioux Fails, Mn

b6, b7C

Print Name & Duty Location
b6, b7C

n, PHS- Miami,Fl.

Print Name & Duty Location

DO- Chicago, II

Superior
ClUe Rating Recommendation: oo Good

~ Acceptable

o Deficient
OAt-Risk

RIC Comments: It is the RIC recommendation that the facility recieve a rating of" Acceptable." The El Centro Service Processing
Center has made significant advances in critical areas bringing the facility into compliance. All but one previousely noted deficiency
has been corrected. New deficiencies noted in Food Service during the review were immediately corrected.

(
Fonn G-324A (Rev. 9/25/03) No Prior Version May Be Used After 12/31103

(

:ADQUARTERS EXECUTIVE REVIEW

I Review Authority·

. . :.;

";.:

The signature below constitutes review of this report and acceptance by the Review Authority. FD/OICICEO wiD have 30 days
from receipt of this report to respond to aU findings and recommenda
~DRO

EXECUTIVE REVIEW: (Please Print Name)

Signatur

b6, b7C

b6, b7C

Date

Title

Actin Director

Final Rating:

D Superior
DGood
IZI Acceptable
D Deficient
D At-Risk

Comments:
It is the RIC recommendation that the facility receive a rating of "Acceptable." The EI Centro SPC has
made significant improvements since the last HQ review. These improvements have greatly improVed the quality ofHfe for
detainees. The facility now fully complies with 35 of 37 standards.

(
Form G-324A (Rev. 9/25/03) No Prior Version May Be Used After 12131103

Department of HomelanclecUrity
Immigration and Customs Enforcement
Office of Detention and Removal

(

Condition of Confinement Review Worksheet
(This document must be attached to each G-324a Inspection Form)

This Form to be used for Detention Reviews of SPCs

Headquarters Detention and Removal Operations

(

H eadlquart ers an

Ie

Ipera lonalReVlew W orksh eets
I

Immigration and Customs Enfrocement

\

Name
EI Centro Service Processing Center
Address (Street and Name)
1115 North Imperial Ave.
City, State and Zip Code
Elcentro, Ca. 92243
County
Imperial
Name and Title of Chief Executive Officer (Warden/O/C/Superintendent)
b6, b7C
l OIC
Nam
ewer-In-Charge
b6, b7C

(

Date{s} of Review
July 27-29. 2004
Type of Review
[X }Headquarters D Operational

DSpecial Assessment

o Other

Department of Homelamlcurity
Immigration and Customs Enforcement
Office of Detention and Removal

•

Condition of Confinement Review Worksheet
(This document must be attached to each G-324a Inspection Form)
This Form to be used for Detention Reviews of spes

Headquarters Detention and Removal Operations

(

Detainee Services
Section I

(

ACCESS TO LEGAL MATERIALS
Policy: Facilities holding ICE detainees shall permit detainees' access to a law library, and provide legal
materials, facilities, equipment and document copying privileges, and the opportunity to prepare legal
documents.

(

(

Components

A

U

NA

The facility provides a deSignated law library for
detainee use.
The library contains a sufficient number of chairs, is well
lit and is reasonably isolated from noisy areas.
The law library is adequately equipped with typewriter,
computers or both and has sufficient supplies for daily
use by the detainees.
There is a designated ICE ·employee responsible for
ensuring the equipment is in good working order and
supplies are adequately stocked.
Outside persons and organizations are permitted to
submit published legal material for inclusion in the legal
library. Outside published material is forwarded and
reviewed by the ICE prior to inclusion.
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 ICE office subscribes to updating Services where
applicable and legal materials requiring updates are
current.
There is a designated ICE employee who inspects,
updates, and maintain/replace legal material on a
routine basis. The designee properly disposes outdated
supplements and replaces damaged or missing material
promptly.
If material submitted by outside organizations need to
be replaced, does the facility contact ICE?
Detainees are offered a minimum 5 hours per week in
the law library. Detainees are not required to forego
recreation time in lieu of library usage. Detainees facing
a court deadline are given priority use of the law library.
Detainees may request material not currently in the law
library. Each request is reviewed and where appropriate
an acquisition request is initiate and timely pursued.
Request for copies of court decisions are accommodate
within 3 - 5 business days.
The facility permits detainees to assist other detainees,
voluntarily and free of charge, in researching and
preparing legal documents, consistent with security.
The ICE ensures that illiterate or non-English-speaking
detainees without legal representation receive more
than access to English-language law books after
indicating their need for help.
Detainees may retain a reasonable amount of personal
legal material in the general population and in the
special management unit. Stored legal materials are
accessible within 24 hours of a written request.

[8J

D

D

[8J

D

D

[8J

D

D

[8J

D

D

I8l

D

D

I8l

D

D

I8l

D

D

I8l

D

D

I8l

D

D

Remarks

Recreation Specialist

[g]

D

0

[g]

D

D

[g]

D

D

[8J

D

D

[g]

D

D

b6, b7C

b6, b7C

Detainees may also request
extra time.

The Recreation Specialist
retrieves any additional
infonnation requested.

ACCESS TO LEGAL MATERIALS
Policy: Facilities holding ICE detainees shall permit detainees' access to a law library, and provide legal
materials, facilities, equipment and document copying privileges, and the opportunity to prepare legal
documents.
Components

A

Detainees housed in Administrative Segregation and
Disciplinary Segregation units have the same law library
access as the general population, barring security
concerns. Detainees denied access to legal materials
are documented and reviewed routinely for lifting of
sanctions.
All denials of access to the law library fully documented.
ICE Management is aware of each instance where
detainees are denied access to the law library or law
materials.
Indigent detainees are provided with free envelopes and
stamps for mail related to legal matters. Indigent
detainees may mail up to 3 first class letters at no
charge while in ICE custody.
Detainees who seek judicial relief on any matter are not
subjected to reprisals, retaliation, or penalties.

IX! Acceptable

D

U

NA

Remarks
One hour daily during the
afternoon.

IX!

D

D

IX!

D

D

IX!

D

D

[g]

D

D

IX!

D

D

Standard Rating:
Deficient
D At·Risk

No denials noted, log
empty.

o Repeat Deficiency

Remarks: (Record significant facts, obseNations, alternate source used for verification, etc.)

(

'-

Two security guards are posted whenever detainees are in the law library. Most detainees request
materials on how to appeal their criminal convictions. The Recreation Specialist provides any additional
inees as requested.
b6, b7C

b6, b7C

Auditor's Signature 1 Date

ADMISSION AND RELEASE
Policy: All detainees will be admitted and released in a manner that ensures their health, safety, and welfare.
The admissions procedure will, among other things include: medical screening; a file-based assessment and
classification process; a body search; and a search of personal belongings, which wilt be inventoried,
documented, and safeguarded as necessary.
Components

(

(

In processing includes an orientation session. At a
minimum, orientation addresses: Unacceptable
activities and behavior, and corresponding sanctions.
How to contact his/her deportation officer. 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, etc and the detainee
handbook.
Medical screenings are performed by a medical staff or
persons who have received specialized training for the
purpose of conducting an initiat health screening.
The accompanying documentation is used to identify
and classify each new arrival?
All new arrivals strip-searched in accordance with the
"Detainee Search" 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.
The "Contraband" standard governs all personal property
searches. IGSAs use or have a similar contraband
standard. Staff prepares a complete inventory of each
detainee's possessions. The detainee receives a copy.
Excess funds and valuables accounted for and
safeguarded in accordance with the "Funds and Personal
Property" standard or a similar policy for IGSAs and the
detainee receives a receipt?
During detainee in-processing staff inventories every item
property
and
baggage
(except
of personal
funds/valuables) using personal property inventoryforms.
Each detainee receives a receipt.
Staff completes Form 1-387 or similar form for CDFs and
IGSAs for every lost or missing property claim. IGSA
facilities forward all 1-387 claims to ICE.
Detainees are issued appropriate and sufficient clothing
and bedding for the climatic conditions.
For SPCs and CDFs clothes and wristbands are colorcoded.
The facility provides and replenishes personal hygiene
items as needed. Gender-specific items are available.
ICE Detainees are not charged for these items.
The admissions process includes the following
components:
• Classification.
Medical screening.
• Inventory of personal effects.

•

Yes

No

NA

Remarks

Detainees are issued a
handbook and attend an
orientation video session.

j:gJ

D

D

~

D

D

~

D

D

D

~

D

~

D

D

~

D

D

j:gJ

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

Done by Public Health staff.

Detainee Classification
Form.
Detainees are observed
changing into SPC
uniforms, but, not stripsearched. Strip-searches are
conducted if there is
probable cause.

No females' detainees in
this SPC.

ADMISSION AND RELEASE

\

Policy: All detainees will be admitted and released in a manner that ensures their health, safety, and welfare.
The admissions procedure will, among other things include: medical screening; a file-based assessment and
classification process; a body search; and a search of personal belongings, which will be inventoried,
documented, and safeguarded as necessary.
Components
Yes
No
NA
Remarks
All releases are coordinated with the ICE office of
jurisdiction.
Staff completes paperwork/forms for release as required.
ICE Staff enter ali information on detainees admitted,
released, or transferred into the Deportable Alien Control
System (DACS).

[;8J Acceptable

~
~

0
0

0
0

~

0

0

Standard Rating:
At-Risk

D Deficient D

D Repeat Deficiency

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

b6, b7C
b6, b7C
7/29/04
Auditors Signature I Date

(

(

CLASSIFICATION SYSTEM

{

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

Components
The facility has a system for classifying ICE detainees.
In SPCs the system is the Objective Classification
System speCified in the ICE Standard. In CDFs the
system is the ICE Objective Classification System or
similar system. In IGSAs, an Objective Classification
System or similar is used.
The facility classification system includes:
• Classifying detainees upon arrival.
Separating individuals who cannot be classified
upon arrival from the general population.
• The first-line supervisor or designated
classification specialist reviewing every
classification decision.
The intake/processing officer reviews work-folders, Afiles, etc., to identify and classify each new arrival.

•

(

In SPCs and CDFs, staff assigns each detainee a
color-coded uniform and wristband based on his/her
classification level.
In SPCs every A-file includes original paperwork
supporting the classification and the detention file
contains a copy.
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.
Housing aSSignments are based on classificationlevel. Detainees are assigned to the least restrictive
housing unit based and are not assigned more than
one level higher or lower than their classification
desianation.
Detainees' meals are not based on classification
designation.
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. Reassessments are
conducted between 45 and 60 days after arrival and
subsequent reassessments are completed every 60 to
90 dayS?
The classification system includes standard procedures
for processing new arrivals' appeals. 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.

Yes

No

NA

[g]

0

0

Remarks

-

[g]

0

0

[g]

0

0

[g]

0

0

0

~

0

[g]

0

0

[g]

0

0

[g]

0

0

[g]

0

0

IZl

0

0

~

0

0

[g]

0

0

[g]

0

0

After classification, the files
are forwarded to
Deportations.

Copies not placed in
detention fIles to support
classification.

Copies of reclassifying
docwnents are placed in
detention fIles.

CLASSIFICATION SYSTEM
(
Policy: AU facilities will develop and implement a system according to which ICE detainees are classified. The
classification system will ensure that each detainee is placed in the appropriate category, physically separated
from detainees in other categories
Components
Classification designations may be appealed to a
higher authority such as the Officer in Charge or
equivalent.
The Detainee Handbook or equivalent for IGSAs
explains the classification levels, with the conditions
and restrictions applicable to each.
The Detainee Handbook or equivalent for IGSAs
specifies the procedures a detainee must follow to
appeal his/her classification or request reclassification.

Yes

No

NA

~

D

D

~

D

D

~

D

D

Standard Rating:
D At-Risk

IZI Acceptable D Deficient

Remarks

Handbook amendment
placed in all housing areas
as of7/23/04.

o Repeat Deficiency

*Remarks: (Record signfficant facts, observations, other sources used, etc.)
Detainees that cannot be classified are placed in Administrative Segregation until documents are received
for proper classification. An Interoffice Memorandum is submitted to Deportations daily to retrieve the
required information. If the files cannot be obtained, the detainees are reprocessed for removal by
Deportations .
b6, b7C

(

(

7/29/04
b6, b7C
Auditor's Signature / Date

II

(

CORRESPONDENCE AND OTHER MAIL
Policy: All facilities will ensure that detainees send and receive correspondence in a timely manner, subject to
limitations required for the safety, security, and orderly operation of the facility. Other mail will be permitted,
subject to the same limitations. Each facility will widely distribute its guidelines conceming correspondence and
other mail.
Components

Yes

No

NA

The admission process includes informing detainees of
the facility's correspondence and other mail policy.

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

Notification of the policy is made in the detainee
handbook and for SPCs and CDFs in the detail required
to comply with the ICE standard.
Each detainee receives a detainee handbook upon
admittance.

(

The rules for correspondence and other mail are posted
in each housing or common area.
The facility provides key information in languages other
than English; In the language(s) spoken by significant
numbers of detainees. List any exceptions.
Incoming mail distributed to detainees on the day it is
received by the facility and in no case more than 24
hours after it is received.
Outgoing mail routinely delivered to the postal service
within one day of its entering the internal mail system
(excluding weekends and holidays).
Staff records all priority, overnight, and certified mail
delivered by the U.S.P.S. and all deliveries from
commercial alternatives to the U.S.P.S.
Staff do not open and inspect incoming general
correspondence and other mail (including packages and
publications) without the detainee present unless
documented and authorized by the Officer-In-Charge or
equivalent for prevailing security reasons.
Staff does not ever read incoming general
correspondence without the OIC's prior approval.
Staff does not inspect incoming special
Correspondence for physical contraband or to verify the
·special" status of enclosures without the detainee
present.
Staff is prohibited from reading or copying incoming
special correspondence.
Staff are only authorized to inspect outgoing
correspondence or other mail without the detainee
present when there is reason to believe the item might
present a threat to the facility's secure or orderly
operation, endanger the reCipient or the public, or might
facilitate criminal activity. Inspection of outgoing special
correspondence is done in the presence of the detainee
and for contraband only.
Correspondence to a politician or to the media is
processed as special correspondence and is not read or
copied.
The official authorizing the rejection of incoming mail
sends written notice to the sender and the addressee.

Remarks

Spanish versions posted.

Logbook used.

Logbook used.

Logbook entries verified.

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

!8J

D

D

~

0

0

All incoming mail and
packages are x-rayed.

Entered in logbook.

CORRESPONDENCE AND OTHER MAIL
Policy: All facilities will ensure that detainees send and receive correspondence in a timely manner, subject to
limitations required for the safety, security, and orderly operation of the facility. Other mail will be permitted,
subject to the same limitations. Each facility will widely distribute its guidelines concerning correspondence and
other mail.

(

The official authorizing censorship or rejection of
outgoing mail provides the detainee with signed written
notice.
Staff maintains a written record of every item removed
from detainee mail. In SPCs and CDFs documentation
is in accordance with the Standard.
The OIC monitors staff handling of discovered
contraband and its disposition. Records are accurate
and up to date.
The procedure for safeguarding cash removed from a
detainee is effective. The amount of cash credited to
detainee accounts is accurate. Discrepancies are
documented and investigated. Standard procedure
includes issuing a receipt to the detainee.
Detainee identity documents (e.g., passports, birth
certificates) are maintained A-files. Only copies of
detainee identity documents are maintained in other
non-official files.
Staff provides the detainee an ICE-certified copy of
his/her identity document(s) upon reQuest.
Staff disposes of prohibited items found in detainee mail
in accordance with the "Control and Disposition of
Contraband" Standard or the similar prevailing policy in
IGSAs.
Every indigent detainee has the opportunity to mail, at
govemment expense: Correspondence about a legal
matter: At least three other letters per week: Packages
deemed necessary by ICE.
The facility has a system for detainees to purchase
stamps and for mailing a/l special correspondence and a
minimum of 5 pieces of general correspondence per
week.
The facility provides writing paper, envelopes, and
pencils at no cost to ICE detainees.

D

D

I:8l

I:8l

D

D

I:8l

D

D

All outgoing mail is being
sent-out.

Logbook verified.

I:8l

D

D

[8J

D

D

[8J

D

D

[8J

D

0

[8J

0

0

[8J

D

0

[8J

0

0

Detainees are given the
maximum amount of $40,
any remaining balances are
sent to properly for a
receipt.

Detainee mails are sent free
of charge by SPC.

Standard Rating:

[8J Acceptable 0 Deficient 0 At-Risk 0 Repeat Deficiency
*Remarks: (Record significant facts, observations, other sources used, etc.)
Themail-officer.IE
aappearstobeveryorganized.this assignment on a rotational 30-day detail. All
b6, b7C
transactions in the mailroom is being document documented and mail is being delivered and sent out-timely
b6, b7C
b6, b7C

Auditor's Signature 1 Date

i

DETAINEE HANDBOOK
Policy: Every ole will develop a site-specific detainee handbook to serve as an overview of, and guide to, the
detention policies, rules, and procedures in effect at the facility. The handbook will also describe the services,
programs, and opportunities available through various sources, including the facility, ICE, private organizations,
etc. Every detainee will receive a copy of this handbook upon admission to the facility.
Components
Each SPC/CDF have a detainee handbook. Each
IGSA has a detainee handbook or equivalent.
The detainee handbook is written in English and
translated into Spanish or into the next most-prevalent
Language(s).
In SPCs and CDFs detainees are required to sign for
them to ensure accountability.
The handbook supplements the facility orientation
video where one is provided.
All staff members receive a handbook and training
regarding the handbook contents.
The handbook is revised as necessary and there are
procedures in place for immediately communicating
any revisions to staff and detainees.

Yes

No

NA

~

D

D

~

D

D

~

D

D

[8'J

D

D

~

D

D

[8'J

D

D

There an annual review of the handbook by a
designated committee or staff member.
The detainee handbook address the following issues:
Personal Items permitted to be retained
• by the detainee.
• Initial issue of clothes.
Personal hygiene items issued.
The detainee handbook states in clear language basic
detainee responsibilities.

[gI

D

D

[gI

D

D

~

D

D

The handbook identifies: Initial issue of clothing and
bedding and initial issue of personal hygiene items.
The handbook states when a medical examination will
be conducted.
The handbook describes the facility, housing units,
dayrooms, In-dorm activities and special management
units.
The handbook describes; Official count times and
count procedures Meal times, feeding procedures,
procedures for medical or religious diets, additional
information, Smoking policy, Clothing exchange
schedules and if authorized, clothes washing and
drying procedures and expected personal hygiene
practices.
The handbook describe times and procedures for
obtaining disposable razors and allows that detainees
attending court will be afforded the opportunity to shave
first.
The handbook describes barber hours and hair cutting
restrictions.

~

0

D

~

D

D

[gI

D

D

[gI

D

D

[gI

D

D

[gI

D

D

[8'J

D

D

•

(

Remarks

Information and changes
distributed by daily
information sheets and staff
meetings.

•

The handbook describes; the telephone policy, debit
card procedures, direct and frees calls; Locations of
telephones; Policy when telephone demand is high;
Policy and procedures for emergency phone calls, and
the Detainee Message System.

Within 14 days.

Done during recreation
periods. Barber is a
detainee. Haircuts are free.

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

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

(

The handbook states times and procedures for
commissary or vending machine usage. (where
available)
The handbook describes the detainee voluntary work
program procedures and pay procedures.
The handbook describes the library location and hours
of operation and law library procedures and schedules.
The handbook describes; attorney visitation hours;
Location of the list of pro bono legal organizations;
Group legal rights presentations schedule and sign up
procedures.
The handbook describes the facility search procedures
and contraband policy.
The handbook describes the facility visiting hours and
schedule and visiting rules and regulations.
The handbook describes the correspondence policy
and procedures.
The handbook describes the detainee disciplinary
policy and procedures: Including:
• Prohibited acts and severity scale sanctions.
• Time limits in the Disciplinary Process.
Summary of Disciplinary Process.
The handbook describes the detainee grievance
procedures including appeals.
The detainee handbook describes the sick call
procedures for general population and segregation.
The handbook describes the facility recreation policy
including:
Outdoor recreation hours.
• Indoor recreation hours.
In dorm leisure activities.
• Rules for television viewing.
The handbook describes the detainee dress code for
daily living; Work assignments and in SPCs and CDFs
the meaning of color-coded uniforms.
The handbook specifies the rights and responsibilities
of all detainees.

Yes

No

NA

[gj

D

D

[gj

D

D

[gj

D

D

[gj

D

D

[gj

D

D

[gj

0

0

[gj

0

0

[gj

D

0

~

0

D

[gj

D

0

[gj

D

0

[gj

D

0

[gj

D

D

~

D

0

Remarks
No commissary. vending
machine available.

•

•
•

[gj Acceptable

Standard Rating:
At-Risk

D Deficient D

D Repeat Deficiency

II

*Remarks: (Record significant facts, observations, other sources used, etc.)
The detainee handbook is very informative and covers the majority of all the required topics listed in the
standard. The staff is very receptive in adding needed information and current revisions are placed in all
affected areas.
b6, b7C
b6, b7C

Auditor's Signature I Date

(

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
The food service program is under the direct
supervision of a professionally trained and certified
service administrator.
In larger facilities the Cook Supervisor (CS) assists the
FSA in day-to-day management of food service
<merations.
Responsibilities of cooks and cook foremen are in
writing. The FSA determines the responsibilities of the
Food Service Staff.
The CS is on duty on days when the FSA is off duty
and vice versa.
The FSA provides food service employees with training
that specifically addresses detainee-related 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.
The FSAICS monitor the condition of knives and dining
utensils.
Special procedures govern the handling of food items
that pose a security threat.
Standard operating procedures include daily searches
(shakedowns) of detainee work areas.
Food service personnel conduct shakedowns along
with detention staff.
The FSA monitor staff's implementation of the facilities
counting procedures. These procedures in written form
and staff are trained in counting procedures.
The detainees assigned to the food service department
look neat and clean. Their clothing and grooming
comply with the "Food Service" standard.
The FSA annually reviews detainee-volunteer job
descriptions to ensure they are accurate and up-todate.
The CS instructs newly assigned detainee workers in
the rules and procedures of the food service
department.
Training includes workplace-hazard recognition and
deterrence.
• Training covers the safe handling of every
hazardous material the detainee are likely to
encounter in their work.

Yes

No

NA

Remarks
The CS is in charge of all
operations.

0

[8J

0

[8J

0

0

[8J

0

0

The position descriptions
are kept in the CS office.

[8J

0

0

The CS and FS Supervisor
alternate.

[8J

0

0

[8J

0

0

[8J

0

D

IZJ

0

0

[8J

0

D

[8J

0

0

~

0

D

IZJ

D

0

~

D

0

~

D

0

[8l

D

D

[8J

D

0

Level 1 only.

FOOD SERVICE

(

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

Components
During orientation and training session(s), the CS
explains and demonstrates:
• Safe work practices and methods.
Safety features of individual products! pieces of
equipment.
The CS documents all training in individual detainee
detention files?
Detainees are paid in accordance with the "Voluntary
Work Program" standard or prevailing IGSA standards.
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.
IN SPCs only: The ICE supervisor on duty ensure that
ICE officers participate in dining room supervision.

•

(

A transparent "sneeze guard" protects both the serving
line and salad bar line.
The facility has a standard 35-day menu cycle. IGSAs
use a 35-day or similar system for rotating meals.
The FSA or facility considers the ethnic diversity of the
facility's detainee population when developing menu
cycles. (Provide examples)
A registered dietitian conducts a complete nutritional
analysis of every master-cycle menu planned.
Are menus sometimes adopted without the dietitian's
certification?
• If yes, under what circumstances
The CS has established procedures to ensure that
items on the master-cycle menu are prepared and
Qresented according to approved recipes.
Does the CS have the authority to change menu items
if necessary?
• If yes, documenting each substitution, along
with its justification
• With copy to FSA
All staff and volunteers know and adhere to written
"food preparation" procedures.
Detainees whose religious beliefs require the
adherence to particular religious dietary laws are
referred to the Chaplain or FSA.

(

Yes

No

NA

Remarks

181

D

D

181

D

D

181

D

D

rgJ

D

D

181

D

D

181

D

D

181

D

D

rgJ

D

D

181

D

D

Dietitian's License seen
and verified.
If the food supply is
interrupted and the
needed items are not
available.

$1 a day.
Served 3 hot meals daily.

rgJ

D

D

rgJ

D

D

[gJ

D

D

[gJ

D

D

181

D

D

2-security guards- 1 lEA
and 1 contract guard
(AKAL Security).
A stainless steel wall
enclosure is used.

The detainees are issued a
special meal card that is
approved
by
the
Chaplain.

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

A common-fare menu available to detainees whose
dietary requirements cannot be met on the main.
Changes to the planned common-fare menu
can be made at the facility level.
• Hot entrees are offered three times a week.
• The common-fare menus satisfy nutritional
recommended daily allowances (RDAs).
Staff routinely provides hot water for instant
beverages and foods.
Common-fare
meals are served with:
•
• Disposable plates and utensils?
• Reusable plates and utensils?
• Staff use separate cutting boards, knives,
spoons, scoops, etc., to prepare the commonfare diet items.
A Supervisor at the command level must approve a
detainee's removal from the Common-Fare Program.
• Under what circumstances?
The OIC, in conjunction with the Chaplain and/or local
religious leaders, provide the FSA a schedule of the
ceremonial meals for the followina calendar year.
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-Fare Program
receive the same Kosher-for- Passover meals
as those who do participate.
Main-line offerings include one meatless meal
(lunch or dinner) on Ash Wednesday and
Fridays during Lent.
IN SPCs the FSA prepares quarterly cost estimates for
the Common Fare Program.
• This quarterly estimate is factored into the
quarterly budQet.
The food service program addresses medical diets.

Yes

No

NA

[8J

D

0

[8J

D

D

[8J

D

D

[8J

D

D

Remarks

•

•

(

If recommended by the
appropriate parties i.e.,
Medical, C~plain.

•

prepares

[8J

D

D

~

D

D

Special meal cards are issued
by medical.

Satellite-feeding programs follow guidelines for proper
sanitation.

~

D

D

Boxed meals served for
infirmary
patients
&
processing area detainees.

Hot and cold foods are maintained at the prescribed,
"safe" temperature(s) after two hours.

~

D

D

[8J

D

D

Food is not used to punish or reward detainees based
upon behavior.

~

0

D

ICE SPCs and CDFs, a member of the food service
staff prepares the sack lunches for detainee
transportation.

~

D

D

All meals provided in nutritionally adequate portions.

(

CS,
b6, b7C
this report.

(

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
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.
• If not, explain non-compliance.

•

Standard operating procedures include weekly
inspections of all food service areas, including dining
and food-preparation areas and equipment.
• who conducts the inspections?
Either the FSA or the CS inspects all food service
areas once every week.
Equipment is inspected for compliance with health and
safety codes and regulations.
• How often?
When was the most recent inspection?
• Which agency conducted the in~ection?
. Reports of discrepancies are forwarded to the OIC or
AOIC and corrective action is scheduled and
completed.
Standard procedure includes checking and
documenting temperatures of a/l dishwashing
machines during each meal.
Staff documents the results of every refrigeratorl
freezer temperature check.
The cleaning schedule for each food service area is
conspicuously posted.
Do procedures include inspecting all incoming food
shipments for damage, contamination, and pest
infestation?
ICE SPCs and CDFs Staff complies with the ICE
requirements for "food receipt and storage.

•

(

ICE SPCs and CDFs Are stock inventory levels
periodically monitored and adjusted to correct overage
and shortCige problems?
Storage areas are locked.
ICE SPCs and CDFs staff complies with all ICE
"Housekeeping, Storeroom/Refrigerator" requirements
• Identify and explain shortcomings.

Yes

No

NA

~

D

D

D

~

D

IZl

D

D

IZl

D

D
Inspected by food service
staff.

IZl

D

D

~

D

D

~

D

D

~

D

0

~

0

0

~

D

D

D

~

0

~

0

0

[gj

D

0

0

[gj

D

Temperature spike noted on
freezer.

Shoes being stored near the
food storage and kitchen
areas.

See Connnents.

Standard Rating:

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

!

Equipment not being cleaned
properly and trash found
underneath sink-tables &
freezers.
The FS Supervisor, b6, b7C
b6, b7C or staff/cooks.

o Acceptable J:gJ Deficient D At-Risk 0 Repeat Deficiency
(

,

Remarks

HOUSEKEEPING: Shoes were being stored in the kitchen area. On the third day of inspection, several
food preparation equipment still had little pieces of meat, carrot, lettuce and grease left on the machines

I

(

after being cleaned. Trash was found stuffed underneath the freezer and sink-table in the food-serving
area. The catch area under the range contained remnants of prepared food. These discrepancies were
immediately corrected. However, these problems were occurred on a daily basis during the inspection on
different sets of equipment. Better supervision by the kitchen staff and attention to detail is needed to
remedy th is deficiency.
STOREROOM: Shoe storage remained to be problem in this area, as detainees need to switch from their
uniform shoes to safety boots as a precaution. A proposed shoe/boot storage rack has been submitted
for either purchase or furnished by the Maintenance department.
FREEZER: There was an instance when the freezer was recorded to have a temperature of sixty-four
degrees. The time differential was unknown per the equipment check logs. As a result, the stored food
was transferred to another freezer. However, since it is unknown how long the freezer was out of range.
The food should have been thrown away as a safety precaution. There was a detainee grievance that
possibly related toa food borne illness. New thermometers have been ordered to closely monitor these
temperature changes. These thermometers will be able to record the temperatures on a continuous
basis.
BROKEN REFRIGERATOR: The refrigerator in the serving area has a broken thermostat; however, milk,
fruit and drinks is being stored and the temperature is being check with a hand held thermometer. Since
the refrigerator is supposed to be inoperable, the temperature checks are not being recorded as well since
it's suppose to be out of commission.

(

(

MAINTENANCE CONCERNS: Several ceiling tiles were missing and the thermostat for the air
conditioning was malfunctioning. Electric fans and extension cords were being used in the dishwashing
room for the comfort of the workers. However, since this area generally wet, the extension cords and fans
posed as an electrocution hazard. The maintenance department immediate replaced the missing ceiling
tiles, repaired the thermostat, and removed the electric fans and extension cords.
b6, b7C
b6, b7C

re I Date

(

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

c

Components
Detainee funds and valuables are properly separated
and stored away. Detainee funds and valuables are
accessible to designated supervisor(s} only.
Detainees' large valuables are secured in a location
accessible to designated supervisor(s) or proceSSing
staff only.
Staff itemizes the baggage and personal property of
arriving detainees, including funds and valuables). For
IGSAs and CDFs, using a personal property inventory
form that meets the ICE standard?
IN SPCs and CDFs staff gives the detainee the original
inventory form, filing copies in the detainee's detention
file and the personal property container.
Staff forwards an anriving detainee's medicine to the
medical staff.
Staff searches anriving detainees and their personal
property for contraband.
ICE SPCs and CDFs staff obtains a forwarding address
from each detainee. IN IGSAs, district staff obtains a
forwarding address from each detainee.
There is a written policy for retuming forgotten property
to detainees and staff follows procedures?
In SPCs and CDFs it is standard procedure for two
officers to be present when removing/documenting the
removal of funds from a detainee's possession.
ICE SPCs and CDFs staff issues and maintains
property receipts (G-589s) in numerical order. (CDFs
may use a similar form if not specified in the contract)
In SPCs and CDFs staff completes and distributes the
G-589 in accordance with the ICE standard.
In ICE SPCs and CDFs the processing officer records
each G-589 issuance in a G-589 logbook. The record
includes the initials and star numbers of receipting
officers.
In ICE SPCs and CDFs staff tags large valuables with
both a G-589 and an 1-77?
In ICE SPCs and CDFs the supervisor verifies the
accuracy of every G-589.

In ICE SPCs and CDFs the supervisor ensures that:
• Detainee funds are, without exception,
deposited into the cash box;
• Every property envelope is sealed.
All sealed property envelopes are placed in the
safe.
• Large, valuable property is kept in the secured
locked area.
In ICE SPCs and CDFs staff tags every baggage/facility
container with an 1-77, completed in accordance with the
ICE standard.

•

(

Yes

No

NA

0

D

0

0

D

0

0

D

0

0

0

0

0

D

0

0

D

0

0

0

0

Information listed in
detention file.

0

0

0

Forwarded to detainees
designated address.

0

D

0

0

0

0

0

0

0

0

0

D

0

D

0

0

0

0

0

0

0

0

0

0

Remarks

Verified every morning
when valuab les are removed
from the safe to the property
room.

FUNDS AND PERSONAL PROPERTY

(

Policy:

All facilities will implement procedures to control and safeguard detainees' personal property.
Procedures will provide for the secure storage of funds, valuables, baggage and other personal property; the
documentation and receipting of surrendered property; and the initial and regularly scheduled inventorying of all
funds, valuables, and other property.
In ICE SPCs and CDFs staff secures every container
used to store property with a tamper-proof numbered
strap.
In SPCs and CDFs a logbook records detainee name,
A- number/detainee-number, baggage-checkll-77
number, security tie-strap number, property description,
date issued and date returned.
Property discrepancies are immediately reported to the
CDEO or Chief of Security.
In SPCs and CDFs the DOS (or equivalent)
accompanied by a detention staff member conduct a
comprehensive weekly audit.
In SPCs and CDFs the OIC has established quarterly
audits of baggage and non-valuable property as facility
policy, the audits occur each quarter and audits are
entered in the daily log.
The facility positively identifies every detainee being
released or transferred. In SPCs and CDFs in
accordance with the ICE standard.
Staff follows written procedures when returning property
to detainees.
Staff routinely informs supervisors of lost/damaged
property daims. Claims are properly investigated and
missing or damaged property claim reports are filed.
In SPCs and CDFs every lost/damaged property report
completed in accordance with the ICE standard on an 1387 (or equivalent). The OIC receives a copy and staff
places the original in the detainee's A-file, retaining a
copy in facility files.
The SPC uses the Form SF-95 for all detainee
missing/damaged property claims against the
government. The claimant signs every SF-95.
CDFIIGSA facility procedures for handling detainee
property claims are similar with the ICE standard.
The facility attempts to notify an out-processed detainee
that he/she left property in the facility.
• By sending written notice to the detainee's last
known address;
Via certified mail;
• The notice state that the detainee has 30 days
in which to claim the property, after which it will
be considered abandoned.
The facility disposes of abandoned property in
accordance with written procedures.
• If an SPC, in accordance with the ICE standard
(based on ICE' "Personal Property Operations
Handbook")
• If a CDFIIGSA facility, written procedure
requires the prompt forwarding of abandoned
property to ICE.

(

•

(

I

t:8l Acceptable 0

~

D

D

IZI

0

D

IZI

D

D

~

D

D

Straps are numbered and
entered in detention file.

Accompanied by
Administrative DOS.

Entered by Admin DOS.

IZI

D

D

IZI

D

D

~

D

D

IZI

D

D

IZI

D

0

IZI

D

0

IZI

0

D

~

0

0

~

D

0

Standard Rating:
Deficient cy 0 At-Risk

D Repeat Deficient

(

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

b6, b7C

.

c

(

b6, b7C
7/29/04
Auditor's Signature I Date

(

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

Yes

No

NA

The ICEIOIC is responsive to requests by attomeys and
accredited representatives for group presentations.
Upon receipt of concurrence by the District Director, the
OIC ensures proper notification to attomeys or
accredited representatives in a timely manner.
The facility follows policy and procedure when rejecting
or requesting modifications to objectionable material
provided or presented by the attorney or accredited
representative.
Posters announcing presentations appear in common
areas at least 48 hours in advance and sign~up sheets
are available and accessible.

~

D

D

~

D

D

Documentation is submitted and maintained when any
detainee is denied permiSSion to attend a presentation
and the reason(s) for the denial.
When the number of detainees allowed to attend a
presentation is limited, the facility allows a sufficient
number of presentations so that all detainees Signed up
may attend.
Detainees in segregation and unable to attend for
security reasons may request separate sessions with
presenters. Such requests are documented.
Interpreters are admitted when necessary to assist
attomeys and other legal r~esentatives.
Presenters are afforded a minimum of one hour to make
the presentation and to conduct a question~and~answer
session.
Staff permits presenters to distribute ICE-approved
materials.
The facility permits presenters to meet with small groups
of detainees to discuss their cases after the group
presentation. ICE Staff is present but do not monitor
conversations with legal providers.
Group presenters who have had their privileges
suspended are notified in writing by the OIC and the
reasons for suspension are documented. The District
Director is notified when a group or individual is
suspended from making presentations.
The facility plays ICE-approved videotaped
presentations on legal rights, at regular opportunities at
the request of outside organizations.
A copy of the Group Legal Rights Presentation policy,
including attachments, is available upon request

(

~

~ Acceptable

0

Standard Rating:
Deficient D At-Risk

Remarks

Notified in writing.

r8J

D

D

IZl

0

0

0

0

r8J

All detainees attend.

lXI

0

0

lXI

0

0

r8J

0

0

~

0

0

lXI

0

D

lXI

0

0

I

Maximum of 70
detainees in general
purpose room AKA dining
room.

Guards present for
security purposes.

None to date.

IZl

0

0

lXI

0

0

r8J

0

0

0

None submitted by
outside
organ izations.

Repeat Deficiency

(

Remarks: (Record significant facts, observations, altemate source used for verification, etc.)

(

b6, b7C

b6, b7C
7/29/04
Au ltor's Slgnature/ Date

(

(

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 prescribed time frame.
Among other things, a grievance will be processed, investigated, and decided (subject to appeal) in accordance
with the SOPs; a grievance committee will convene as provided in the SOPs. Standard procedure will include
providing the detainee with a written response to any formal grievance, which will include the basis for the
decision. The facility will also establish standard procedures for handling emergency grievances. All
grievances will receive supervisory review. Reprisal against the filer of a grievance will not be tolerated.
Components
Written procedures provide for the informal resolution of
oral grievances.
• If yes, the detainee has up to five days within
which to make his/her concern known to a
member of the staff.
Detainees have access to the grievance committee (or
equivalent in IGSA), using formal procedures.
• Detainees may seek help from other detainees
or facility staff when preparing a grievance.
Illiterate, disabled, or non-English-speaking
detainees receive special assistance when
necessary.
In SPCs/CDFs, the detainee has five days after the
incident or informal-grievance outcome to file a formal
_grievance.
Every member of the staff knows how to identify
emergency grievances, including the procedures for
expediting them.
In SPCs and CDFs, when a Detainee does not accept
the grievance committee's decision, he/she files an
appeal with the ICE OIC.
• In all facilities written procedures cover detainee
appeals and are included in the detainee
handbook
There are no documented substantiated cases of staff
harassing, disciplining, penalizing, or otherwise
retaliating against a detainee who lodges a complaint.
• If yes, explain.
Procedures include maintaining a Detainee Grievance
Log.
• If not; an alternative acceptable record keeping
system is maintained.
"Nuisance
complains" are identified in the
•
records.
• For quality control purposes, staff documents
nuisance complaints received but not filed.
Staff is required to forward any grievance that includes
officer misconduct to a higher official or, in a CDFIIGSA
facility, to ICE.
The admissions process includes providing each new
arrival with a copy of the detainee handbook (or
equivalent).

•

(

Yes

No

NA

~

D

D

~

D

D

r:8J

0

0

~

0

0

r:8J

0

0

IZI

D

0

~

0

D

~

D

D

r:8J

0

D

Remarks

Detainee is escorted by to
the SIEA immediately.

(

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 prescribed time frame.
Among other things, a grievance will be processed, investigated, and decided (subject to appeal) in accordance
with the SOPs; a grievance committee will convene as provided in the SOPs. Standard procedure will include
providing the detainee with a written response to any formal grievance, which will include the basis for the
decision. The facility will also establish standard procedures for handling emergency grievances. All
grievances will receive supervisory review. Rep'risal against the filer of a grievance will not be tolerated.
Components

:

,

The grievance section of the handbook explains all
steps in the grievance process - Including:
• Informal and formal grievance procedures;
• The appeals process and step-by-step
procedures;
In CDFs/IGSA facilities: procedures for filing an
appeal with ICE.
• Staff/detainee availability to help during the
grievance process
Guarantee against staff retaliation for
filing/pursuing a grievance.
• How to file a complaint about officer misconduct
with the Department of Justice.

•

Yes

No

NA

~

0

0

•

I
(

~ Acceptable

0

Standard Rating:
Deficient 0 At-Risk D Repeat Deficiency

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

b6, b7C
b6, b7C

Auditors Signature I Date

Remarks

(

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

Yes

The facility has a policy and procedure for the regular
issuance and exchange of clothing, bedding, linens and
towels.
• The supply of these items exceeds the
minimum required for the number of detainees.
All new detainees are issued clean, temperatureappropriate, presentable clothing during in processing.
Detainees receive
• One uniform shirt and one pair of uniform pants
or one jumpsuit.
• One pair of socks.
One pair of underwear (Daily change).
One pair of facility-issued footwear.
In SPCs and CDFs the uniform/jumpsuit is color-coded
to reflect the detainee's classification level.
Additional clothing is available for changing weather
conditions or is seasonally appropriate.
New detainees are issued clean bedding, linens and
towel. They receive
One mattress
• One blanket
One pillow
Two
sheets
•
One pillowcase
One towel
• Additional blankets are issued based on local
weather conditions.

No

NA

Remarks
3 to 1 ratio of supplies to
detainees.

[8J

0

0
Detainees also issued
hygiene-kits.

~

0

0

~

0

0

~

0

0

J:8J

0

0

J:8J

0

0

[8J

0

0

[8J

0

0

[8J

0

0

•
•

LeveI1-Blue, Level 2Orange, Level 3-Red.

•

(

•

•

•

Detainees aSSigned to special work areas are clothed in
accordance with the requirements of the job.
Detainees are provided clean clothing, linen and towels.
• Socks and undergarments exchanged daily.
• Outer garments at least twice weekly.
• Sheets at least weekly.
• Towels at least weekly.
Pillowcases at least weekly.
Food service detainee volunteer workers permitted to
exchange outer garments daily.
Volunteer detainee workers are permitted to exchanges
of outer garments more frequently.

•

I

[8J Acceptable

0

Standard Rating:
Deficient 0 At-Risk

0

Repeat Deficiency

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

b6, b7C

\

b6, b7C

Auditor's Signature I Date

MARRIAGE REQUESTS

•

Policy: All detainee marriage requests will receive case-by-case consideration from ICE management.
Components

Yes

No

NA

The OIC/ICE considers detainee marriage requests on a
case-by-case basis.

I:8J

0

0

~

0

0

~

0

D

I:8J

0

0

~

D

0

~

D

0

I:8J

0

0

I:8J

0

0

I:8J

0

D

In SPCs and CDFs the OIC or highest-ranking ICE
official on-site is the only officer authorized to approve a
request to marry.
The ADD reviews every marriage request rejected by an
OIC or IGSA. Rejections are documented.
It is standard practice to require a written request for
permission to marry.
The written request includes a signed statement or
comparable documentation from the intended spouse,
confirming marital intent.
The OIC provides a written copy of his/her decision to
the detainee and his/her legal representative.
When permission is denied, the OIC states the basis for
his/her decision.
The OIC provides the detainee with a place and time to
make wedding arrangements.
The detainee handbook (or equivalent) explains the
marriage request process.
~ Acceptable

(

0

Standard Rating:
Deficient OAt-Risk

D Repeat Deficient

"'Remarks: (Record significant facts, observations, other sources used, etc.)
b6, b7C
b6, b7C

.

7/29/04

Auditor's Signature / Date

Remarks

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

Components
The OIC considers and approves, on a case-by-case
basis, trips to immediate family member's:
• Funeral
• Deathbed
The facility recognizes mother, father, brother, sister,
spouse, child, stepparent, and foster parent as
"immediate family".
The IGSA facility notifies ICE of all detainee requests for
non-medical escorts.

(

(

The District Director is the approving official for nonmedical escorted trips.
The detainee's Deportation Officer reviews the file
before forwarding a detainee's request, with
recommendation, to the approving official. Each
recommendation addresses the individual's suitability for
travel, e.g., the kind of supervision required?
Detainees who require overnight housing placed in
approved IGSA facilities.
At SPCs and CDFs, facility procedures comply with the
following ICE Standards:
• Non-Medical Emergency Escorted Trips
• Transportation (Land Transportation)
• Restraints applied strictly in accordance with the
Use of Force standard.
Each escort includes at least two officers.
• The detainee under constant, direct visual
supervision of escorting staff.
The Chief Detention Enforcement Officer responsible for
traininQ escort officers to follow written procedures.
Escorting officers report unexpected situations to the
originating facility as a matter of procedure and the
ranking supervisor on duty has the authority to issue
instructions for completion of the trip.
Escorting officers have the discretion to: a. Increase or
decrease minimum restraints in accordance with written
instruction, procedures and classification level of the
detainee.
Escort officer training includes ICE Firearms Policy,
Section 20.012?
Escort officers do not accept gifts/gratuities from a
detainee, detainee's relative or friend for any reason.

Yes

No

NA

Remarks
Delegated to the

[8J

D

D

Deportation Officer.

~

D

D

D

D

IZl

IZl

D

D

~

D

D

IZl

D

D

[8J

D

D

IZl

D

D

IZl

D

D

[8J

0

D

~

0

0

~

D

0

~

0

0

SPC facility.
OlC.

NON-MEDICAL EMERGENCY ESCORTED TRIPS

(

Policy: The Immigration and Naturalization Service (ICE) may provide detainees with staff-escorted trips into
the community for the purpose of visiting critically ill members of the detainee's immediate family, or for
attending funerals.
Components
Escort officers ensure that detainees:
Conduct themselves in a manner that does not
bring discredit to the ICE.
• Do not violate federal, state, or local laws.
• Do not purchase, possess, use, consume, or
administer narcotics, other drugs, or intoxicants.
• Do not arrange to visit family or friends unless
approved before the trip.
• Make no unauthorized phone calls.
• Know they are subject to search, urinalysis,
breathalyzer, or comparable test upon return to
the facility.
.
Standard procedure requires the immediate return to the
facility of any detainee who violates trip rules.

Yes

No

NA

IZJ

0

0

IZJ

0

0

•

I

I:8J Acceptable 0

Standard Rating:
Deficient 0 Repeat Deficiency

0

*Remarks: (Record Significant facts, observations, other sources used, etc.)
b6, b7C

(

b6, b7C

7/29/04

Auditor's Signature 1 Date

At-Risk

Remarks

(

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

(

(

The facility provide:
• An indoor recreation program
• An outdoor recreation program
In each SPC and CDF the facility has a full-time:
Recreational Specialist and recreational assistant where
required b~the standard.
The recreational specialist tailors the program activities
and offerings to the particular detainee population.
Regular maintenance keeps recreational facilities and
equipment in good condition.
In SPCs and CDFs the recreational specialist
supervises approved recreation activities.
The recreational specialist supervises detainee
recreation workers.
The recreational specialist oversees recreation
programs for Special Management Unit and specialneeds detainees.
Dayrooms offer sedentary activities, e.g., board games,
cards, television.
Outside activities are restricted to limited-contact sports.
Each detainee has the opportunity to participate in daily
recreation.
Detainees have access to recreation activities outside
the housing units for at least one hour daily, 5 days a
week.
Staff checks aI/ items for damage and condition when
equipment is returned.
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 SMU at least one
hour of recreation time daily.
Detainees in disciplinary segregation receive a written
explanation when a panel revokes his/her recreation
privileges.
Does the OIC review the panel's decision before it
becomes effective.
If yes, in every case?
Detainees in administrative segregation receive a
written explanation for denied recreational privileges.
Volunteer groups present special programs or religious
activities.
Volunteers are required to sign a waiver of liability
before entering a secure portion of the facility where
detainees are present.
Visitors, relatives or friends are not allowed to serve as
volunteers.
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.

Yes

No

NA

[g1

0

0

[g1

0

D

[g1

D

D

[g1

0

D

[g1

D

D

[g1

D

D

[g1

D

D

[g1

D
D

[g1

D
D
D

[g1

D

D

[g1

D

0

[8J

D

0

[8J
[8J

[]

0

D
D

[g1

D

0

[8J

D

0

[8J

D

D

[8J

D

D

[g1

D

0

[8J

0

0

[8J

D

D

Remarks

Recreation Specialist-

[g1

D

D

b6, b7C

Suggestions gathered
from detainee surveys.

Two level 2 detainees
work in recreation.

0

[g1

When detainee poses a
hazard to himself or
others.

Usually H IV and religious
classes.

Outside recreation
available.

(

RECREATION
Policy: It is ICE policy to provide access to recreational programs and activities to all ICE detainees, to the
extent possible, under conditions of security and supervision that protect their safety and welfare ..
Case officers make written transfer recommendations
about every six-month detainee to the OIC.
The OIC documents all detainee-transfer decisions,
whether yes or no.
The detainee's written decision for or against an offered
transfer documented in his/her A-file.
Staff notifies the detainee's legal representative of
his/her decision to accept/decline a transfer.
If no recreation is available, the ICE District routinely
review transfer eligibility for all detainees after 60 days.
Does the A-file of every detainee is held more than 60
days without access to recreation contains either a
transfer-waiver signed by the detainee or the OIC's
written determination of the detainee's ineligibility for
transfer.
The detainee's legal representative is notified of the
detainee'slOIC's decision.

I:8l Acceptable 0
Remarks:

(

b6, b7C
b6, b7C

7/29/04

Auditor's Signature I Date

Standard Rating:
Deficient D At-Risk

0

D

(gJ

D

D

(gJ

D

0

L8J

0

0

L8J

0

0

L8J

0

D

(gJ

D

0

L8J
II

0

Repeat Deficiency

(

RELIGIOUS PRACTICES
Policy: Facilities will provide ICE detainees of all faiths with reasonable and equitable opportunities to
participate in the practices of their faith, limited only by the constraints of safety, security, the orderly operations
of the facility and budgetary considerations.

Components

Yes

No

NA

Detainees are allowed to engage in religious services.
Space is available for detainees to conduct religious
services.
The facility allows detainees to observe the major "holy
days" of their religious faith.
a. List any exceptions.
The facility accommodates recognized holy-day
observances by:
• Providing special meals, consistent with dietary
restrictions.
Honoring fasting requirements.
• FaCilitating religious services.
Allowing activity restrictions.
Each detainee is allowed religious items in his/her
immediate possession.
Volunteer's credentials are checked and verified before
letting him/her participate in detaine-e Qrograms.
Members of faiths not represented by clergy conduct
may request to present their own services within security
allowances.
Detainees in the Special Management Unit to participate
in religious practices unless otherwise documented for
the safety and security of the facility.

~

[]

~

D
D

D

~

D

D

IZI

D

0

IZI

0

0

IZI

0

0

~

0

0

~

0

0

•

Remarks
Cafeteria eating area used as
a general purpose room.

•

(
I

[8J Acceptable

0

Standard Rating:
Deficient 0 At-Risk

0

Repeat Deficiency

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

b6, b7C

b6, b7C

Auditor's Signature I Date

(

DETAINEE TELEPHONE ACCESS
Policy: All facilities housing ICE detainees will permit detainees' reasonable and equitable access to
telephones.
Yes

No

NA

[gJ

0

0

[gJ

18I
18I

0
0
0

0
0
0

[gJ

0

0

18I

0

0

Telephones are inspected regularly (daily in
SPCs/CDFs), by designated facility staff, to ensure that
they are in good working order.

18I

0

0

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

[gJ

0

D

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

18I

D

D

18I

0

0

L8J

0

D

[gJ

0

0

[gJ

D

D

0

0

18I

L8J

0

D

18I

D

D

L8J

0

D

L8J

0

D

L8J

0

D

Emergency phone call messages are immediately
given to detainees.

18I

D

D

Detainees are allowed to retum emergency phone calls
as soon as possible.

[gJ

0

D

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

(

Detainees are afforded a reasonable degree of privacy
for legal phone calls.
A procedure exists to assist a detainee who is having
trouble placing a confidential call.
The facility provides the detainees with the ability to
make non-collect (special access) calls.
Special Access calls are at no charge to the detainees.
In facilities unable to fully meet this requirement initially
because of limitations of its telephone service, the ICE
makes altemate arrangements to provide required
access within 24 hours of a request by a detainee.
No restrictions are placed on detainees attempting to
contact attorneys and legal service providers who are
on the approved "Free Legal Services Lisf.
Special arrangements are made to allow detainees to
speak by telephone with an immediate family member
detained in another SPC or CDF?
Use of general access phones is ordinarily not
restricted.
Any restrictions are documented and fall within one of
the categories in paragraph VIII section G?
The facility has a system for taking and delivering
detainee telephone messages.

Remarks

Spanish versions available.

11 to 1 ratio.

Calls made from staff
telephone on case-by-case
basis.

Detainee Message Center.

DETAINEE TELEPHONE ACCESS

(

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

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 allowed phone
calls for family emergencies.
Detainees in administrative segregation and protective
custody afforded the same telephoning privileges as
those in general population.
When detainee phone calls are monitored, notification
is posted by detainee telephones that phone calls
made by the detainees may be monitored. Special
Access calls are not monitored.

i

~ Acceptable

0

Yes

No

NA

18I

0

0

18I

0

0

18I

0

0

18I

0

D

18I

D

D

Standard Rating:
Deficient 0 At-Risk

0

Remarks

Repeat Deficiency

Remarks: (Record significant facts, observations, alternate source used for verification, etc.)

b6, b7C

(

..

b6, b7C
7/29/04
Auditor's Signature / Date

II

(

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

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

(

No

NA

IZl

D

D

IZl

D

D

Upon admittance detainees are made aware of the
facility's visitation policy and the hours of visitation for
the following categories: general visitation (including
visitation by minors), legal visitation, consultation
visitation for expedited removal. consular visitation, and
special family visits, in the detainee handbook.

IZl

D

D

The visitation schedule and rules are available to the
public.

IZl

D

D

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

IZl

D

D

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

IZl

A general visitation log is maintained.

IZl

The detainees are permitted to retain personal property
item specified in the standard.

[8J

A visitor dress code is available to the public.

[8J

Visitors are searched and identified according to
standard requirements.

rgJ

D
D
D
D
D

D
D
D
D
D

The requirement on visitation by minors is complied
with.

[8J

D

D

At facilities where there is no provision for visits by
minors. the ICE arranges for visits by children and
stepchildren, on request, within the first 30 days.
After that time, on request, ICE considers a transfer,
when possible, to a facility that will allow minor
visitation. At a minimum, monthly visits are allowed.
Detainees in special housing afforded visitation.

(

Yes

D

D

IZl

D

D

IZl

[8J

D
D

Legal visitation is available seven (7) days a week.
including holidays?

rgJ

D
D

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

[8J

D

D

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

IZl

D

D

In SPCs and CDFs, the facility has a written procedure
allowing legal service providers and assistants to
telephone the facility in advance of a visit to determine
whether a particular detainee is detained in that facility.
After consultation with a detainee, the attorney files the
appropriate Form EOIR-28 with the court and a copy is
maintained in the detainees file.

[8J

D

D

Remarks

Paperwork only.

VISITATION

(

Policy: ICE shall permit detainees to visit with family, friends, legal representatives, special interest groups and
the news media.
The call ahead inquiry policy is available to legal
service providers.
Private consultation rooms are available for attorney
meetings. There is a mechanism for the detainee and
hislher representative to exchange documents.
There are written procedures goveming detainee
searches. The procedure is also listed in the detainee
handbook or equivalent.
When strip searches are required after every contact
visits with a legal representative, the facility provides an
option for non-contact visits with legal representatives.
Prior to each visit, legal service providers and
assistants are identified per the standard.

(

IZI

D

D

D

IZI

D

IZI

D

D

D

0

IZI

IZI

0

D

The current list of pro bono legal organizations is
posted in the detainee housing areas and other
appropriate areas.

[gJ

0

0

The decision to permit or deny a tour is not delegated
below the level of District Director?

0

[gJ

0

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

IZI

0

D

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

IZI

D

0

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

D

0

IZI

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

IZI

0

0

I

Non-contact visits only

Standard Rating:
At-Risk

IZI Acceptable D Deficient D

0

b6, b7C
b6, b7C
7/29/04
Auditor's Signature 1 Date

(

I

Delegated to the OIC.

Not allowed to visit.

Repeat Deficiency

*Remarks: (Record significant/acts, observations, other sources used, etc)
/

Non-contact visits only in
the main visitation area.

~

(

VOLUNTARY WORK PROGRAM
Policy: In every facility offering a voluntary work program, ICE detainees will have the opportunity to work and earn
money by participating. While not legally required, ICE affords detainee workers basic Occupational Safety and Health
Administration (OSHA) protections.
Components
Does the facility have a voluntary work program?
If yes, do detainees participate?
In SPCs and CDFs staff maintains a written chart with
work assignments and the corresponding classification
levels.
Detainee housekeeping meets neatness and cleanliness
standards.
In SPCs and CDFs, low level-three detainees have the
opportunity to participate in special details, however, are
never allowed to work outside the secure perimeter.
Written procedures govern selection of detainees for the
Voluntary Work Program.
• The same procedures apply for replacement
workers as for "new" workers.
• Staff follows written procedures.
Where possible, physically and mentally challenged
detainees participate in the program.
The facility complies with work-hour requirements for
detainees, not exceeding:
• Eight hours a day.
Forty hours a week.
Detainee volunteers generally work according to fixed
schedule.
In SPCs and CDFs volunteers receive the $1/dal'stipend.
In SPCs and CDFs every participating detainee signed the
Voluntary Work Program agreement?
If a detainee is removed from a work detail, staff places
the written justification for the action in the detainee's
detention file.
Staff, in accordance with written procedure, ensures that
detainee volunteers understand their responsibilities as
workers before they join the work program.
The voluntary work program meets:
• OSHA standards
• NFPA standards
• ACA standards
• EOSH standards
Medical staff screens and formally certifies detainee food
service volunteers.
Before the assignment begins
As
a matter of written procedure
•
Detainees receive safety equipment! training sufficient for
the assignment
Does the OIC have the latest OSHA standards? NFPA?
ACA? EOSH?
Proper procedure is followed when an alien is injured on
the job.

(

(

No

NA

rgJ

0

0

rgJ

0

0

rgJ

0

0

rgJ

0

0

rgJ

0

0

rgJ

0

0

rgJ

0

0

rgJ
rgJ

0
0
0

0
0
0

18I

0

0

0

k8J

0

18I

0

0

18I

0

0

18I

0

0

18I

0

0

[8J

0

0

Remarks

level 3 only allowed to
clean their areas.

•

•

!

Yes

I

rgJ

Standard Rating:
y 0 At-Risk

lSI Acceptable D Deficient

Training
officer
not
involved in this program.

D Repeat Deficiency

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

-----

(

*Remarks: (Record significant facts, observations, other sources used, etc.)
The department heads are in charge of creating the training regimen for its volWltary workers. Management and the
Training Officer are not involved in the review and approval process of this program. The standards state that the
Training Officer and Management need to approve the training.

b6, b7C
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7/29/04

Auditor's Signature 1 Date

(

Department of HomelandtcUrity

(

Immigration and Customs Enforcement
Office of Detention and Removal

Condition of Confinement Review Worksheet
(This document must be attached to each G-324a Inspection Form)
This Form to be used for Detention Reviews of spes

Headquarters Detention and Removal Operations

(

Health Services
Section II

(

(

hours,
standard practice for staff to refer him/her to the medical
department.
The OIC immediately reports a hunger strike to the DO.
CDFs and IGSAs immediately report a hunger strike to
the INS.

(

of the facility obtains a hunger striker's consent
before medical treatment.
every
A signed
detainee who rejects medical evaluation or treatment.
During a hunger strike, staff documents and provides
the hunger-striking detainee three meals a day.
of drinking

X

0

0

X

0

0

X

0

0

X

0

0

X

0

0

x

0

D

X

D

D

X

D

D

X

D

D

X

D

D

X

D

0

Notification

to record the hunger
and food consumption, does staff always use Hunger
Strike Monitoring Form 1-839.

medical staff has written procedures for treating
hunger strikers.

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

D

X

0

X

D

D

X

D

0

X

0

D

Consent
medical staff

by

form not
to be routinely in use,
however, the content
contained on the 1-839
was found to be
consistently recorded in
the
notes

(

X Acceptable

Standard Rating:
Repeat Deficiency

D Deficient 0

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

b6, b7C

b6, b7C
/29 July 04
Auditor's Signature I Date

(

D

At·Risk

(

health program in
dards and the facility is

examine and

(
area.
has
own
The restricted access area is located within the confines
of the secure perimeter and no detainees have gained
access in the
twelve months.
The medical facility entrance includes a holding/waiting
the

o

x

o

X

o o

X

0

0

X

0

0

X

0

0

X

0

0

X

0

0

X

0

0

X

0

0

X

0

0

X

0

0

June

2 local
contracted for emergency
care. List of specialized
service providers update
2004

are:

•

•
•

Secured in a locked area within the medical
unit.
With physical access restricted to authorized
medical staff.
Procedurally. no copies made and placed in

are stored in a secure area. In INS
SPCs and CDFs they are stored in a manner consistent
of the INS standard.
with all

(

All narcotics .secured
double locks

e
(
Medical screening includes a Tuberculosis
test.
• Every arriving detainee receives a TB test.
• During the admission process.
• Detainee's TB-screening does not occur more
than one business day after his/her arrival at the
facility.
• Detainees not screened are housed separate
from the
All detainees receive a mental-health screening upon
arrival. It is conducted:
• By a health care provider or specially trained
officer;
• Before a detainee's assignment to a housing
unit.
In INS spes and CDFs the screener records all findings
on the in-processing health screening form (1-794). In
IGSAs the screening is recorded on an approved mental
facility health care
794s (or equivalent) to
medical attention.
The health care provider physically examines/assesses
arriving detainees within 14 days of admission.

(

Detainees in the Special Management Unit have access
to health care services.
detainees
services request
slips daily, upon request.
• Request slips are available in the languages
other than English, including every language
spoken by a sizeable number of the facility's
detainee population.
• Service-request slips are delivered in a timely
fashion to the health care
sick call is scheduled in accordance
with the guideline in paragraph VIII section E.
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 immediate outside
medical attention is
numbers for local

(

x

0

0

X

0

0

X

0

0

x

0

0
0

X

X

0

25 charts
1
found without 14 day PE.
LOP states PE's to be

0
call slips provided in
English and Spanish

X

0

D

X

0

0

X

0

0

X

0

0

X

0

0

X

0

0

x

0

0

Sick
conducted 7
days weekly, exceeds

x

D

D

X

D

D

D

x

x

D

D

es
Clinic for general
population. SMU meds
delivered to SMU by clinic
staff. Housing unit staff
authorized to issue
Tylenol within specified
guidelines. Training
provided on guidelines.
CD concurs with training

Noted via chart reviews

(

• are
records are placed a sealed envelope or
other container labeled with the detainee's name and Amarked
CONFIDENTIAL",
number
In SPCs and CDFs formal documented meetings are
held at least quarterly between the OIC of the facility
and the HSA of the medical

X

D

0

X

D

D

X

D

D

X

D

D

X

D

0

X

D

0

X

0

0

X

D

0

X

D

0

x

D

0

X

D

0

x

D

0

X

D

0

II

(
\

Meetings conducted
weekly

(
\

X Acceptable

0

Standard Rating:
Deficient
Repeat Deficiency

0

0

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
Pharmacy SIPS system has capability to print prescription labels in English as well as Spanish. Pharmacist is
currently developing resources for providing medication instructions. in written form for detainees in every
spoken language.
b6, b7C
b6, b7C
/29 July 04
Auditor's Signature I Date

(

::

(

x

0

0

x

0

0

x

0

0

x

0

0

"

Staff observes a suicide-watch detainee at least once
every 15 minute.

X

X Acceptable

0

0

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

b6, b7C

/29 July 04
Auditor's Signature j Date
b6, b7C

0

Standard Rating:
Deficient
Repeat Deficiency

0

15 min
conducted in
SSU, detainees requiring
1:1 obs are transferred to
"rubber" room, placed in
suicide

0

At-Risk

(

who are
to
office promptly notifies
or appropriate I
the next of kin of the detainee's: medical condition.
• The detainee's location.
on
• The limitations
For SPCs and CDFs There are guidelines addressing
State Advanced Directive Form for Implementing Living
Wills and Advanced Directives.
• The guidelines include instructions for detainees
who wish to have a living will other than the
generic form the DIHS provides or who wish to
appoint another to make advance decisions for
him or her.
to

(

X

0

0

X

0

0

x

0

0

x

0

0

X

0

0

x

0

0

X

D

0

X

0

0

X

0

0

LOP's reviewed
DNR noted to be
completed and
appropriately signed in
detainee's native
language.
Multidisciplinary
involvement including
Medical, Mental Health
and ICE noted.

via chart

Headquarters' Legal Counsel of the name and basic
circumstances of any detainee with a "Do Not
Resuscitate" order in the medical record. In the case of
IGSAs, this notification is made through the local INS
has
procedures to address
issues
of organ donation by detainees.
• INS SPCS and CDFs the procedures adhere to
the detention standard requirements, if not, state
the diffe
The facility has written procedures to notify INS officials,
deceased family members and consulates, when a
detainee dies
ile in Service.
The facility has a policy and procedure to address the
death of a detainee while in transport.
• In SPCs and CDFs the procedures adhere to
the
uirements in the detention standard.

review

(

At all INS locations the detainee's remains disposed of
in accordance with the provisions detailed in this
standard.
• The family has seven calendar days of the date
of notification (in writing or in person) to claim
the remains.
If the family chooses to claim the body, they are
told that they will assume responsibility for
making the necessary arrangements and paying
all associated costs (transportation of body,
burial, etc.).
• If the family wants to claim the remains, but
cannot afford the transportation costs, they are
aware that INS may assist the family by
transporting the remains to a location in the
United States.
• The consulate is notified.
• When family members cannot be located or
decline, orally or in writing, to claim the remains,
the consulate is notified in writing.
• The consulate is given seven calendar days to

•

(

X

0

0

X

0

0

x

0

0

x

0

0

x

0

0

the

•
and procedures
describing when to contact the local coroner regarding
such issues as
• Performance of an autopsy.
Who will perform the autopsy.
Obtaining
State approved death certificates.
•
of the
Local

•

•

(

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

181 Acceptable 0

b6, b7C
b6, b7C
J29July 04
Auditors Signature I Date

(

(,

Standard Rating:
Deficient 0 Repeat Deficiency

0

At-Risk

(

Department of Homelan.CUrity
Immigration and Customs Enforcement
Office of Detention and Removal

•

Condition of Confinement Review Worksheet
(This document must be attached to each G-324a Inspection Fonn)
This Form to be used for Detention Reviews of SPCS

Headquarters Detention and Removal Operations

Security and Control
Section III

CONTRABAND

(

Policy: All detention facilities will ensure the proper handling and disposal of all contraband. Documentation of
contraband destruction is required.
Components
The facility follows a written procedure for handling
iflegal contraband. Staff inventories, holds, and reports
it when necessary to the proper authority for
action/possible seizure.
Contraband that is government property is retained as
evidence for potential disciplinary action or criminal
prosecution.
Staff returns property not needed as evidence to the
proper authority. Written procedures cover the return of
such property.

(

No

NA

L8J

D

D

L8J

D

D

[8]

D

D

Altered property is destroyed following documentation
and using established procedures.
Before confiscating religious items, the OIC or
designated investigator contacts a religious authority.

L8J

D

D

[8]

D

0

Staff follows written proced ures when destroying hard
contraband that is illegal.

L8J

D

0

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.

L8J

D

D

L8J

D

D

(gJ

D

0

[8]

D

0

[8]

D

D

All identity documents (birth certificates, passports, etc.)
are held in A-files. Detainees receive copies upon
request. In SPCs and CDFs the detainee handbook (or
equivalent) tells detainees that a copy of each identity
document is available upon request.
Upon admittance, detainees receive notice of items they
can and cannot possess.
New arrivals receive copies of the rules regarding
contraband.
Detainees receive notification of contraband rules and
procedures in the detainee handbook (or equivalent).

(

Yes

Remarks

(

Verification Sources:
SOURCE
Detainee Handbook
Contraband LOQbook
A-File/Detention file
Review of facility policy and procedure for
control and disposition of contraband
Observation of contraband confiscation
Detainee and staff interviews

I2J Acceptable 0

TIME
11:30
08:45
09:00
15:45

DATE
07/28
07/28
07/28
07/27

LOCATION
ECC Admin Trailer
SIEA Offices
ECC Intake Area (Detention Folders)

08:45
09:00

07/28

From LOQbooks only
ECC Intake Area

07/28

Standard Rating:
Deficient 0 Repeat Deficiency

D

At-Risk

*Remarks: (Record significant facts, observations, other sources used, etc.)
Two entries were taken from the Contraband Logbook in the SIEA offices, where the book is kept, and the
detention files were later pulled for these two cases to verify appropriate forms and proceedures. The
detention files did, in fact, contain documentation that contraband was taken from the detainee at time of
admission to ECC.

b6, b7C

Auditor's Signature I Date

(

(

___?_~27-0¥

(

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

(

A detention file is created for every new arrival whose
stay will exceed 24 hours. In SPCs and CDFs written
procedures for in processing cover creation of the
detention file.
The OIC or staff designate ensures that necessary
equipment and supplies, including copier(s) and copier
paper, are available; that all equipment is maintained in
good working order, and that equipment has the
capacity to handle the volume of work generated.
The detainee detention file contains either originals or
copies of documentation and forms generated during
the admissions process. In SPCs and CDFs, if
necessary, copies of documents and forms contained
are in the detainee'S A-File.
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 Chief Detention Enforcement Officer (CDEO) or
equivalent directs certain documents be added to an
alien's detention file.
The detention files are located and maintained in a
secured area. If not the cabinets are lockable and
distribution of the keys is limited to supervisors.
The detention file remains active during the detainee's
stay. When the detainee is released from the facility,
staff adds copies of completed release documents, the
original closed-out receipts for property and valuables,
the original 1-385 or equivalent and other
documentation.
The officer closing the detention file makes a notation
that the file is complete and ready to be archived.
Staff makes copies and sends documents from the file
when appropriately requested by supervisory personnel
at the receiving facility or office.
In SPCs and CDFs archived files are purged after three
(3) years by shredding or burning.
Appropriate staff has access to the detention files and
other departmental requests are accommodated by
making a request for the file. Each file is properly
logged out and in by a representative of the responsible
department.

Yes

No

NA

181

D

D

181

D

D

181

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

0

~

0

0

~

D

D

Remarks

* See Remarks

(

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

Yes

No

NA

Field offices controlling detention in IGSA facilities
create and maintain detention files on all detainees
admitted to IGSA facilities. These files contain the
forms and documents set forth for SPCfCDF detention
files to the extent that the field office creates them or the
IGSA forwards them.

0

D

~

Remarks

Not an IGSA Facility.

Verification Sources:
SOURCE·
Review of facility policy and procedures.
Observation of in processing procedures
Review of detention files

[8] Acceptable

0

TIME

DATE

08:00
15:15
09:00

07/28
07/28
07/28

LOCATION
EGC Admin Trailer
EGG Intake Area
EGG Intake Area (Detention Files)

Standard Rating:
Deficient 0 Repeat Deficiency

0

At-Risk

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

(

The detention files are not located in a secure area. They are kept in lockable steele file cabinets near the
SDEO office in the processing area. These cabinets were unlocked when this reviewer arrived as one of the
officers was actively working with the files. Upon completion of his task this reviewer witnessed the officer
locking the file cabinets. He was asked how many officers in intake have keys to these file cabinets. The
officer stated he was the only one.

b6, b7C

Auditor's Signature

(

~
Date

7--c?-<..:..'Y

(

DISCIPLINARY POLICY
Policy: All facilities housing INS detainees 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
• deprivation of phvsical exercise
The rules of conduct, sanctions, and procedures for
violations are defined in writing and communicated to all
detainees verbally and in writing.
The following conspicuously posted in Spanish and
English or other dominate languages used in the facility:
• Rights and Responsibilities
• Prohibited Acts
• Disciplinary Severity Scale
• Sanctions
• If so, where posted
When minor rule violations or prohibited acts occur,
informal resolutions are encouraged.
If informal resolutions are not appropriate, incident
reports and Notice of Charges are promptly forwarded to
the INS/CDF supervisor.
Incident reports are investigated within 24 hours of the
incident report. The Unit Disciplinary Committee (UDC)
or equivalent does not convene before investigations
have ended.

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 detainee and staff
representative
Bases its findings on the preponderance of
evidence
• Imposes only authorized sanctions
A staff representative is available, if requested for a
detainee facing a disciplinary hearing
The facility permits hearing postponements or
continuances when conditions warrant such a
continuance. Reasons for are documented.

Yes

No

NA

'rg]

0

0

rg]

0

0

rg]

0

0

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0

0

[g]

0

0

rg]

0

0

rg]

0

0

['g]

0

0

rg]

D

D

rg]

D

0

rg]

0

0

rg]

0

0

•
•

(

'Remarks

DISCIPLINARY POLICY

(

Policy: All facilities housing INS detainees are authorized to impose discipline on detainees whose behavior is
not in compliance with facility rules and regulations.
Components
Yes
No
NA
Remarks
The duration of punishment set by the
OIC/recommended by the disciplinary panel does not
exceed established sanctions. The maximum time in
disciplinary segregation does not exceed 60 days for a
single offense.
Written procedures govern the handling of confidentialinformant 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.

~

D

D

~

D

D

~

D

D

Verification Sources:
SOURCE
Observing posted notices of rights
Observinq diSCiplinary hearings
Review of written disciplinary actions
Facility's written policy and procedures
Detainee and staff interviews *

TIME
10:00

DATE
07/27

09:45
08:00
15:00

07/28
07/28
07/27

LOCATION
EGC - Kilo Barracks
Not Available
ECC Intake (Detention Files}
EGC Admin Trailer
EGC SMU

Standard Rating:

[8] Acceptable

(

D Deficient D Repeat Deficiency D

At-Risk

*Remarks: (Record significant facts, obselVations. other sources used, etc.)
There was only one individual currently in the SMU (admin seg) awaiting a disciplinary hearing for misconduct.
Contract guards in the SMU were not able to tell this reviewer when that hearing was going to be.

b6, b7C

Auditors Signature / Date

(

,,7_~-::? -<.JY

__

EMERGENCY (CONTINGENCy) PLANS

(

Policy All facilities holding INS 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 of Understanding (MOU), with federal, local and state agencies to assist in times
of emergency.
Yes
No
Remarks
Components
NA
No Detainee or detainee groups exercise control or authority
over other detainees.
Detainees are protected from:
Personal abuse
Corporal punishment
Personal injury
Disease
• Property damage
• Harassment from other detainees
Staff are trained to identify signs of detainee unrest.
• What type of training and how often?
Does staff effectively disseminates information on facility
climate, detainee attitudes, and moods to the Officer In
Charge (OIC)?
• From the OIC to line staff?
There is a designated person or persons responsible for
emergency plans and their implementation. Sufficient time
is allotted to the person or group for development and
implementation of the plans.
The plans address the following issues:
• Confidentiality
Accountability (copies and storage locations)
Annual review procedures and schedule
• Revisions
Contingency plans include a comprehensive general section
with procedures applicable to most emergency situations.
The facility has cooperative contingency plans with
applicable:
• Local law enforcement agencies
State agencies
• Federal agencies
All staff receives copies of Hostage Situation Management
policy and procedures.
Staff is trained to disregard instructions from hostages,
regardless of rank. Within 24 hours after release hostages
are screened for medical and psychological effects. In
SPCs and CDFs, the OIC has a plan that includes the use
of a victim assistance team for released hostages and
hostage families.
In SPCs and CDFs a review team visits the facility after every
hostage taking.
Emergency plans include emergency medical treatment for
staff and detainee$ during and after an incident.
The food service maintain at least 3-days' worth of
emergency meals for staff and detainees.
Written plans locate shut-off valves and switches for all
utilities (water gas, electric).
In SPCs and CDFs emergency plans describe alternative
routes to the facility.

•
•
•
•

(

•
•

•

(

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gI

D

D

[gI

D

D

[gI

D

D

D

[gI

D

[gI

D

D

[gI

D

D

[gJ

D

0

~

D

D

0

0

D

~

0

D

[gJ

D

D

Annual Crisis Training

Detention Operations
b6, b7C
Supervisor

See Remarks

Section C, No. 16 of the
ECC Em.Cont. book

EMERGENCY (CONTINGENCy) PLANS

(

Policy All facilities holding INS 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 of Understanding (MOU), with federal, local and state agencies to assist in times
of emergency.
Components
Yes
No
NA
Remarks
In SPCs and CDFs emergency procedures include
notification of neiQhbors.
In SPCs and CDFs Do plans specify procedures for postemergency debriefings and discussion?
In SPCs the OIC periodically schedule emergency "drills" to
test the facility's emergency preparedness (readiness to
implement contingency plan(s)>" The plans reviewed annually.
Written procedures cover:
• Work/Food Strike
• Disturbances
• Escapes
• Bomb Threats
• Adverse Weather
Internal Searches
• Facility Evacuation
• Detainee Transportation System Plan
Internal Hostages
Civil Disturbances

•

~

D

D

~

D

D

~

D

D

~

D

D

Lists with numbers right
under title paQe.

Emergency drill Jog was
reviewed in the SIEA
building

•
•

c

Verification Sources:
SOURCE
Facility's written J)9Jicy andproced ures
Reviewing facility records
Detainee and staff interviews

[XI Acceptable

TIME

15:00
08:45

14:00

0

DATE
07/28
07/28
07/28

LOCATION
ECC Admin Trailer
ECC SIEA buildin~
ECC OIC Office

Standard Rating:
Deficient 0 Repeat Deficiency

D

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
The Emergency Contingency Plans book was very nicely organized and provided phone numbers to be called
in case of emergency. The phone numbers were easily accessible even in a frantic state of mind during an
emergency.

b6, b7C

Auditors Signature 1 Date

(

ENVIRONMENTAL HEALTH AND SAFETY

i

Policy: Every facility will control flammable, toxic, and caustic materials through a hazardous materials
program. The program will include, among other things, the identification and labeling of hazardous materials in
accordance with applicable standards (e.g., National Fire Protection Association [NFPA]); identification of
incompatible materials, and safe-handling procedures
Components
The facility has a system for storing, issuing, and
maintaining inventories of hazardous materials.
Constant inventories are maintained for all flammable,
toxic, and caustic substances used/stored in each
section of the facility.
The manufacturer's Material Safety Data Sheet (MSDS)
file is up-to-date for every hazardous substance used.
• The files list all storage areas, and include a
plant diagram and legend.
The
MSDSs and other information in the files
•
are available to personnel managing the
facility's safety program.
All personnel using flammable, toxic, and/or caustic
substances follow the prescribed procedures. They:
• Wear personal protective
• Equipment.
• Report hazards and spills to the
deSignated official.
The MSDSs are readily accessible to staff and
detainees in the work areas.

Yes

No

NA

~

D

D

~

D

D

~

D

D

~

D

D

D

~

D

~

D

,D

~

D

D

181

D

D

181

D

D

D

181

D

~

D

0

D

D

181

181

D

0

•

(

Hazardous materials are always issued under proper
supervision.
• quantities are limited.
• Staff always supervises detainees using these
substances.
"Flammable" and "combustible" materials (liquid and
aerosol) are stored and used according to label
recommendations.
Lighting fixtures and electrical equipment are installed in
storage rooms and other hazardous areas meet
National Electrical Code requirements.
In SPCs and CDFs the storage rooms meet the security
and structural requirements speCified in the standard.
Storage cabinets meet the physical requirements
specified in the standard?
All toxic and caustic materials stored in their original
containers in a secure area.
Excess flammables, combustibles, and toxic liquids are
disposed of properly and in accordance with MSDSs.
Staff directly supervises and accounts for products with
methyl alcohol. Staff receives a list of products
containing diluted methyl alcohol, e.g., shoe dye. All
such products clearly labeled as such. "Accountability"
includes issuing such products to detainees in the
smallest workable Quantities.
Every employee and detainee using flammable, toxic, or
caustic materials receives advance training in their use,
storage, and disposal.

Remarks

MSDS's were not located
at all chemicallocatations

Sev cases of dry bleach
was stored unsec in
laund
Imp Valley Environment
PO done as needed.
No methyl alcohol
products are used in
ECC.

ENVIRONMENTAL HEALTH AND SAFETY

(

Policy: Every facility will control flammable, toxic, and caustic materials through a hazardous materials
program. The program will include, among other things, the identification and labeling of hazardous materials in
accordance with applicable standards (e.g., National Fire Protection Association [NFPA]); identification of
incompatible materials, and safe-handling procedures
Components
The facility complies with the most current edition of
applicable codes, standards, and regulations of the
National Fire Protection Association and the
Occupational Safety and Health Administration (OSHA).
A technically qualified officer conducts the fire and
safety inspections. In SPCs arid CDFs, these
inspections are conducted informally on a weekly basis
and formally monthly. Every written inspection report
forwarded to the OIC.
The Safety Office (or officer) maintains files of
inspection reports? Including corrective actions taken.
The facility has an approved fire prevention, control, and
. evacuation plan.
The plan requires:
Monthly fire inspections.
• Fire protection equipment strategically located
throughout the facility.
• Public posting of emergency plan with
accessible building/room floor plans.
• Exit signs and directional arrows.
• An area-specific exit diagram conspicuously
posted in the diagrammed area.
Fire drills are conducted and documented monthly.
A sanitation program covers barbering operations.
The barbershop has the facilities and equipment
necessary to meet sanitation requirements.
The sanitation standards are conspicuously posted in
the barbershop.
Written procedures regulate the handling and disposal
of used needles and other sharp objects.
All items representing potential safety or security risks
are inventoried and a designated individual checks this
inventory weekly.
In SPCs and CDFs, the Health Services Administrator
(HSA) has implemented a program supporting a high
level of environmental sanitation.
In SPCs and CDFs the HSA conducts medical-facility
inspections every day. Each inspection includes noting
the condition of floors, walls, windows, horizontal
surfaces, and equipment.
Standard cleaning practices include:
• Using specified equipment; cleansers;
disinfectants and detergents.
An
established schedule of cleaning and follow•
up inspections.
The facility follows standard cleaning procedures.
• For SPCs and CDFs list discrepancies between
INS standard and facility procedures and
isolation-cleaning procedures been
implemented as required.
Spill kits are readilv available.

Yes

No

NA

~

0

0

18I

0

0

18I

0

D

18I

D

0

•

(

(

18I

0

0

18I
18I

0
0
D

0
D
D

18I

D

0

18I

0

0

18I

0

0

18I

D

0

18I

0

0

[8J

~

D

0

~

0

0

18I

D

0

Remarks

Fire extinguishers are
throughout facility but are
under padlock. Every
key ring has keys to
these locks.

1 per shift per quarter

In medical unit.

The delegated health &
safety to one of her staff
officers

The kitchen could use
some closer attention but
over all the facility is well
kept and very clean.

See remarks

(

ENVIRONMENTAL HEALTH AND SAFETY
Policy: Every facility will control flammable, toxic, and caustic materials through a hazardous materials
program. The program will include, among other things, the identification and labeling of hazardous materials in
accordance with applicable standards (e.g., National Fire Protection Association [NFPA]); identification of
incompatible materials, and safe-handling procedures
Components
A licensed medical waste contractor disposes of
infectious/bio-hazardous waste.
In SPCs and CDFs staff is trained to prevent contact
with blood and other body fluids and written procedures
are followed.
Do the methods for handling/disposing of refuse meet
all regulatory requirements.
A licensed/CertifiedlTrained pest-control professional
inspects for rodents, insects, and vermin.
• At least monthly.
• The pest-control program includes preventive
spraying for indigenous insects.
Drinking water and wastewater is routinely tested
according to a fixed schedule.
Emergency power generators are tested at least every
two weeks.
• Other emergency systems and equipment
receive testing at least quarterly.
• Testing is followed-up with timely corrective
actions (repairs and replacements).

(

(

Yes

No

NA

~

0

0

0

~

0

See remarks

~

0

0

Only 1 lisenced service
provider in EI Centro.
Completed 07/09/04,

~

0

0

[ZJ

0

0

~

0

0

Remarks

06/26/04,05/08/04,
03/26/04 . ...

Annually
Generator is
approximately two years
old and is very clean.
Very well maintained!

(

Verification Sources:
SOURCE
Observe maintenance crews
Observe detainee work crews
Inspect storage facilities
Facility's written policy and procedures
Inspect inspection reports
Inspect medical facilities
Review waste removal contracts
Review evacuation routeslmaps
Detainee and staff interviews *

TIME

DATE

10:30
11:00
11:00
11:30
11:35
11:15
10:30

07129/04
07/29/04
07/29/04
07/29/04
07/29/04
07129104
07/29/04

LOCATION
Limited but thouahout inspection.
Limited but thouahout inspection.
ECC Rec & Laundry Buildings
ECC Maintenance Building
ECC Maintenance Building
ECC Medical Unit Dumpsters
ECC Admin Trailer
ECC Maintenance Building
ECC Laundry

Standard Rating:

[8] Acceptable

D Deficient D Repeat Deficiency D

At-Risk

*Remarks: (Record significant facts, observations, other sources used, etc.)
There were not spill kits readily available at many of the posts within ECC. The Facility Manager was in
attendance during the review and he was in contact with his staff at each occasion ordering them to provide spill
kits to the location/post in question. Spill kits were provided but most officers questioned were unable to explain
how to use them. Only 3 of 10 staff member questions could explain how to use a spill kit.

b6, b7C

Auditors Signature 1 Date

(

(

7-c.)?~<.J,/

----

(

~.

HOLD ROOMS IN DETENTION FACILITIES

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

(

Components

Yes

No

NA

The hold room is situated in a location within the secure
perimeter.
In SPCs and CDFs the single occupant hold rooms
contain a minimum of 37 square feet (7 unencumbered
square feet for the detainee, 5 square feet for a
combination lavatory/toilet fixture, and 25 square feet
for a wheelchair turn-around area).
• If multiple-occupant hold rooms are used, there
is an additional 7 unencumbered square feet
for each additional detainee.
The hold rooms well ventilated, well-lighted and all
activating switches located outside the room.
The hold rooms contain sufficient seating for the
number of detainees held.
No bunks/cots/beds or other related make shift
sleeping apparatuses are permitted inside hold rooms.
In SPCs and CDFs constructed after 1998 the hold
rooms are equipped with stainless steel combination
lavatory/toilet fixtures with modesty panels. They are:
• Compliant with the American Disabilities Act.
Small hold rooms (1 to 14 detainees) have at
least one combi-unit.
Large hold rooms (15 to 49 detainees) are
provided with at least two combi-units.
In SPCs and CDFs constructed after 1998 the hold room
have floor drain(s).
The walls of the hold rooms escape proof.
The hold room ceilings are escape and tamper
resistant.
In SPCs and CDFs constructed after 1998 the door to the
hold room swings outward the door complies with the
specifications outlined in the standard.
Individuals are not held in hold rooms for more than 12
hours.
In SPGs, GDFs are family units, persons of advanced
age (over 70), females with children, and
unaccompanied juvenile detainees (under the age of
18) placed in hold rooms?
Male and females are segregated from each other at
all times.
Every effort is made to ensure that detained detainees
under the age of 18 are not held with adult detainees.
Detainees are provided with basic personal hygiene
items such as water, soap, toilet paper, cups for water,
feminine hygiene items, diapers and wipes.
In older facilities officers are within visual or audible
range to allow detainees access to toilet facilities on a
regular basis.
In SPCs and CDFs Officers inspect all property,
including parcels, suitcases, bags, bundles, boxes,
before accepting the property.

!8l

0

0

•
•

•

(

0

0

!8l

18I

0

0

!8l

0

0

18I

0

0

Remarks

Although there are three
small rooms originally
used for detainees, these
rooms are no longer
used. They have been
converted into clothing
issue, temporary property
storage.

18I

0

0

Very minor observation:
Hold Room A has a sign
on the door that states
capacity of 15 but that
room only has 1 toilet.

0

18I

0

Two of these rooms do
not have drains.

18I

0

0

18I

0

0

0

!8l

0

0

0

18I

0

0

18I

0

0

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18I

0

0

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0

0

0

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0

See Remarks
Neither females nor
juveniles are housed at
EGC.
No females are housed
at ECC.
No juveniles are housed
at EGG.

Property is not
inventoried until later in
processing,
after detainee is accepted

HOLD ROOMS IN DETENTION FACILITIES

(

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

Yes

No

NA

All detainees are given a putdown search for weapons or
contraband before beinQ placed in the room.
For SPCs and CDFs, each detention facility maintains
a detention log (manually or by computer) for each
detainee placed in a hold cell.
• The log includes the required information
specified in the standard.
In SPCs and CDFs officers provide a meal to any
detainee detained more than six hours.
Juveniles, babies and pregnant women have
access to snacks, milk or juice? .
• Meal are served to juveniles regardless of time in
custody
Officers closely supervise the detention hold rooms
using direct supervision (Irregular visual monitoring.).
• Hold rooms are irregularly monitored every 15
minutes.
• Unusual behavior or complaints are noted.
In SPCs and CDFs policy prevents an officer to enter
an occupied detention hold room unless another officer
is stationed outside the door.
When the last detainee has been removed from the
hold room, it is given a thorough inspection.
• Cleaning.
• Evidence of tampering with doors, locks,
windows, grills, plumbing or electrical fixtures is
reported to the shift supervisor for corrective
action or repair.
There is a written evacuation plan?
• There is a designated officer to remove
detainees from the hold rooms in case of fire
and/or buildinQ evacuation.
An appropriate emergency service is called
immediately upon a determination that a medical
emergency may exist.

IZI

D

D

~

D

D

•

(

IZI

D

D

IZI

0

D

~

0

0

0

~

0

~

0

0

IZI

D

0

Remarks

Meals are provided to the
hold rooms during meal
times, otherwise a bag
lunch is available upon
request during after
hours.
All four hold rooms are in
direct visual contact of
processing staff.

Staff states that the areas
are cleaned by workers
once emptied but failed to
specifically mention a
security inspection after
cleaning.

(

Verification Sources:
SOURCE
Hold room logbook review
Observation of hold rooms
Review of facility policy and procedure for
control and dis~osition of contraband
Detainee and staff interviews

o Acceptable 0

TIME
14:30
14:00
15:45

DATE
07/27
07/27
07/27

LOCATION
ECC Admin Trailer
ECC Intake - Hold Rooms
ECC Admin Trailer

14:00

07/27

ECC Intake

Standard Rating:
Deficient rgJ Repeat Deficiency

0

At-Risk

*Remarks: (Record significant facts, observations. other sources used, etc.)
Staff in the processing area state they do not have any memory of anybody spending more than 12 hours in
the hold rooms in the past two years; however, Hold Room logs show some detainees spending up to 17
hours in the holding area. Hold Room logs document that this is not typical but it is happening on small but
regular occassions. It should be noted that some detainees spent as little as 17 minutes in the processing
area.
This reviewer would not otherwise find this standard particularly defiCient; however, this was an issue on the
past review and should be continued to be improved upon. Log sheets do document that most of the
detainees spent less than 12 hours in holding. Although under 12 hours is acceptable, logs show that
detainees are frequently kept in holding for 8 to 12 hours before being transferred to Bravo West to await
medical clearance to go to the general population barracks.

(

It appears that progress has been made in this area since last review but logs reflect that the violations
continue on a less frequent basis.

b6, b7C

Auditor's Signature I Date

_7_--2 ,5>-G y

(

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
Policy It is the pOlicy of the INS Service to maintain an efficient system for the use, accountability and
maintenance of all keys and locks.
Components
In SPCs and CDFs each facility has the position of
Security Officer. If not
• A staff member appointed the collateral duties of
security officer.
In SPCs and CDFs the security officer has a written
position description.
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 admin istrative duties and responsibilities
relating to keys, locks etc.
The security officer, or equivalent in IGSAs, provides
training to employees in key control.
The security officer, or equivalent in IGSAs, maintains
inventories of all keys, locks and locking devices.

(

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

..

Yes

No

NA

~

D

D

~

D

0

0

I8l

D

~

D

D

~

D

D

~

D

0

~

D

0

~

D

D

~

0

D

0

I8l

D

~

I8l

D
0
-0
D

D
D
D
D

~

D

D

~

D

D

~

D

0

~

D

D

[gI

D

0

Remarks
is the
b6, b7C
primary Security Officer

Locksmithing only is
through maintenance.

Twice Annually

~

~

See Remarks.

A wall was built to hide
keys from public view.
All key rings ckecks had
chits indicating the
number of keys on the
ring.
b2High

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)

(

Policy It is the policy of the INS Service to maintain an efficient system for the use, accountability and
maintenance of all keys and locks.
Components
The facilities use a key accountability system.

(

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.
The facility has a key accountability policy and procedures
to ensure key accountability. The keys are physically
counted daily.
In SPCs and CDFs the designated key control officer the
only employee who is authorized to add or remove a key
from a ring.
In SPCs and CDFs the splitting of key rings into separate
rings is authorized in writing and documented.
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 permitted to handle keys
aSSigned to staff.

•

Yes

No

NA

~
~

0
0

0
0

~

0

0

~

0

0

Counted each shift at
Control Alpha

~

0

0

and must provide auth. to
locksmith in written form.

~

0

0

~

0

0

Remarks

Verification Sources:

A.
B.

A.
B.
C.

rocedures.
Detainee and staff interviews *

[81 Acceptable

D

TIME
13:15
13:00
12:00
13:30
13:00

DATE
07/29/04
07/29/04
07/29/04
07/29/04
07/29/04

LOCATION
ECC Control AI ha
ECC Control AI ha
EGG Maintenance Building
EGC Admin Trailer
ECC Control Alpha

Standard Rating:
Deficient 0 Repeat Deficiency

0

At-Risk

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

There are no padlocks or chains on doors or gates that are used for egress or control of detainees but there are
numerous padlocks within the perimeter on utility cages and fire extinguishers.
b6, b7C

Auditors Signature 1 Date

7-c,?-oj'

/

POPULATION COUNTS

!

Policy: All detention facilities shall ensure around-the-clock accountability for all detainees. This requires that
they conduct at least one formal count of the detainee population per shift, with additional formal and informal
counts conducted as necessary.

(

Components

Yes

No

NA

Staff conducts a formal count at least once each shift.
Activities cease or are strictly controlled while a formal
count is being conducted.
Do certain operations continue during formal counts?
Is a certain amount of movement tolerated during a
formal count?
Formal counts in all units take place simultaneously.
In SPCs and CDFs at least two officers participate in
the count in each area/unit.
In SPCs and CDFs count procedures include sending a
count slip to the control officer after each count.
In SPCs and CDFs both officers conducting the count
prepare and sign the count slip in indelible ink.
Officers do not allow detainee ~articipation in the count.
In SPCs and CDFs every area/unit conducts a recount
whenever an incorrect count is reported.
A face-to-photo count follows each unsuccessful
recount.
In SPCs and CDFs the two officers conducting the
area/unit count switch p_ositions for the recount.
Officers positively identify each detainee before
counting him/her as present.
Written procedures cover informal and emergency
counts.
• They followed during informal counts .
• During emergencies .
The control officer (or other designated position)
maintains an out -count record of all detainees
temporariJyleaving the facility.
In SPCs and CDFs the facility train all officers to follow
all requirements of INS' "Population Count Detention
Standard".
This training is documented in each officer's training
folder.

lZl
lZl
lZl
lZl
lZl
!8J

D
D
D
D
D
D

D
D
D
D
D
D

!8J

D

0

!8J
!8J
r8j

0
D
D

D
0
0

r8j

D

D

!8J

0

D

[8J

D

D

[8J

D

0

[8J

D

D

r8j

0

0

[8J

0

0

Remarks

6am,3pm,!!Qm,& 2am

No transfers/movement
No transfers/movement
but workers may be out.

Unless missing detainee
is already identified.

Only after unsuccessful
counts.

Located in Processing
Unit for detainees outside
of ECC.

Verification Sources:
Source
Observation of facility counts
Observation of escort procedures (whether out
counts are maintained)
Facility log books
Written policy and procedures

Time
15:30
15:30

Date
07/28
07/28

Location
ECC Alpha North
ECC Alpha North

15:45
16:00

07/28
07/28

ECC Alpha North
ECC Admin Trailer

Detainee and staff interviews*

15:45

07/28

EGC Alpha North

~ Acceptable

0

Standard Rating:
Deficient 0 Repeat Deficiency

0

At-Risk

*Remarks: (Record significant facts, observations, other sources used, etc.)
Staff state that there is no transfers tolfrom barracks during counts until a/l detainees are accounted for. They
state that it is typically 10 minutes from the beginning of count before they are notified to continue regular
operations.
An inaccurate count was not witnessed.

b6, b7C

(

(

(

POST ORDERS
Policy: INS provides officers aU necessary guidance for carrying out their duties. This guidance includes the
post orders established for every post, which are reviewed at least annually, and given to each officer upon
assignment to that post.
Components
NA
Remarks
Yes
No
I
[ ]
[]
Every Fixed post has a set of post orders.
I2J
Each set contains tlie latest inserts (emergency
I2J
0
0
memoranda, etc.) and revisions.
One individual or department is responsible for keeping
aU post-orders current with revisions that take place
I2J
0
0
between reviews.
In SPCs and CDFs the CDEO's office or contract
[gJ
equivalent maintains a complete set (central file) of post
0
0
orders.
[gJ
In SPCs and CDFs the central file accessible to all staff.
0
0
The OIC or Contract ilGSA equivalent
[gJ
0
0
initiate/authorizes all post-order changes.
The OIC or Contract IIGSA equivalent has signed and
Cover memo in each
0 P.O.
I2J
0
dated the last pa~e of every section.
folder.
In SPCs and CDFs, the post orders contain the required
Nicely kept and recently
I2J
D
D updated.
six sections.
A review/updatinglreissuing of post orders occurs
regularly. At a minimum, Annually.
I2J
D
D
• In SPCs and CDFs the facility follows written
post-order review procedures.
In SPCs and CDFs the OIC or Contract equivalent
CIEA writes and reviews
initiates the annual review by soliciting suggestions from
P.O.'s then forwards
[gJ
affected staff.
D
D them to the OIC for
approval.
• Staff has sufficient notice to prepare and submit
written suggestions by the due date
In SPCs and CDFs the OIC or contract equivalent
Historical files include HQ
retains all written suggestions, whether accepted or
memos and suggestions
from staff but are not
rejected, in a historical file.
[gJ
D
D
kept together in one file.
The
records
are
retained
for
two
years.
•
Could
be in one of two
The
historical
file
includes
comments,
if
any,
•
places.
from the reviewing official(s).
Procedures keep post orders and logbooks secure from
[gJ
D
D
detainees at all times.
In SPCs and CDFs emergency changes to post orders
[gJ
D
0
are made bymemorandum.
In SPCs the post orders for armed posts provide
b2High
instructions for:
[gJ
D
• Recognizing conditions when use of weapons is D
authorized.
• The care and safe handling of firearms.
Every armed-post officer qualifies with the post
d
b2High
D
D
I2J
weapon(sl before assuminQ post duty.
In SPCs armed-post post orders clearly state that if an
d
b2High
official is taken hostage, he/she loses all authority
[gJ
D
0
normally associated with his/her position, regardless of
rank or seniority.
Armed-post post orders provide instructions for escape
[gJ
b2High
0
0
attempts.
The post orders for housing units track the event
r8l
0
D
schedule.

e·
(

POST ORDERS
Policy: INS provides officers aI/ necessary guidance for carrying out their duties. This guidance includes the
post orders established for every post, which are reviewed at least annually, and given to each officer upon
assignment to that post.
Components
Housing-unit post officers record all detainee activity in a
log. The post order includes instructions on maintaining
the logbook.
In SPCs and CDFs the SDEO/contract supervisor visits
each housing area and reviews the logbooks at least
once J!er shift.

Yes

No

NA

[gj

0

0

I2$J

0

0

Remarks

Verification Sources:
SOURCE
Post orders in use atQosts
Master copy of post orders
Documentation of firearms qualifications
Housing unit logbooks
Facility policy & procedures for post orders
History file for each set ofpost orders
Staff Jnterview(s) *

I:2J Acceptable 0

10:00
10:30

DATE
07/27
07/28

10:00
10:30
10:30
15:30

07/27
07/28
07/28
07/27

TIME

LOCATION
ECC Barracks & SMU
ECC Admin Trailer
Not Available
ECC Barracks
ECC Admin Trailer
ECC Admin Trailer
ECCSMU

Standard Rating:
Deficient 0 Repeat Deficiency

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

(
b6, b7C

0

At-Risk

SECURITY INSPECTIONS
Policy: Post assignments in the facility's high-risk areas, where special security procedures must be followed,
will be restricted to experienced personnel with a thorough grounding in facility operations.
No
Components
NA
Yes
Remarks
The facility has a comprehensive security inspection
policy. The policy specifies:
• Posts to be inspected
• Required inspection forms
[8J
0
0
• Frequency of inspections
Guidelines for checking security features
Procedures for reporting weak spots,
inconsistencies, and other areas needing
improvement
Every officer is required to conduct a security check of
Results are not doc'd
lZI
D
0 unless
his/her aSSigned area. The results are documented.
somethin9_ wrong.
Documentation of security inspections is kept on file.
0
0
lZI
In SPCs and CDFs an officer been assigned responsibility
b6, b7C
Sec. Officer
for ensuring the security inspection process covers all
0
0
lZI
areas of the facility.
Procedures ensure that recurring problems and a failure to
take corrective action are reported to the appropriate
0
0
lZI
manager.
In SPCs and CDFs the front entrance has a sallyport-type
0
0
lZI
entrance, with interlocking electronic doors or grilles.
The front-entrance officer checks the ID of everyone
This was def. last review[8J
0
0 - completely rectified.
entering or exiting the facility.

•
•

(

All visits officially recorded in a visitor logbook or
electronically recorded.
In SPCs and CDFs the Control Center maintain employee
Personal Data Cards (Form G-74 or contract equivalent).
The facility has a secure visitor pass system.
Every Control Center officer receives specialized training.
The Control Center is staffed around the clock.
Policy restricts staff access to the Control Center.
Detainees do not have access to the Control Center.
Communications are centralized in the Control Center.
In SPCs and CDFs the recall list includes the current
home telephone number of each employee. Phone
numbers are updated as needed.
In SPCs and CDFs staff makes watch calls every half-hour
between 6 PM and 6 AM.
Officers monitor all vehicular traffic entering and leaving
the facility.
The facility maintains a log of all incoming and departing
vehicles to sensitive areas of the facility. Each entry
contains:
• The driver's name
• Company represented
• Vehicle contents
• Delivery date and time
• Date and time out
Vehicle license number
Name of employee responsible for the vehicle
during the facility visit

•
•

lZI

0

0

[8J

0
0

lZI
lZI

0
0
0
0
0
0
0

[8J

D

0

0

[8J

0

f8]

D

0

[8J

lZI
18I
[8J

Control Alpha has for
ICE,PHS. & Contractors

[]

0

[]
[]

0
On computer-Only
contract supervisors have
access.
hourly, not every half
hour
See Remarks
See Remarks

[8J

0

0

i

SECURITY INSPECTIONS
Policy: Post assignments in the facility's high-risk areas, where special security procedures must be followed,
will be restricted to experienced personnel with a thorough grounding in facility o:>erations.
Components
No
Yes
Remarks
NA

(

Officers thoroughly search each vehicle entering and
leaving the facility.
The facility has a written policy and procedures to prevent
the introduction of contraband into the facility or any of its
components.
Tools being taken into the secure area of the facility are
inventoried before entering and prior to departure.
The SMU entrance has a sallyport.
Written procedures govern searches of detainee housing
units and personal areas.
Housing area searches occur at irregular times.
Every search of the SMU and other housing units
documented.
Storage and supply rooms; walls, light and plumbing
fixtures, accesses, and drains, etc. undergo frequent,
irregular searches. These searches are documented.
Walls, fences, and exits, including exterior windows, are
inspected for defects once each shift.
Daily procedures include:
• Perimeter alarm system tests.
• Physical checks of the perimeter fence.
• Documenting the results.
In SPCs and CDFs the maintenance supervisor and
CDEOI Chief of Security make monthly fence checks.
Visitation areas receive frequent, irregular inspections.

0

J:8J

0

J:8J

0

0

J:8J

0

0

J:8J

J:8J
J:8J
J:8J

0
0
0

0
0
0

J:8J

0

0

J:8J

0

0

J:8J

0

0

0

~

J:8J

0

D
0

See Remarks

[J

0

Each shift by contract
supervisors

(

Verification Sources:
SOURCE
Observing ins~ection procedures
Observing procedures at front entrance
Reviewing logbooks
Facility's written policy and procedures
Detainee and staff interviews

TIME

DATE

15:30
16:00
15:15
15:30

07/29/04
07/29/04
07/29/04
07/29/04

LOCATION
Not Available
Front Entrance
ECC Contract Project Manager
ECC Admin Trailer
Throughout EGC Facility

Standard Rating:

r8J Acceptable D Deficient D Repeat Deficiency D

At-Risk

*Remarks: (Record significant facts, observations, other sources used, etc.)
Facility deliveries are during first shift only. Swing shift and night shift document all vehicle entries into the
salleyport area at Control Alpha (logs confirmed). These entries are presumably transport vehicles only and
are directly related to transportation of detainees.
Deliveries during first shift are documented at Gate 1 of the salley port by security staff stationed at that gate.
Logs for day shift are kept at that location and are appropriate. There ar
b2High

b2 high

(
-<;f/

b6, b7C

Auditors Signature

(

Date

(

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

Yes

No

NA

~

0

0

~

0

0

~

D

D

•

~

D

0

•
•

~

D

0

~

0

0

181

D

0

The Administrative Segregation unit provides
non-punitive protection from the general population and
individuals undergoing disciplinary segregation.
• Detainees are placed in the SMU
(administrative) in accordance with written
criteria.
In exigent circumstances, staff may place a detainee in
the SMU (administrative) before a written order has
been approved.
A copy of the order given to the detainee within
24 hours.
The ole (or equivalent) regularly reviews the status of
detainees in administrative detention?
• A supervisory officer conducts a review within
72 hours of the detainee's placement in the
SMU (administrative).
A supervisory officer conducts another review after the
detainee has spent seven days in administrative
segregation.
• Every week thereafter for the first month.
Every 30 days after the first month.
Does
each review include an interview with the
•
detainee.
• Is a written record made of the decision and
the justification.
The detainee is given a copy of the decision and
justification for each review.
If not, why not?
The detainee is given an opportunity to appeal
the reviewer's decision to someone else in the
facility.
The ole (or equivalent) routinely notifies the Assistant
District Director (or staff officer in charge of IGSAs),
Detention and Deportation (ADDD), any time a
detainee's stay in administrative detention exceeds 30
days.
• Upon notification that the detainee's
administrative segregation has exceeded 60
days, the ADDD forwards written notice to the
Assistant Regional Director for DRO.
The ole or equivalent) reviews the case of every
detainee who objects to administrative segregation
after 30 days in the SMU.
• A written record is made of the decision and
the justification.
• The detainee receives a copy of this record.

•

(

Remarks

SPECIAL MANAGEMENT UNIT (SMU)
Administrative Segregation
Policy: The Special Management Unit required in every facility isolates certain detainees from the general
population. The Special Management Unit will consist of two sections. One, Administrative Segregation,
houses detainees isolated for their own protection; the other for detainees being disciplined for wrongdoing (see
the "Special Management Unit [Disciplinary Segregation]" standard).
Components
The detainee is given the right to appeal to the ole (or
equivalent) the conclusions and recommendations of
any review conducted after the detainee has remained
in administrative segregation for seven consecutive
days.
Administratively segregated detainees enjoy the same
general privileges as detainees in the general
population.
The SMU well ventilated.
• Adequately lighted.
• Appropriately heated.
• Maintained in a sanitary condition.
All cells are equipped with beds.
• Every bed securely fastened to the floor or
wall.
The number of detainees in any cell does not exceed
the occupancy limit.
Does the ole approve excess occupancy on a
case-by-case basis?
When
occupancy exceeds recommended
•
capacity, do basic living standards decline?
• Do criteria for objectively assessing living
standards exist?
• If yes, are the criteria included in the written
procedures?
The segregated detainees do not have fewer
opportunities to exchange/launder clothing, bedding,
and linen than detainees in the general population.
Detainees receive three nutritious meals per day.
From the general population's menu of the day.
Do detainees eat only with disposable utensils.
Is food ever used as punishment.
Each detainee maintains a normal level of personal
hygiene in the SMU.
The detainees have the opportunity to shower
and shave at least three times a week.
• If not, explain.
The detainees are provided:
Barbering services.
Recreation privileges in accordance with the
"Detainee Recreation" standard.
• Non-legal reading material.
• Religious material.
• The same correspondence privileges as
detainees in the general population.
• Telephone access similar to that of the general
population.
• Personal legal material.

Yes

No

NA

l2l

0

0

[g]

0

0

l2l

0

0

[g]

0

0
Staff staes that they have
double bunked in the
SMU but it is very rare.

•

(

•
•
•
•

Remarks

[g]

0

0

[g]

0

D

[g]

0

0

[g]

0

0

l2l

D

0

•
•

Staff state that due to
heat & humidity they offer
detainees a chance to
shower daily.

SPECIAL MANAGEMENT UNIT (SMU)
Administrative Segregation

(

Policy: The Special Management Unit required in every facility isolates certain detainees from the general
population. The Special Management Unit will consist of two sections. One, Administrative Segregation,
houses detainees isolated for their own protection; the other for detainees being disciplined for wrongdoing (see
the "Special Management Unit [Disciplinary Segregation]" standard).
Components
A health care professional visits every detainee at least
three times a week.
• The shift supervisor visits each detainee daily.
• Weekends and holidays.
Procedures comply with the "Visitation" standard.
• The detainee retains visiting privileges.
• The visiting room available during normal
visitill9 hours.
Visits from clerQV are allowed.
Detainees do not have have less law-library access
than the general population.
• Are they required to use the law library
separately, as a group? If so:
L~gal materials brought to them.
The SMU maintains a permanent log.
• Detainee-related activity, e.g., meals served,
recreation, visitors etc.
SPC procedures include completing the SMU Housing
Record (1-888) immediately upon a detainee's
placement in the SMU.
Staff completes the form at the end of each
shift.
• CDFs and IGSA facilities use Form 1-888 (or
local equivalent).
Does staff record whether the detainee ate, showered,
exercised and took any medication during every shift?
• Does the log record all pertinent information,
e.g., a medical condition, suicidal/assaultive
behavior, etc.?
• Does the medical officer/health care
professional Sign each individual's record
during each visit?
• Does the housing officer initial the record when
all detainee services are completed or at the
end of the shift?
A new record is created for each week the detainee is
in Administrative Segregation.
• These weekly records are retained in the SMU
until the detainee's return to the general

Yes

No

NA

!25l

0

0

!25l

0

0

!25l

[J

0

~

0

0

[gJ

0

0

~

0

0

!25l

0

0

!25l

0

0

•

(

•

~opulation.

(

Remarks
Medical staff visits daily.
Logs are available in the
SMU.

Verification Sources:
SOURCE
SMU Observation
SMU logs
Review of the facility's Administrative
Segregation polic:y_and Qrocedures
Detainee and staff interviews
*Other

!;gI Acceptable 0

TIME
15:30
15:30
11:00

DATE

07/27
07/27
07/27

LOCATION
ECC SMU
ECC SMU
ECC Admin Trailer

15:00

07/27

ECC SMU

Standard Rating:
Deficient 0 Repeat Deficiency

0

At-Risk

*Remarks: (Record significant facts, observations, other sources used, etc.)
Contract detention staff were interviewed. They state that they prefer to treat detainees in the SMU (admin or
disciplanary) with respect as it begets respect. Three detainees were interviewed en route to the law library
from the SMU and they all stated that the SMU staff are excellent about getting them their programming (law
library, ree, etc).

b6, b7C

Auditor's Signature I Date

(

"C)r

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

Yes

No

NA

Officers placing detainees in disciplinary segregation
follow written procedures.
The sanctions for violations committed during one
incident do not exceed 60 d"!Ys.
Disciplinary
Segregation
Order
completed
A
accompanies the detainee into the SMU?
The detainee receives a copy of the order
within 24 hours of placement in disciplinary
segregation.
Standard procedures include reviewing the cases of
individual detainees housed in disciplinary detention at
set intervals.
• Who conducts the review?
• What is reviewed?
How is the review documented?
Does the reviewer interview the detainee?
• Can the reviewing officer recommend an early
release from the SMU?

~

D

0

~

D

D

~

0

D

•

•
•

(

•

If yes, under what circumstances?

•

After each formal review, does the detainee
receive a written copy of the decision and
reason(s) for it?

The conditions of confinement in the SMU are
proportional to the amount of control necessary to
protect detainees and staff.
Detainees in disciplinary segregation have fewer
privileges than those housed in administrative
segregation.
Living conditions in disciplinary SMUs modified to
reinforce acceptable behavior.
If yes, does staff prepare written
documentation for this action.
• Does the OIC sign to indicate approval.
Every detainee in disciplinary segregation receives the
same humane treatment, regardless of offense.
The quarters used for segregation are:
• Well-ventilated.
• Adequately lighted.
• Appropriately heated.
• Maintained in a sanitary condition.

•

All cells are equipped with beds.
• The beds securely fastened to the floor or wall of
the cell.

(

Remarks

What is reviewed?
1) Abides by all rules
and regulations and 2)
provided showers, meals,
rec, and other basic living
standards.

~

D

D

~

D

D

I2?J

D

0

The SDEO may authorize
early release from the
SMU if it is no longer
necessary to control
behavior.

Per policy.

Living conditions (heat,

alc, lighting, meals, etc)

D

I:8J

D

I:8J

D

0

[gJ

D

D

~

D

D

are not altered/modified
in anyway.

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)

(

Policy: Each facility will establish a Special Management Unit in which to isolate certain detainees from the
general population. The Special Management Unit will have two sections, one for detainees in Administrative
Segregation; the other for detainees being segregated for disciplinary reasons.
Components
The number of detainees confined to each cell or room
does not exceed the number for which the space was
designate.
• Does the OIC approve excess occupancy on a
temporary basis.

(

Is a dry cell part of the disciplinary SMU?
When a detainee is segregated without clothing,
mattress, blanket, or pillow, a justification is made and
the decision is reviewed each shift. Items are returned
as soon as it is safe.
Detainees in the SMU have the same opportunities to
exchange clothill9, bedding, etc., as other detainees.
Detainees in the SMU receive three nutritious
meals/days.
• Selected from the Food Service's menu of the
day.
• Food is not used as punishment.
Detainees are allowed to maintain a normal level of
personal hygiene. including the opportunity to shower
and shave at least three times/week.
The detainees receive, unless documented as a threat
to secu rity:
• Barbering services.
• Recreation privileges.
• Other-than-Iegal reading material.
• Religious material.
The same correspondence privileges as other
detainees.
• Personal legal material.
When phone access is limited by number or type of calls,
limits do not apply to the following:
• Calls about the detainee's immigration case or
other legal matters.
• Calls to consular/embassy officials.
• Calls during family emergenCies (as determined
by the OIClWarden).
A health care professional visits every detainee in
disciplinary segregation every day, Monday through
Friday.
• The shift supervisor visit each segregated
detainee daily
• Weekends and holidays.
SMU detainees are allowed visitors, in accordance with
the "Visitation" standard.
SMU detainees receive legal visits, as provided in the
"Visitation" standard.
• Legal service providers notified of security
concerns arising before a visit.

Yes

No

NA

~

0

0

0

~

0

~

0

0

~

0

0

[gJ

0

0

[gJ

0

0

~

0

0

[gJ

0

0

Remarks
The OIC may authorize if
other living conditions
may be maintained;
however, at time of
review the SMU was not
full.
See remarks

Showers are offered
daily.

•

~

0

D

~

0

0

[gJ

D

D

Logs are available in the
SMU and in the medical
unit documenting the
visits.

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)

(

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

Visits from clergy are allowed.
• The clergy member given the option of
visiting/not visiting the segregated detainee.
• Violent/uncooperative detainees denied access
to religious services when safety and security
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
material brought to individuals in the
•
SMU on a case-by-case basic.
Staff documents every incident of denied
access to the law library.
All detainee-related activities are documented, e.g.,
meals served, recreation activities, visitors, etc.
Is the SPC's, the Special Management Housing Unit
Record (1-888) is prepared as soon as the detainee is
placed in the SMU.
• All 1-888s filled out by the end of each shift
• The CDFIIGSA facility use Form
1-888 (or equivalent local form).
SMU staff records whether the detainee ate, showered,
exercised, took medication, etc.
• Details about the detainee logged, e.g., a
medical condition, suicidal/violent behavior,
etc.
• The health care official sign individual records
after each visit.
• The housing officer initials the record when all
detainee services are completed or at the end
of the shift.
• A new record is created weekly for each
detainee in the SMU.
The
SMU retains these records until the
•
detainee leaves the SMU.

Yes

No

NA

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

•

(

•

Remarks

Verification Sources:
SOURCE
Detainee Detention Files
SMU Logs
Facility Policy and Procedures
Detainee and staff interviews
Observations of SMU

TIME
09:30
15:00
11 :00
15:00
15:30

DATE
07128
07127
07/27
07/27
07127

LOCATION
ECC Intake - Detention Files
ECC SMU
ECC Admin Trailer
ECC SMU
ECCSMU

Standard Rating:
Deficient D Repeat Deficiency

IZJ Acceptable 0

D

At-Risk

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

There is a dry cell with rubber walls located within the SMU building but, per policy, it is considered a part of
the medical unit. Detainees are not housed in that room without medical authorization. Staff was unaware of
the policy stating it was part of the medical unit but they did confirm that anybody that goes into that room
comes from the medical unit.

b6, b7C

Auditor's Signature I Date

(

(
'.

~
-."

0:;;.

-2. ~

-<J

'Y

(

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

Yes

No

NA

[gj

D

D

[gj

D

D

[gj

D

D

[gj

D

D

[gj

D

D

Remarks

•

'•.
•
•
•

(

In SPCs and CDFs, the tool inventories are conducted
as specified in the detention standard.
The facility has a tool classification system. In SPCs and
CDFs tools classified according to:
• Restricted (dangerous/hazardous)

•

[gj

0

D

[gj

D

D

Non Restricted (non-hazardous).

Department heads are responsible for implementing
tool-control procedures. In SPCs and CDFs they are
required to:
• Prepare a computer-generated inventory of
all class "R" tools.
Post a copy of the class "R" tool inventory
with the equipment, in a prominent position.
• Post a copy of the class "R" tool inventory
with the equipment, in a prominent position.
• Submit a second copy of the inventory to
the CDEO.
• Repeat the class "R" tool inventory on a
regular schedule (at least weekly, monthly, or
quarterly), as follows:
• Food service department-weekly
Maintenance department
medical facility-monthly
• Electronics work area, recreation area(s),
and armory-quarterly.
Send
a copy of inventory report to the OIC.
•
Report
missing tools in accordance with
•
procedures in the standard. (see section
1I1.H., below).

•

•

All tools are classified as
restricted. None are
considered NonRestricted.

TOOL CONTROL

/
(

Policy: It is the policy of all facilities that all employees shall be responsible for complying with the tool control
policy. The Maintenance Supervisor shall maintain a computer generated or typewritten Master Inventory list of
tools and equipment and the location in which tools are stored. These inventories shall be current, filed and
readily available for tool inventory and accountability during an audit.
Components ;
The facility has policies and procedures in place to
ensure that all tools are marked and readily identifiable.
The facility has an approved tool storage system.
The system ensures that all stored tools are
accountable.
Commonly
used tools (tools that can be
•
mounted) are stored in such a way that
missing tool are readily notice.
Each facility has procedures for the issuance of tools to
staff and detainees. In SPCs and CDFs:
• Restricted tools are issued only to the individual
who will be using it.
• Detainees are not permitted to use non-restricted
tools except under supervision.
A
metal or plastic chit receipt used to sign out
•
tools.
• The ole has established site-specific procedures
for the control of ladders, extension cords, and
ropes.
The
CD EO or contract equivalent approves the
•
issuance of tools to a specified project for
extended periods.
The facility has policies and procedures to address the
issue of lost tools. The policy and procedures include:
• Verbal and written notification.
• Procedures for detainee access.
• Necessary documentationlreview for all
incidents of lost tools.
Broken or worn out tools are surveyed and disposed of
in an ap~ropriate and secure manner.
All private or contract repairs and maintenance workers
under contract to the INS, or other visitors, submit an
inventory of all tools prior to admittance into or departure
from the facility.

Yes

No

.NA

~

0

0

•

(

(

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

Remarks

Facility uses a red
outlined shape of tool and
a chit system to identify
tools' locations.

Recycled with service
provider as needed.

(

Verification Sources:
SOURCE
Tool inventories
Review of facility policy and procedure
Housing unit log books
Observation of tool issuance
Detainee and staff interviews"

IZI Acceptable 0

TIME

DATE

12:15
11:45
15:00
12:00
11 :45

07/29
07/29
07/28
07/29
07/29

LOCATION
ECC Maintenance Building (Tool Rm)
ECC Admin Trailer
ECC Alpha North
ECC Maintenance Building (Tool Rml
ECC Admin Trailer

Standard Rating:
Deficient
Repeat Deficiency

0

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

Auditor's Signature I Date

(

(

/',-? r-Gy

0

At-Risk

(

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

Transporting officers comply with applicable local, state,
and federal motor vehicle laws and regulations. Records
support this finding of compliance.
Every transporting officer required to drive a commercial
size bus has a valid Commercial Driver's License (COL)
issued by the state of employment.
Supervisors maintain records for each vehicle operator.
Officers use a checklist during every vehicle inspection.
Officers report deficiencies affecting operability.
• Deficiencies are corrected before the vehicle
Roes back into service.
Transporting officers:
• Limit driving time to 10 hours in any 15-hour
period.
• Drive only after eight consecutive off-duty hours.
• Do not receive transportation assignments after
having been on duty, in any capacity, for 15
hours.
• Drive a 50-hour maximum in a given work week;
a 70-hour maximum during eight consecutive
days.
During
emergency conditions (including bad
•
weather), officers may drive as long as
necessary and safe to reach a safe
area-exceedinQ the 1O-hour limit.
Two officers with valid CDLs required in any bus
transporting detainees.
• When buses travel in tandem with detainees,
there two qualified officers per vehicle.
• An unaccompanied driver transports an empty
vehicle.
Before the start of each detail, the vehicle is thoroughly
searched.
Positive identification of all detainees being transported is
confirmed.
All detainees are searched immediately prior to boarding
the vehide by staff controlling the bus or vehicle.
The facility ensures that the number of detainees
transported does not exceed the vehicles manufacturers
occup_ancy level.
Protective vests are provided to all transporting officers.
The vehicle crew conducts a visual count once all
passengers are on board and seated.
• Additional visual counts are made whenever the
vehicle makes a scheduled or unscheduled
stop.
Policies and procedures are in place addressing the use of
restraining equipment on transportation vehicles.

•

(

Yes

No

NA

~

0

0

~

0

0

~

0

0

~

0

0

Remarks

In the SIEA Bldg.

All per ECC SOP's

~

0

0

~

0

0

~

0

0

[gI

0

0

~

0

0

[gI

0

0

[gI

0

0

Long range busses are
always available if they
can't fit into van.
Per lEA staff--not actually
witnessed.

~

0

0

t8J

0

0

TRANSPORTATION
(Land Transportation)

(

Policy The Immigration and Naturalization Service will take all necessary precautions to protect the lives,
safety, and welfare of our officers, the general public, and those in INS 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.
Components
Officers ensure that no one contacts the detainees.
One officer remains in the vehicle at all times
when detainees are present.
Meals are provided during long distance transfers.
• The meals meet the minimum dietary standards,
as identified by dieticians utilized by the Service.
The vehicle crew inspects all Food Service pickups before
accepting delivery (food wrapping, portions, quality,
quantity, thermos-transport containers, etc.).
• Before accepting the meals, the vehicle crew
raises and resolves questions, concerns, or
Service
with
Food
discrepancies
the
representative.
latrines,
drinking-water
and
• Basins,
containers/dispensers are cleaned and sanitized
on a fixed schedule.
INS Vehicles have:
Two-way radios.
Cellular telephones.
• Equipment boxes stocked in accordance with the
Use of Force Standard.
The vehicles are clean and sanitary at all times.
Personal property of a detainee transferring to another
facility:
• Is inventoried.
• Is inspected.
• Accompanies the detainee.
The following contingencies are included in the written
procedures for vehicle crews:
• Attack
• Escape
• Hostage-taking
• Detainee sickness
• Detainee death
• Vehicle fire
• Riot
• Traffic accident
• Mechanical problems
• Natural disasters
• Severe weather
• Passenger list is not exclusively men or women
or minors

•

•
•

(

No

NA

1ZI

0

0

1ZI

0

D

1ZI

0

0

Yes

0

IZJ

0

IZJ

0

0

Remarks

Box lunches & water
provided for trips over 4
hours.

No equipment boxes in
vans. Flares were in
vans but there were no
blankets.

& recorded on the 1-216

IZJ

0

0
per policy women &
children to ride in another
vehicle if trip is >6 hours
& they are to sit in the
front of the vehicle.

IZJ

0

0

(

Verification Sources:
SOURCE
Observing transportation activities
Traveling with vehicle crew
Observing search procedures
Observing restraining procedures
Facil~s written policy and procedures
Detainee and staff interviews·

t8J Acceptable 0

TIME
09:00

DATE
07/29

09:15

07129

15:00
08:30

07/28
07/29

LOCATION
ECC Processing (Detention Vans)
Not Available
ECC Salley Port
Not Available
ECC Admin Trailer
ECC Processing

Standard Rating:
Deficient D Repeat Deficiency

0

At-Risk

*Remarks: (Record Significant facts, obseNations, other sources used, etc.)
Staff states that detainees could be in leg irons or handcuffed to each other. The transporting officer would
decide at what level of security to operate.

b6, b7C

(

(

'.

7-2?,-<lY

•

(

USE OF FORCE

Policy: The U.S. Immigration & Naturalization Service authorizes the use of force only as a last alternative after
all other reasonable efforts to resolve a situation have failed. Only that amount of force necessary to gain
control of the detainee, to protect and ensure the safety of detainees, staff and others, to prevent serious
property damage and to ensure institution security and good order may be used. Physical restraints necessary
to gain control of a detainee who appears to be dangerous may be employed when the detainee:
Components
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 offorce.
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 Technique.
• Under staff supervision.
• In SPCs and CDFs a Physician's Assistant
is present prior to and during the Use-ofForce Team Technique to observe and
immediately treat any injuries.
Staff members are trained in the performance of the
Use-of-Force Team Technique.
All use-of-force incidents are documented and reviewed.
In SPCs and CDFs the calculated-use-of-force video
sequentially presents the following:
• Team Leader's introduction
• Face of each team member (without
helmet), identified by name and title
Team
Leader offering detainee a last
•
chance to comply, and explaining the useof-force results of noncompliance
Unedited coverage of the operation, from
the use-of-force order to the end
• Medical staff examining the detainee in
restraints, with close-ups recording the
presence or absence of injuries on the
detainee's body
• Staff injuries, with oral description(s)
All videotapes of use-of-force incidents catalogued and
preserved for at least 2-1/2 years after last documented
use.
• The videotapes available for incident review .

•

(

Yes

No

NA

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D
D

d

~

~

~

D

D

Remarks

D

D

D

Policy is appropriate but
staff and the OIC state
that no significant
incidents have been
video'd for several years.
Unable to confirm the
SOP is being followed as
there is no incidents to
compare to.

OIC states that he had
some video from several
years ago but sent it out
to warehouse storage.

•

(

USE OF FORCE

Policy: The U.S. Immigration & Naturalization Service authorizes the use of force only as a last alternative after
all other reasonable efforts to resolve a situation have failed. Only that amount of force necessary to gain
control of the detainee, to protect and ensure the safety of detainees, staff and others, to prevent serious
property damage and to ensure institution security and good order may be used. Physical restraints necessary
to gain control of a detainee who appears to be dangerous may be employed when the detainee:
Components

Yes

No

NA

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

Remarks

Staff:

•

Does not use force as punishment.
Attempts to gain the detainee's voluntary
cooperation before resorting to force
• Uses only as much force as necessary to
control the detainee.
• Uses restraints only when other nonconfrontationa I means, including verbal
persuasion, have failed or are impractical.
Medication may only be used for restraint purposes
when authorized by the Medical Authority as medically
necessary.
SPCs and CDFs use INS-authorized restraint
equipment.
Use-of-Force Team follow written procedures that
attempt to prevent injury and exposure to communicable
disease(s).
In SPCs and CDFs the OIC contacts higher command
before restraining a detainee beyond eight hours.
Standard procedures associated with using four-point
restraints include:
• Soft restraints (e.g., vinyl)
• Dressing the detainee appropriately for the
temperature.
A bed, mattress, and blanket/sheet.
Checking the detainee at least every 15
minutes.
• Logging each check.
• Turning the bed-restrained detainee often
enough to prevent soreness or stiffness.
• Medical evaluation of the restrained
detainee twice per eight-hour shift.
• When qualified medical staff is not
immediately available, staff positions the
detainee "face-up".
The shift supervisor monitors the detainee's
position/condition every two hours.
• He/she allows the detainee to use the rest
room at these times under safeguards.
All detainee checks are logged.
In immediate-use-of-force situations, staff contacts
medical staff once the detainee is under control.
When the OIC authorizes use of non-lethal weapons:
• Medical staff is consulted before staff use
pepper spray/non-lethal weapons.
Medical
staff reviews the detainee's medical
•
file before use of a non-lethal weapon is
authorized.

•

•
•

(

~

D

0

~

D

0

~

D
D

D
D

~

0

~

D

See remarks.
Policy & SOP exist for the
use of soft restraints but
staff states that they are
not used in ECC
anymore. Staff could not
identify where such
equipment was even
located in the facility.
Policy was appropriate
but apperantly not
applicable as ECC no
longer used this type of
restraint.

No spray is used in the
facility. lEA's carry
colapsable steele batons
& do not require medical
review prior to use.

USE OF FORCE

(

Policy: The U.S. Imm igration & Naturalization Service authorizes the use of force only as a last alternative after
all other reasonable efforts to resolve a situation have failed. Only that amount of force necessary to gain
control of the detainee, to protect and ensure the safety of detainees, staff and others, to prevent serious
property damage and to ensure institution security and goOd order may be used. Physical restraints necessary
to gain control of a detainee who appears to be dangerous may be employed when the detainee:
Components
Special precautions are taken when restraining pregnant
detainees.
Medical personnel are consulted
Protective gear is worn when restraining detainees with
open cuts or wounds.
Staff documents every use of force and/or non-routine
application of restraints.
It standard practice to review any use of force and the
non-routine application of restraints.
In spes and GDFs After-Action Review Teams rev-iew
the videotape for the following:
• Professionalism
• Use of Force Team's protective gear
• Appropriate/excessive use of force
Proper application of restraints
Time
needed to restrain the detainee
•
Removal
of protective gear before entering
•
the cell or area
• Prompt medical examination of the detainee
after the move
• Proper use of chemical agents or pepper
mace
• Opportunity for detainee to submit
voluntarily to the placing of restraints before
the team enters the cell
Derogatory, demeaning, taunting, or other
inappropriate language between team
members and the detainee. or between
team members and individuals outside the
cellar area
In spes and CDFs the After-Action ReviewReport is
completed within two working days of the detainee's
release from restraints.
If the reviewers decide the matter requires further
investigation, the Office of Internal Affairs, the Office of
the Inspector General, and/or the FBI are notified.
All officers receive training in self-defense,
confrontation-avoidance techniques and the use of force
to control detainees.
Specialized training is given Officers are
certified in all devices they use.
The officers are thoroughly trained in the use of soft and
hard restraints.
In spes is the Use of Force form is used.
In other facilities this form or its equivalent
is used.

•

Yes

No

NA

0

0

rzJ

[8]

0

0

[8]

0

0

[8]

0

0

No females at EGG.

Policy is appropriate but
staff and the ole state
that no significant
incidents have been
video'd for several years.
Unable to confirm the
SOP is being followed as
there is no incidents to
compare to.

•

(

rzJ

D

0

rzJ

D

0

rzJ

0

0

rzJ

0

D

rzJ

D

D

[8]

D

0

•

•

•

(

Remarks

(

Verification Sources:
SOURCE
Facility policy and procedure for Use of
Force
Use of Force log and forms
Observation of Use of Force (actual or
simulated)
Detainee and staff interviews

IZI Acceptable 0

TIME
11:30

07/28

DATE

LOCATION
ECC Admin Trailer

11:30

07/28

Unable to locate Use of Force lo~_.
Not Available

11:30

07/28

ECC Admin Trailer

Standard Rating:
Deficient 0 Repeat Deficiency

0

At·Risk

*Remarks: (Record significant facts, observations, other sources used, etc.)
If behavior cannot be controlled after 8 hours of being restrained then the OIC would seek assistance from the
medical unit to seek placement in another more appropriate facility.

b6, b7C

(

-C)r

(

•

STAFF DETAINEE COMMUNICATIONS
Policy: Procedures must be in place to allow for formal and informal contact between key facility staff
and ICE staff and ICE detainee and to permit detainees to make written requests to ICE staff and receive
an answer in an acceptable time frame.
Components
The ICE Field Office Director ensures that weekly
announced and unannounced visits occur at the IGSA.
Detention and Deportation Staff conduct scheduled
weekly visits with detainees held in the IGSA.
Scheduled visits are ~osted in ICE detainee areas.
Visiting staff observe and note current climate and
conditions of confinement at each IGSA.
ICE information request Forms are available at the
IGSA for use by ICE detainees.
The IGSA treats detainee correspondence to ICE staff
as Special Correspondence.
ICE staff respond to a detainee request from an IGSA
within 72 hours.
ICE detainees are notified ion writing upon admission to
the facility of their right to correspond with ICE staff
regarding their case or conditions of confinement.

Yes

No

NA

~

0

0

~

0
[J

~

0
0
0

0

0

~

~

0

0

0

0

~

0

~

0

~

Remarks

DO's witnessed speaking
to detainees on 07/27104.

0
Not an IGSA facility.

Not an IGSA facility.
Standard is explained on
orientation video but is
not provided in writing.

Staff Detainee Communications - Rating

(

When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into compliance.
For each element found out of compliance, the plan of action will specify remedial action and the estimated
timetable for compliance.
Standard Rating:
~ Acceptable

o Deficient

OAt-Risk

o Repeat Finding

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

b6, b7C

Auditor's Signature 1 Date

7- 2 .7'"-<)"

u.s. Department of Homeland Security
U.S. Immigration and Customs Enforcement

HQDRO 50/10.8
Office ofthe Director

425 I Street NW
Washington, DC 20536

MEMORANDUMFOR

b6, b7C

OFFICER-IN-CHARGE
CESSING CENTER
FROM:

SUBJECT:

(

b6, b7C

Detention Review Notification

The Headquarters Office of Detention and Removal intends to perform a review of your
facility on January 27. This review will be performed under the supervision of Headquarters
staff. The review is expected to conclude on or about January 29. The Review Team will
conduct a complete closeout and share the preliminary findings ot the review at that time.
In preparation for this inspection, you are requested to provide working space for the review
team. ·Additionally, a master copy of the facility's Policies and Procedures, Post Orders, and
Emergency Plans should be available to the review team during the review. The Reviewer-inCharge (RIC) may request additional materials during or prior to the scheduled review.
The designated RIC for your review is
. Should your staff have any questions
b6, b7C
regarding this review, please have them contac
, Deputy Assistant
b6, b7C
Director, Detention Management Division, at (202) 616 b2 high

CC:

Ronald J. Smith, Acting Field Director, San Diego
El Centro Service Processing Center
Deputy Assistant Director, Field Operations Division

CC:
b2High, (b)(6), (b)(7)c

(

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

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

_.s.

Department of Homelaod Security
425 I St. NW
W lIshington, D.C. 20536

U.s. Immigration

and Customs
Enforcement

Int~roffice

MelTIOrandum

To: Anthony S. Tangeman, Director, Detention and Removal Operations
b6, b7C

Fr

b6, b7C

er-In-Charge, HQDROIDODIFMTB

Date: February 5, 2004
Re: EI Centro Service Processing Center Review Summary Report

(

The Detention Operations Division (DOD) performed a review of the El Centro Service
nter (SPC) on January 27-29. This review was performed under the supervision of
b6, b7C
, Reviewer-In-Charge (RIC) with team members,
t
and
b6, b7C
b6, b7C
b6, b7C
The San Diego Field Office last performed a self-assessment of the facility on
November 19,2003.

Type of Review:
This review is a scheduled Headquarters Review and was conducted to determine overall
compliance with the ICE Detention standards.

Review Summary:
The El Centro SPC is not accredited by the American Correctional Association (ACA). The
facility is accredited by the National Commission on Correctional Health Care and the Joint
Accreditation Commission for Healthcare.
The following information summarizes those standards not in compliance. Each standard is
identified and a short summary provided regarding standards or procedures not currently in
compliance.

(
www.ice.gov

(

Memorandum for Anthony S. Tangeman
Subject: El Centro Service Processing Center Review Summary Report

Page 2

•

2004 Review

2003 Review

Acceptable - 33

Compliant -

31

2
Deficient Repeat Deficiency - 2
0
At-Risk -

Deficient Repeat Deficiency At-RiskNot Applicable -

4
O

1

0

Classification - Repeat Deficiencv:
•
•
•

The facility does not conduct reclassification reassessments between 45 and 60 days after
arrival and subsequent reassessments every 60 to 90 days.
The detainee handbook does not address the different levels of classification.
The facility does not classify all detainees based on information received at intake.
Classification has been a repeat deficiency at the facility for the past three years.
Many detainees were not reclassified within 90 days as required. Detainees received
at the facility with little or no documentation are automatically classified as Level 2.
The facility has not trained employees to request the appropriate information to
properly classify detainees.

(

Hold Rooms - Repeat Deficieney:
•
•
•

Bunk beds are located in the Holding Rooms.
Detainees are held in Hold Rooms for more than 12 hours.
There is not a written evacuation plan that addresses removing detainees from Hold Rooms
in case of fire and/or building evacuation.
Hold Rooms have been a repeat deficiency at the facility for the past two years. The
processing area Hold Room logs document that detainees are being held past
the permitted 12 hours. The auditors were told the reason for the delay was due to the
fact that the x-ray machine was broken. It was later verified that the x-ray machine
was only inoperable from 1125 - 1/27. A further log review documented that holding
detainees over 12 hours is a common practice at the facility. The average time
detainees were kept in the Hold Rooms were between 14 -16 hours.
Several detainees had remained in the Hold Room for approximately 24 hours.
Detainees from general population awaiting court appearances are placed with
detainees who have not been medically screened.

(

1\,

Memorandum for Anthony S. Tangeman
.
Subject: EI Centro Service Processing Center Review Summary Report

Page 3

(
Securitv Inspections - Deficient:
•
•

The front entrance officer does not check the ID of everyone entering or exiting the facility
(employee or visitor).
The facility does not maintain a log of all incoming and departing vehicles to sensitive areas
of the facility.
Entrance officers at the facility did not request government issued photo ID from
employees. The AKAL officer post orders mandate that the officers physically check
the ill of every employee and visitor entering the facility. This practice was observed
to be violated on several occasions during the three-day inspection. An officer was
observed permitting a visitor to enter the facility prior to checking her ID. Names of
various individuals were incorrect in the logbook. Bags and briefcases are not
properly searched when entering the facility. The x-ray machine is out of order and a
maintenance request could not be located.

StaffDetainee Communications - Deficient:
•

(

•

Detention and Deportation Staff do not conduct scheduled weekly visits with detainees
held in the SPC.
ICE information request forms are not available at the SPC for use by ICE detainees.
Detainees and staff both reported that this standard is deficient. Recently, the
Supervisory Deportation Officer has created a new visitation list that is posted in all
detainee living areas. The schedule began in January and iffollowed., will provide
detainees weekly access to Deportation Officers. The staftldetainee communication
should be documented and request forms filed to ensure follow-up.

RIC Issues and Concerns:
•

Infection Control: (At-Risk)
Detainees who have completed their tuberculosis (TB) test and have been cleared are being
placed in holding cells with new arrivals that have not been TB screened. This high-risk
practice places detainees in an environment where prolonged close contact with non-TB
screened persons could lead to a potential, unnecessary exposure and spread of the disease.

•

Key and Lock Control: (Advisory)
Two padlocks were discovered on one of two doors on the detainee holding cell, which
would prevent detainees from immediately exiting in the event of a fire. The National
Detention Standards mandate that padlocks andlor chains are not to be used on cell doors.

(

e

Page 4

Memorandum for Anthony S. Tangeman

(

Subject: EI Centro Service Processing Center Review Summary Report

,

RIC Issues and Concerns: (Continued)

•

Collapsible Steel Batons: (Advisory)
Collapsible steel batons are carried by officers inside the facility. Officer-In-Charge (OIC)
cited a memo from the San Diego District Director in 1999 permitting this
b6, b7C
practice. However, the memo presented did not address this issue. OIC b6, b7C
stated
that the collapsible steel batons were needed for the safety of his officers and he would not
remove them from the facility unless ordered to do so. Officers continued to carry batons
inside the facility on the third and final day ofthe review.

•

American Correctional Association (ACA) Accreditation:
Approximately 25 ACA files were reviewed to ensure compliance. All files lacked required
index forms, policy highlights, appropriate secondary documentation or contained excessive
paperwork not related to the standard. This officer reviewed each file with Accreditation
Manger b6, b7C
to discuss w'hat specific documentation was required. The facility had
originally planned to schedule their accreditation audit for March or April, which is
extremely premature. The Accreditation Department currently lacks direction. The OIC and
this officer discussed sending two identified employees to the Florence Processing Center for
file training.

(
•

Construction:
The processing area of the facility is currently under construction. The estimated completion
date is scheduled for February. Four of the facility pods (Limo, Kilo, Nancy and Mike) are
in great need of paint to improve the quality of life for detainees. There are no major
renovation projects scheduled for the El Centro SPC.

RIC OBSERVATIONS:
•

Best Practice - Mental Health: All detainees housed at the facility are offered various
mental health programs, which include individual and group counseling. Specific treatment
plans are created and detainees are placed in either anger management or adjustment disorder
groups. The involved staff continue to monitor the detainees' progress and make appropriate
adjustments when necessary.

•

Overall Cleanliness of the Facility: The overall sanitation of the facility was good.
Detainees were continuously observed cleaning throughout the review. The food service
equipment was found to be dirty, but this deficiency was immediately corrected when
reported to the OIC.

(

Page 5

Memorandum for Anthony S. Tangeman
Subject: El Centro Service Processing Center Review Summary Report

•

Staff Interaction: OIC b6, b7C n and his staff were extremely professional and helpful
during the review. Information requested was immediately provided. Employees were
knowledgeable and well versed regarding their post orders and appeared comfortable within
their positions.

Recommended Rating and Justification:

It is the RIC recommendation that the facility receive a rating of "Deficient". The EI Centro SPC
has continued for numerous years to remain deficient in critical areas, which affect the quality of life
for detainees. The facility did not attempt to correct the identified problems in those areas even
when documented in the past two reviews. The facility now fully complies with 33-of-37 standards.
The RIC recommends that the Field Office review standards found to be deficient within 90 days
after receipt and concurrence of the El Centro SPC plans of action. It is also recommended that the
accreditation process be put on hold until the above deficiencies and files can be corrected.
RIC Assurance Statement:

(

It is the opinion of this RIC that the findings of compliance and non-compliance are documented on
the G-324a inspection form and that it is supported by documentation in the review file.

Deputy Assistant Director, Field Operations Division
CC: Official File
b2High, (b)(6), (b)(7)c

t

(

(

LADQUARTERS EXECUTIVE REVIEW

The signature below constitutes review of this report and acceptance by the Review Authority. OIC/CEO will bave
receipt of this report to respond to all findings and recommendations.

II1II from

HQDRO EXECUTIVE REVIEW: (Please Print Name)
(b)(6), (b)(7)c

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

Da

Director

Final Rating:

0

Superior

o Good
o Acceptable

[gI Deficient
OAt-Risk
Comments:

(

It is the RIC recommendation that the facility receive a rating of "Deficient". The EI Centro Service
Processing Center has continued for numerous years to remain deficient in critical areas, which affect
the quality of life for detainees. The facility did not attempt to correct the identified problems in those
areas even when documented in the past two reviews. The facility now fully complies with 33-of-37
standards.

Form G-324A (Rev. 8/1101) No Prior Version May Be Used After 12/31101

-Detention Facility Review Fonn

U.S. Department Of Homeland seCUrityU.S. Immigration and Customs Enfo~cement
(

Facilities Used Over 72 hours

,gJ=---I-C-E-S-e-rv-j-ce-P-ro-c-e-ss-i-n-g-C-e-n-t-er-----------,

o

o
o

PreviousIMost Recent Review
Date[s] of Last Review
January 28-30, 2003
Previous Rating
Superior 0 Good ~ Acceptable

o

o

0

Deficient D At-Risk

Name and Location of Facilitv

Name
EI Centro Service Pro(eS$inl! Center
Address (Street and Name)
1115 North Imperial Avenue
City, State and Zip Code
EI Centro, CA 92243
County
Imperial
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
OfIicer-ln-Chaf2e
b6, b7C
Telephon
de)
(760) 353
b6, b7C
)istrict
JBnDiego
Distance from District Office
120 miles

(

JCAHO: ~
Date: 3/2003

Problems I Complaints (Copies must be attached)
F.
The Facility is under Court Order or Class Action Finding
D Court Order
0 Class Action Order
The Facility has Significant Litigation Pending
Major Litigation
Life/Safetv Issues
Checked Box above requires a detailed written memorandum.

A. Current Inspection
Type of Review
Field Office ~ HQ Review
Date[s] of Review
January 27-29, 2004

B.

NCCHC: ~
Date: 1/2003

ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

C. ICE Information
Name of Reviewer (Last Name, Title and Duty Station)
b6, b7C / Detention and Deportation Officer / Washington DC
Last Name I Title of Team Members (Reviewers)
b6, b7C / PHSIPHO; b6, b7C IEAlDallas; b6, b7C / DO/Wash
Controlling Field Office
San Diego
Nearest Field or Sub-Office
San Diego (Approximately 120 miles)

D

G FaClltv
T H'IstOrv
Date Built
1975
Date Last Remodeled or Upgraded
Ongoing
Date New Construction / Bedspace Added
None
Future Construction Planned
~Yes ONo Date:
Current Bedspace
Future Bedspace
416
544

I

H. Total Facility Population
Total Intake for previous 12 months
7,357
Total Mandays for Previous 12 months
11.86
Classification Level (ICE SPCs and CDFs Only)
L-l
L-2
L-3
I AdultMale
230
134
43
I Adult Female
0
0
0

I.

Facility Ca Ilacity
Rated
I AdultMale
544
I Adult Female
0

Operational
450
0

Emer2ency
560
0

Average Daily Population

ICE
Adult Male

D. CDFIIGSA Information Only
Contract Number
Date of Contract or IGSA

I

Basic Rates per Man-Day
Adult Female

450
(2003)
415-420
January
2004
0

USMS

Other

0

0

0

0

Other Charges: (lfNone, Indicate N/A)

,

,

,

Estimated Man-days Per Year

Staffing Level
:
(b)(2)High

I

(b)(2)High

E.
Accreditation Certificates
Accredited By:

(
Form G-324A (Rev. 9/25/03) No Prior Version May Be Used After 12131/03

(.
Significant Incident Summary Worksheet
,llr ICE to complete its Review of your facility, the following information must be completed prior to the scheduled review dates.
The information on this form should contain data for the past twelve months in the boxes provided. The information on this form is
used in conjunction with the ICE Detention Standards in assessing your Detention Operations against the needs of the ICE and its
detained population. This form should be filled out by the facility prior to the start of any inspection.

o
Assault:
Offenders on
Offenders!

o

o

o

o

o

o

o

o
Assault:
Detainee on

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

Staff

Number of Forced Moves, incl.
Forced Cell moves 3

# Times FourlFive Point
~traints

applied/used

Offender / Detainee Medical
Referrals as a result of injuries
sustained.

o

o

o

3

2

o

Escapes

o

o

o
21

Grievances:

14

o

Deaths

Psychiatric / Medical Referrals

# Medical Cases referred for

o

o

o

o

o

31

32

27

43

0

o

3

Outside Care

# Psychiatric Cases referred for
Outside Care

4

(

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

Form G-324A (Rev. 9125/03) No Prior Version May Be Used After 12131/03

5.
6.
7.
8.
9.
10.
II.
12.
13.
14.
15.

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

23.
24.
25.
26.
27.
28.
29.
30.
3 I.
32.
33.
34.
35.
36.
37.
38.
39.

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

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

(
Form G-324A (Rev. 9/25103) No Prior Version May Be Used After 12/31103

1&2

RIC Review Assurance Statement

By signing below, the Reviewer-In-Charge (RIC) certifies that all findings of noncompliance with policy or inadequate controls
contained in the Review Report are supported by evidence that is sufficient and reliable. Furthermore, fmdings of noteworthy
accomplishments are supported by sufficient and reliable evidence. Within the scope of the review, the facility is operating in
accordance with applicable law and policy, and property and resources are efficiently used and adequately safeguarded, except for the
deficiencies noted in the report.
Reviewer-In-Charge: (Print Name)
b6, b7C

b6, b7C

Tille & Duty Location

Detention and De ortation Officerl Washin

n DC

Print Name & Duty Location
b6, b7C

Print Name & Duty Location

, Phoenix, AZ

b6, b7C

Print Name & Duty Location
b6, b7C

Dallas, Texas

(rtIC Rating Recommendation:
\,

Washington, DC

Print Name & Duty Location

o Superior
o Good
o Acceptable

IZ1 Deficient
OAt-Risk

RIC Comments: It is the Reviewer-In-Charge recommendation that the facility receive a rating of "Deficient". The EI Centro
Service Processing Center has continued for numerous years to remain deficient in critical areas, which
effect the quality of life for detainees. The facility did not attempt to correct the identified problems in
those areas even when documeneted in the past two reviews. The facility now fully complies with
33-of-37 standards. The RIC recomends that the Field Office review standards found to be deficient
within 90 days after receipt and concurrence of the EI Centro Service Processing Center plans of action.
It is also recommended that the accrediation process be put on hold until the above deficiencies and
files can be corrected.

Form G-324A (Rev. 9/25/03) No Prior Version May Be Used After 12/31/03

 

 

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