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

Office of Detention Oversight
Compliance Inspection
Enforcement and Removal Operations
ERO San Diego Field Office
Imperial Regional Detention Facility
Calexico, CA

December 8–10, 2015

COMPLIANCE INSPECTION
for the
IMPERIAL REGIONAL DETENTION FACILITY
Calexico, California
TABLE OF CONTENTS

EXECUTIVE SUMMARY
Overall Findings .......................................................................................................................2
Findings by Performance-Based National Detention Standards (PBNDS) 2011 Major
Categories .................................................................................................................................3
INSPECTION PROCESS .............................................................................................................4
DETAINEE RELATIONS ............................................................................................................5
INSPECTION FINDINGS
SECURITY
Staff-Detainee Communication ................................................................................................8
Use of Force and Restraints......................................................................................................8
CARE
Food Service .............................................................................................................................8
ACTIVITIES
Telephone Access .....................................................................................................................9
JUSTICE
Grievance System .....................................................................................................................9

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INSPECTION TEAM MEMBERS

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

Office of Detention Oversight
December 2015
OPR 201601062

Lead Inspections and Compliance Specialist
Inspections and Compliance Specialist
Inspections and Compliance Specialist
Contractor
Contractor
Contractor
Contractor
1

ODO
ODO
ODO
Creative Corrections
Creative Corrections
Creative Corrections
Creative Corrections

Imperial Regional Detention Facility
ERO San Diego

EXECUTIVE SUMMARY
The Office of Detention Oversight (ODO) conducted a compliance inspection of the Imperial
Regional Detention Facility (IRDF), in Calexico, California, from December 8 to 10, 2015.1 IRDF
opened in 2014 and is owned by the City of Holtville, CA and operated by the Management and
Training Corporation (MTC). The Office of Enforcement and Removal Operations (ERO) began
housing detainees at IRDF in 2014 pursuant to a Dedicated Inter-governmental Service Agreement
under the oversight of ERO’s Field Office Director (FOD) in San Diego, CA.
ERO staff members are assigned to
Quantity
the facility. A Detention Services Capacity and Population Statistics
Manager provides full-time coverage ICE Detainee Bed Capacity2
704
at the facility.
A Warden is Average ICE Detainee Population3
690
responsible for oversight of daily
Male Detainee Population (as of 12/09/2015)
615
facility operations and is supported
64
by (b)(7)epersonnel. MTC provides Female Detainee Population (as of 12/09/2015)
medical and food services. The facility holds no accreditations at the time of inspection.

OVERALL FINDINGS
This is ODO’s first inspection of the IRDF under the
Performance-Based National Detention Standards
(PBNDS) 2011. ODO reviewed the facility’s
compliance with 16 standards and found the facility
compliant with 12 standards. ODO found five
deficiencies in the remaining four standards. ODO
identified five opportunities where the facility
initiated corrective action during the course of the
inspection.4 Finally, ODO found two deficiencies in
two standards which are priority components.

Inspection Results

FY2016
(PBNDS 2011)

Standards Reviewed

16

Deficient Standards
Overall Number of
Deficiencies

4

Corrective Actions Initiated

5

Best Practice
Deficient Priority
Components

0

5

2

1

Male and female detainees with low, medium and high security classification levels are detained at the facility for
longer than 72 hours.
2
Data Source: ERO Facility List Report as of December 8, 2015.
3
Ibid.
4
Corrective actions, where immediately implemented, best practices and ODO recommendations, as applicable,
have been identified in the Inspection Findings section and annotated with a “C”, “BP” or “R”, respectively.

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FINDINGS BY PBNDS 2011 MAJOR CATEGORIES
PBNDS 2011 STANDARDS INSPECTED5

DEFICIENCIES

Part 1 - Safety
1.2 - Environmental Health and Safety
Sub-Total

0
0

Part 2 - Security
2.1 - Admission and Release
2.2 - Custody Classification System
2.5 - Funds and Personal Property
2.11 - Sexual Abuse and Assault Prevention and Intervention
2.12 - Special Management Units
2.13 - Staff-Detainee Communication
2.15 - Use of Force and Restraints
Sub-Total

0
0
0
0
0
1
0
1

Part 4 - Care
4.1 - Food Service
4.3 - Medical Care
4.4 - Medical Care (Women)
4.6 - Significant Self-Harm and Suicide Prevention and Intervention
Sub-Total

2
0
0
0
2

Part 5 - Activities
5.6 - Telephone Access
Sub-Total

1
1

Part 6 - Justice
6.1 - Detainee Handbook
6.2 - Grievance System
6.3 - Law Libraries and Legal Materials
Sub-Total

0
1
0
1

Total Deficiencies

5

5

For greater detail on ODO’s findings, see the Inspection Findings section of this report.

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INSPECTION PROCESS
Every fiscal year, the Office of Detention Oversight (ODO), a unit within U.S. Immigration and
Customs Enforcement’s (ICE) Office of Professional Responsibility (OPR), conducts compliance
inspections at detention facilities in which detainees are accommodated for periods in excess of 72
hours and with an average daily population greater than ten to determine compliance with the ICE
National Detention Standards (NDS) 2000, or the Performance-Based National Detention
Standards (PBNDS) 2008 or 2011, as applicable.
During the compliance inspection, ODO reviews each facility’s compliance with those detention
standards that directly affect detainee health, safety, and/or well-being.6 Any violation of written
policy specifically linked to ICE detention standards, ICE policies, or operational procedures that
ODO identifies is noted as a deficiency. ODO also highlights any deficiencies found involving
those standards that ICE has designated under either the PBNDS 2008 or 2011, to be “priority
components.”7 Priority components have been selected from across a range of detention standards
based on critical importance, given their impact on facility security and/or the health and safety,
legal rights, and quality of life of detainees in ICE custody.
Immediately following an inspection, ODO hosts a closeout briefing in person with both facility
and ERO field office management to discuss their preliminary findings, which are summarized
and provided to ERO in a preliminary findings report. Thereafter, ODO provides ERO with a final
compliance inspection report to: (i) assist ERO in working with the facility to develop a corrective
action plan to resolve identified deficiencies; and (ii) provide senior ICE and ERO leadership with
an independent assessment of the overall state of ICE detention facilities. The reports enable senior
agency leadership to make decisions on the most appropriate actions for individual detention
facilities nationwide.

6
7

ODO reviews the facility’s compliance with selected standards in their entirety.
Priority components have not been identified for the NDS.

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DETAINEE RELATIONS
ODO interviewed 32 detainees, each of whom volunteered to participate. None of the detainees
made allegations of mistreatment or discrimination. The majority of detainees reported being
satisfied with facility services, with the exception of the complaints below:


Admission and Release:
Allegation: One detainee alleged during intake she was provided used undergarments.
Action Taken: Facility staff notified ODO that all undergarments issued to detainees are new.
The undergarments issued were from different distributors and slightly varied in color. ODO
observed the issuance of new undergarments to detainees during the admission process.



Grievance System:
Allegation: Four detainees alleged a staff officer was rude and verbally abusive towards
detainees.
Action Taken: ODO verified there were grievances filed against the officer and facility
management and ERO staff was informed of the grievances. The allegations were investigated
and substantiated by facility management. The officer was counseled, received refresher
training, and the incident was documented in the employee’s performance file.



Food Service:
Allegation: Two detainees alleged the milk being served had passed the expiration date for
use.
Action Taken: Food services notified ODO that expired milk is not served to detainees.
During the lunch meal, ODO did not observe any expired milk on the food line or in storage
containers.



Staff-Detainee Communication:
Allegation: One detainee alleged she submitted several requests and has not received a reply
from ERO regarding her case.
Action Taken: ODO reviewed the ICE detainee request log and verified requests are not
answered within three days. This was cited as a deficiency under the staff-detainee
communication standard.
Allegation: One detainee alleged his court date kept getting extended every three months.
Action Taken: ODO was informed by ERO regarding the detainee’s court date that the
Pakistani consulate was expecting the imminent delivery of legal documents to return the
detainee to Pakistan. ERO informed the detainee of this information.



Religious Practices:
Allegation: A detainee alleged there were no religious services provided in English.
Action Taken: The facility chaplain notified ODO that religious services are provided in
English. In addition, the facility provided the detainee with the English version of the schedule.

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

Medical Care:
Allegation: Two detainees alleged it takes two to three days to receive medical care after
submitting a sick call request.
Action Taken: ODO notified medical services and was informed sick call requests are triaged
within 24 hours and appointments are scheduled according to clinical judgment.
Allegation: One detainee alleged she was allergic to beef and beans and was placed on a
special diet; however, she subsequently stopped receiving the special diet.
Action Taken: ODO notified medical services and was informed the detainee did not have a
food allergy since she described experiencing symptoms of heartburn when she ate beef and
beans; consequently, she was removed from the special diet.
Allegation: Four detainees alleged they were lactose intolerant and medical services would
not provide prescriptions for lactose free milk.
Action Taken: ODO was informed by medical services the four detainees were not lactose
intolerant.
Allegation: One detainee broke his tooth two weeks prior to ODO’s arrival and alleged that
he received no treatment and no pain medication.
Action Taken: ODO reviewed the detainee’s medical record regarding his chipped tooth and
found he was scheduled to see the dentist within three days of ODO’s review and there was no
complaint for pain.
Allegation: One detainee complained of having chest pain two months before ODO arrived.
The detainee alleged he did not receive medication and said the doctor told him it would go
away in three days. Additionally, the detainee is worried about a lump below his left breast.
Action Taken: ODO reviewed the medical record for the detainee with chest pains and the
lump below the left breast. He was seen by medical services and prescribed Motrin for the
chest pain. The detainee had been evaluated by a doctor the previous week and was told that
the lump was a benign lymph node, and the doctor would follow up in three weeks.
Allegation: One detainee alleged nothing was being done to clean his teeth and braces or adjust
his braces so they wouldn’t rub his gums. He alleged he was not getting proper care.
Action Taken: ODO reviewed the detainee’s medical record and found he had received the
following treatment:
 12/30/2014 his teeth were cleaned; according to the Health Services Administrator the
wires on his braces were trimmed;
 3/17/2015 his teeth were x-rayed;
 3/18/2015 he received antibiotic therapy;
 9/3/2015 he received a second cleaning;
 9/28/2015 medical recommended a tooth extraction—he refused;
 He refused to take antibiotics and pain medications;
 10/27/2015 Annual visit—he refused cleaning or treatment and he refused antibiotics and
pain medication.

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Allegation: One detainee was despondent over his medical condition alleging he had a bulge
protruding from his side. He thought it was a hernia and that he needed an operation.
Action Taken: ODO reviewed the medical record for the detainee and found he had an
ultrasound scheduled in three weeks for evaluation. This information was provided to the
detainee by medical services.
Allegation: One detainee received a prescription for anti-fungus medication and wanted a
refill.
Action Taken: The detainee was instructed by ERO to follow the facility policy and procedure
regarding the refill of medications. These instructions are noted on the medical cart and are
posted in the housing units, both in English and Spanish.

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INSPECTION FINDINGS
SECURITY
STAFF-DETAINEE COMMUNICATION (SDC)
ERO is not responding to received detainee requests within 3 business days (Deficiency SDC-18).
Corrective Action:
ERO initiated corrective action by sending an email to the
Deportation Officers (DO) assigned reiterating the need to respond to all detainee
requests within 3 business days (C-1).

CARE
FOOD SERVICE (FS)
The facility does not check food service line temperatures for all menu items (Deficiency FS-19).
Corrective Action:
The facility initiated corrective action by implementing procedures
and creating forms to record temperatures of all hot and cold menu items (C-2).
The facility could not provide estimated quarterly cost for common fare menu (Deficiency FS210).
Corrective Action:
The facility initiated corrective action by creating a record keeping
system to track costs associated with the common fare menu program (C-3).

“In facilities with ICE/ERO onsite presence the ICE/ERO staff member receiving the request shall normally
respond in person or in writing as soon as possible and practicable, but no later than within three (3) business days
of receipt.” See ICE PBNDS 2011, Standard 2.13, Staff-Detainee Communication, Section (V)(B)(1)(a).
9
“Sanitary guidelines are observed, with hot foods maintained at a temperature of at least 140 F degrees (120 F
degrees in food trays) and foods that require refrigeration maintained at 41 F degrees or below.” See ICE PBNDS
2011, Standard 4.1, Food Service, Section (V)(D)(2)(a)(3). This is a priority component.
10
“The Food Service Administrator (FSA) shall estimate quarterly costs for the common fare program and include
this figure in the quarterly budget. The FSA shall maintain a record of the actual costs of both edible and non-edible
items.” See ICE PBNDS 2011, Standard 4.1, Food Service, Section (V)(G)(14).
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December 2015
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Imperial Regional Detention Facility
ERO San Diego

ACTIVITIES
TELEPHONE ACCESS (TA)
The facility staff does not report telephone outages to the repair service (Deficiency TA-111).
Corrective Action:
The facility initiated corrective action by submitting a telephone
outage report to Talton Communications, the telephone service provider for the facility (C4).

JUSTICE
GRIEVANCE SYSTEM (GS)
ODO reviewed 589 grievances from January 2015 to November 2015 and found 230 grievances
alleging staff misconduct that were not submitted to ICE’s Office of Professional Responsibility
(OPR) Joint Intake Center and/or to the local OPR office for appropriate action (Deficiency GS112).
Corrective Action:
ERO initiated corrective action by sending the 230 grievances
alleging staff misconduct to the OPR Resident Agent in Charge (C-5).

“Designated facility staff shall inspect the telephones daily, promptly report out-of-order telephones to the repair
service so that required repairs are completed quickly.” See ICE PBNDS 2011, Standard 5.6, Telephone Access,
Section (V)(A)(3).
12
“While such grievances are to be processed through the facility’s established grievance system, CDFs and IGSA
facilities must also forward a copy of any grievances alleging staff misconduct to ICE/ERO in a timely manner with
a copy going to ICE’s Office of Professional Responsibility (OPR) Joint Intake Center and/or local OPR office for
appropriate action.” See ICE PBNDS 2011, Standard 6.2, Grievance System, Section (V)(F). This is a priority
component.
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Imperial Regional Detention Facility
ERO San Diego