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

Office of Detention Oversight
Compliance Inspection
Enforcement and Removal Operations
Chicago Field Office
Morgan County Adult Detention Center
Versailles, Missouri

November 1 - 3, 2011

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

COMPLIANCE INSPECTION
MORGAN COUNTY ADULT DETENTION CENTER
CHICAGO FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...............................................................................................1
INSPECTION PROCESS
Report Organization .................................................................................................3
Inspection Team Members .......................................................................................3
OPERATIONAL ENVIRONMENT
Internal Relations .....................................................................................................4
Detainee Relations ...................................................................................................4
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................5
Access to Legal Material .........................................................................................6
Detainee Classification System................................................................................7
Detainee Handbook ..................................................................................................8
Environmental Health and Safety ............................................................................9
Food Service ..........................................................................................................13
Funds and Personal Property .................................................................................14
Staff-Detainee Communication .............................................................................15
Suicide Prevention and Intervention ......................................................................16

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO)
conducted a Compliance Inspection (CI) of the Morgan County Adult Detention Center
(MCADC) in Versailles, Missouri, from November 1 to 3, 2011. Morgan County owns and
operates MCADC. Since July 2003, MCADC has accommodated male and female ICE
detainees of all classification levels for periods in excess of 72 hours, under an
intergovernmental service agreement (IGSA). Advance Corrections Healthcare (ACH) provides
medical care. All meal preparation is performed by Morgan County employees. The facility
holds no accreditations.
The Enforcement and Removal Operations (ERO), Field Office Director in Chicago, Illinois
(FOD/Chicago) is responsible for ensuring facility compliance with ICE policies and the
National Detention Standards (NDS). ERO personnel are not physically located at MCADC.
The total number of staff (non-ICE) employed at MCADC is 48. The Morgan County Sheriff is
the highest ranking official at MCADC, and is responsible for oversight of daily operations at the
facility. In addition to the Sheriff, supervisory staff at MCADC includes one Chief Deputy and
one Sergeant. Non-supervisory staff includes 30 Corrections Officers and 4 civilian employees.
Twenty-four contracted medical staff includes a Health Services Administrator (HSA), a medical
doctor, a psychiatrist, a nurse practitioner, two subcontracted dentists, three medical assistants,
six licensed practical nurses, and nine registered nurses. The total inmate capacity at MCADC is
139. At the time of the inspection, the facility housed 56 ICE detainees (51 males and 5
females), ranging in age from 18 to 45 years old. The average length of stay is 22 days.
In February 2011, ERO Detention Standards Compliance Unit contractor, MGT of America,
Inc., conducted an annual review of the ICE NDS at MCADC. The facility received an overall
rating of “Acceptable’’ and was found to be in compliance with all 38 standards reviewed.
During this CI, ODO reviewed 13 NDS and found a total of 19 deficiencies in the following 8
standards: Access to Legal Material (2 deficiencies), Detainee Classification System (1),
Detainee Handbook (1), Environmental Health and Safety (9), Food Service (1), Funds and
Personal Property (3), Staff-Detainee Communication (1), and Suicide Prevention and
Intervention (1). Overall, ODO found MCADC to be well-managed and in compliance with the
areas and standards inspected with the exception of significant deficiencies in the Environmental
Health and Safety and Suicide Prevention and Intervention standards.
This report includes descriptions of all deficiencies and refers to the specific, relevant NDS. The
report will be provided to ERO to develop corrective actions to resolve identified deficiencies.
All deficiencies were discussed with MCADC personnel on-site during the inspection, as well as
during the close out briefing conducted on November 3, 2011.
ODO found a significant number of deficiencies in its review of the Environmental Health and
Safety NDS. ODO observed chemicals stored and used in many areas throughout the facility.
Inventory records for the chemicals were not accurate. Chemicals in the detainee housing units
were stored in spray bottles that were not labeled accurately. Also, Material Safety Data Sheets
were not current and available for all substances.

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A detainee identified by MCADC staff as at risk for suicide was not referred for medical
evaluation to determine the level of suicide risk. The MCADC staff believed the detainee was
not suicidal and placed him in a cell for precautionary observation, a lower level of observation
than suicide watch that allows detainees to retain personal property. The detainee attempted
suicide while under precautionary observation and was taken to the hospital for overnight
observation, returned to the facility under suicide watch, and transferred the next day to the
Shawnee County Jail located in Shawnee, Kansas, which has additional resources and 24-hour
nursing staff coverage.
Food service workers have not received pre-employment physicals. The Food Service
Administrator informed ODO she was unaware of the requirement for pre-employment medical
examinations.
Detainee requests are processed by MCADC staff and submitted to ERO via email in a timely
manner. ERO responds to detainee requests within 72 hours of receipt by providing an email
response to MCADC staff. MCADC submitted an informal grievance log to ODO for review.
MCADC staff stated no formal grievances have been reported by ICE detainees in the past three
years relating to medical care, mental health care, law library, telephone access, recreation,
religious practices, visitation, staff-detainee communication, use of force, or officer/staff
misconduct.
ODO’s inspection of the Detainee Grievance Procedure standard at MCADC resulted in no
deficient findings. MCADC has an established, reasonable time limit for processing, investigating,
and responding to grievances. All grievances are received, distributed, and responded to within 24
hours. The grievance section of the detainee handbook provides procedures for filing a grievance
and appeal, resolving a grievance, and the right to have the grievance referred to higher levels.
MCADC staff contacts ICE immediately when there is an emergency grievance. All medical
grievances are referred to MCADC medical staff.

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

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

INSPECTION TEAM MEMBERS

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

Special Agent (Team Lead)
Special Agent
Contract Inspector
Contract Inspector
Contract Inspector

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ODO, Houston
ODO, Houston
MGT of America, Inc.
MGT of America, Inc.
MGT of America, Inc.

Morgan County Adult Detention Center
ERO Chicago

OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the MCADC Chief Deputy and Sergeant, and the ERO AFOD and SDDO who
oversee the facility. ICE does not have staff permanently stationed at MCADC.
ERO and MCADC staff stated that morale is good, the working relationship between them is
very good, and working conditions are adequate to accomplish assigned duties.
MCADC management expressed concern that the daily rate paid by ICE per detainee has
remained constant since July 2003, and ERO has not responded to a request for an increase. The
AFOD and MCADC management have agreed to engage in discussions to address the issue.

DETAINEE RELATIONS
ODO interviewed four male and four female detainees (14 percent of the total ICE population),
randomly-selected from all classification levels, to assess detention conditions. All eight
detainees complained they had to pay for barbering services, but it is not a requirement of the
NDS to provide free barbering services. All detainees interviewed stated they participate in
outdoor recreation, can send and receive mail, are permitted to use telephones, have access to a
law library, and voiced no complaints regarding food service and medical care.
Detainees stated they were provided hygiene supplies free of charge. All detainees interviewed
stated they did not receive a detainee handbook. Their detention files did not include signed
acknowledgement forms or any other documentation indicating receipt of a handbook

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 13 NDS and found MCADC fully compliant with the following
5 standards:
Detainee Grievance Procedure
Medical Care
Special Management Unit
Telephone Access
Use of Force and Restraints
As these standards were compliant at the time of the review, a synopsis for these areas was not
prepared for this report.
ODO found deficiencies in the following eight standards:
Access to Legal Material
Detainee Classification System
Detainee Handbook
Environmental Health and Safety
Food Service
Funds and Personal Property
Staff-Detainee Communication
Suicide Prevention and Intervention
Findings for each of these standards are presented in this report.

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ACCESS TO LEGAL MATERIAL (ALM)
ODO reviewed the Access to Legal Material standard at MCADC to determine if detainees have
access to a law library, legal materials, courts, counsel, and equipment to facilitate the
preparation of legal documents, in accordance with the ICE NDS. ODO reviewed local policies,
procedures, and the detainee handbook; inspected the areas designated for law library use; and
interviewed staff and detainees.
The law library is located at the entrance to the booking area. The room is in a very noisy area
adjacent to the detainee processing area and the facility hold rooms. Furnishings consist of one
desk and one chair (Deficiency ALM-1). A quiet area with adequate furnishings, equipment and
supplies supports effective legal research and case preparation. This deficiency was identified
during the February 2011 MGT inspection.
ODO confirmed the MCADC detainee handbook does not contain procedures for requesting
legal reference materials not maintained in the law library or procedures for notifying a
designated employee that library material is missing or damaged. The rules and procedures
governing access to legal materials are not posted in the law library (Deficiency ALM-2).

STANDARD/POLICY REQUIREMENT FOR DEFICIENT FINDINGS
DEFICIENCY ALM-1
In accordance with the ICE NDS, Access to Legal Material, Section (III)(A), the FOD must
ensure the facility shall provide a law library in a designated room with sufficient space to
facilitate detainees’ legal research and writing. The law library shall be large enough to provide
reasonable access to all detainees who request its use. It shall contain a sufficient number of
tables and chairs in a well-lit room, reasonably isolated from noisy areas.
DEFICIENCY ALM-2
In accordance with the ICE NDS, Access to Legal Material, Section (III)(Q)(5)and(6), the FOD
must ensure the detainee handbook or equivalent shall provide detainees with the rules and
procedures governing access to legal materials, including the following information:
5. the procedure for requesting legal reference materials not maintained in the law library;
and
6. the procedure for notifying a designated employee that library material is missing or
damaged.
These policies and procedures shall also be posted in the law library along with a list of the law
library’s holdings.

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DETAINEE CLASSIFICATION SYSTEM (DCS)
ODO reviewed the Detainee Classification System standard at MCADC to determine if there is a
requirement for a formal classification process for managing and separating detainees based on
verifiable and documented data, in accordance with the ICE NDS. ODO interviewed staff and
reviewed detention files.
MCADC staff reported ICE completes a detainee assessment classification form prior to a
detainee arriving at the facility, but does not provide sufficient documentation to aid in the
detainee classification process. ODO reviewed 15 randomly-selected detention files. Five (33
percent) of these files did not contain relevant information such as current and past offenses,
escapes or escape attempts, institutional disciplinary history, and violent episodes/incidents, used
for classification purposes. Ten files (67 percent) contained a Form I-213 (Record of Deportable
Alien) with no additional supporting documentation. Also, none of the 15 classification forms
were reviewed and approved by a first line supervisor as required by the standard
(Deficiency DCS-1). Proper classification of detainees ensures detainees with a history of
violence are not commingled with detainees of a lower classification level. Properly classified
detainees will also ensure the safety of staff and visitors.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DCS-1
In accordance with the ICE NDS, Detainee Classification, section (III)(A)(1)(3), the FOD must
ensure the facility shall abide by ICE policy, rules, and guidelines as set forth in this standard
and implement the attached Detainee Classification system for classifying detainees. CDFs and
IGSA facilities may continue using the systems established locally, if the classification criteria
are objective and all procedures meet ICE requirements. The classification system ensures:
1. All detainees are classified upon arrival, before being admitted into the general
population. ICE will provide CDFs and IGSA facilities with the data they need from
each detainee's file to complete the classification process. All officers assigned to
classification duties shall be trained in the facility’s classification process.
3. The first-line supervisor will review and approve each detainee’s classification.

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DETAINEE HANDBOOK (DH)
ODO reviewed the Detainee Handbook standard at MCADC to determine if the facility provides
each detainee with a handbook, written in English and any other languages spoken by a
significant number of detainees housed at the facility, describing the facility’s rules and
sanctions, disciplinary system, mail and visiting procedures, grievance system, services,
programs, and medical care, in accordance with the ICE NDS. ODO reviewed facility policy
and the handbook, and interviewed detainees and staff.
ODO confirmed the MCADC detainee handbook was last updated in February 2011. ODO
verified it contains all required information. Copies of both the facility handbook and the ICE
National Detainee Handbook are readily available in the booking area. Review of detainee files
revealed issuance to detainees is inconsistent. Though facility policy requires that all detainees
be issued handbooks at intake, only three of fifteen (20%) files reviewed contained
documentation verifying issuance. During interviews, all eight detainees reported they had not
received a handbook (Deficiency DH-1). Uniform issuance of handbooks provides detainees
with critical information on facility rules, procedures, and services. ODO recommends that
action be taken to ensure all detainees receive and sign receipts for handbooks.
Omissions of required material in the handbook are reported under the relevant standards as
Deficiencies ALM-3 and F&PP-3.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DH-1
In accordance with the ICE NDS, Detainee Handbook, Section (I), the FOD must ensure that
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.

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ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Environmental Health and Safety standard at MCADC to determine if the
facility maintains high standards of cleanliness and sanitation, safe work practices, and control of
hazardous materials and substances, in accordance with the ICE NDS. ODO toured the facility,
interviewed staff, and reviewed procedures and documentation of inspections, hazardous
chemical management, and fire drills. ODO identified nine deficiencies, many raising
significant safety concerns.
Hazardous substances are stored in housing units, food service, laundry, and booking areas.
Inventories of hazardous substances were not up-to-date or accurate (Deficiency EH&S-1). This
deficiency was identified during the February 2011 MGT inspection. Maintaining strict
inventory and control of all chemicals is critical to the safety of detainees, staff, and visitors.
Area-specific files of Material Safety Data Sheets (MSDS) were not accurate and did not provide
a plant diagram or legend (Deficiency EH&S-2). Access to accurate MSDS is crucial to ensure
safe handling, storage, usage, and disposal of hazardous substances. A plant diagram and legend
assure locations of stored hazardous substances are identified. The facility does not maintain a
master index of hazardous substances with storage locations, up-to-date emergency phone
listings, or documentation of semi-annual reviews. The Safety Officer stated that MSDS are not
reviewed on any scheduled basis (Deficiency EH&S-3). In the event of an emergency, a master
index assures responders can quickly identify the types of hazardous substances and their storage
locations within the facility. An accurate listing of emergency phone numbers facilitates an
emergency response when immediate treatment is required and medical service is not available.
Semi-annual review ensures MSDS are current, complete, and accurate for all hazardous
substances. ODO observed disinfectant “Altima 128” had been issued and stored in a spray
bottle labeled “Clean Power Pink” (Deficiency EH&S-4). Accurate labeling is critical to ensure
proper medical response in the event of accidental or intentional misuse of a hazardous
substance.
ODO verified fire and safety inspections are conducted monthly and not weekly as required by
the standard (Deficiency EH&S-5). Weekly inspections allow earlier identification and
correction of potential problems before they become life-safety issues.
The facility’s fire prevention, control, and evacuation plan does not address control of possible
ignition sources and control of combustible and flammable fuel load sources. The written plan
does not address requirements for installation of fire protection equipment throughout the
facility; inspection, testing, and maintenance of the equipment; monthly fire inspections; and
floor plans, exit signs, and evacuation diagrams (Deficiency EH&S-6). Though not addressed in
the plan, ODO notes fire protection equipment is in place and documentation of inspection and
testing was available, and there are exit signs and evacuation diagrams throughout the facility.
Monthly fire drills are conducted and documented; however, they are not conducted in certain
areas of the facility and do not include emergency key drills to determine if keys can be located,
and access to exits is available and usable (Deficiency EH&S-7). Fire drills in all areas of the
facility that involve practicing evacuation serve a critical life-safety purpose.

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Administrative staff reported the emergency electrical generator is programmed to self-test
weekly. Maintenance personnel were unavailable to confirm or provide documentation of
testing or preventive maintenance. The only available documentation of testing and preventive
maintenance by an outside vendor was dated April 2011, when biweekly testing is required
(Deficiency EH&S-8). Emergency generators serve a vital life-safety function in the event of a
power outage.
Due to space constraints at MCADC, barbering is conducted in a small room in the booking area
also used for other activities. Detainees complete a Request for Hair Cut form and haircuts are
provided on a first come-first served basis by a local barber. The barber transports all tools and
chemicals for haircuts. Barbering supplies are not maintained by MCADC and were not
available for the inspection. The designated barbershop has adequate lighting and the required
non-absorbent floor; however, hot water was not readily available and hair care regulations were
not posted (Deficiency EH&S-9). This deficiency was identified during the February 2011
MGT inspection. Postings promote adherence to the standard and ensure that all detainees are
aware of sanitation requirements.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EH&S-1
In accordance with ICE NDS, Environmental Health and Safety, section (III)(A), the FOD must
ensure every area will maintain a running inventory of the hazardous (flammable, toxic, or
caustic) substances used and stored in that area. Inventory records will be maintained separately
for each substance, with entries for each logged on a separate card (or equivalent). That is, the
account keeping will not be chronological, but filed alphabetically, by substance (dates,
quantities, etc.).
DEFICIENCY EH&S-2
In accordance with ICE NDS, Environmental Health and Safety, section (III)(B), the FOD must
ensure every area using hazardous substances will maintain a self-contained file of the
corresponding Material Safety Data Sheets (MSDSs). The MSDSs provide vital information on
individual hazardous substances, including instructions on safe handling, storage, and disposal,
prohibited interactions, etc. Staff and detainees will have ready and continuous access to the
MSDSs for the substances with which they are working while in the work area.
Because changes in MSDSs occur often and without broad notice, staff must review the latest
issuance from the manufacturers of the relevant substances, updating the MSDS files as
necessary.
The MSDS file in each area should include a list of all areas where hazardous substances are
stored, along with a plant diagram and legend. Staff will provide a copy of this information and
all MSDSs contained in the file, forwarding updates upon receipt, to the Maintenance Supervisor
or designate.
DEFICIENCY EH&S-3
In accordance with ICE NDS, Environmental Health and Safety, section (III)(C), the FOD must
ensure the maintenance supervisor or designee will compile a master index of all hazardous
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substances in the facility, including locations, along with a master file of MSDS. He/she must
maintain this information in the safety office (or equivalent), with a copy to the local fire
department. Documentation of semi-annual review will be maintained in the MSDS file. The
master index will also include a comprehensive, up-to-date list of emergency phone numbers
(fire department, poison control center, etc.).
DEFICIENCY EH&S-4
In accordance with ICE NDS, Environmental Health and Safety, section (III)(J)(2), the FOD
must ensure the OIC will individually assign the following responsibilities associated with the
labeling procedure: Requiring use of properly labeled containers for hazardous materials,
including any and all miscellaneous containers into which employees might transfer the material.
DEFICIENCY EH&S-5
In accordance with ICE NDS, Environmental Health and Safety, section (III)(L)(2), the FOD
must ensure a qualified departmental staff member will conduct weekly fire and safety
inspections; the maintenance (safety) staff will conduct monthly inspections. Written reports of
the inspections will be forwarded to the OIC for review and, if necessary, corrective action
determinations. The Maintenance Supervisor or designate will maintain inspection reports and
records of corrective action in the safety office.
DEFICIENCY EH&S-6
In accordance with ICE NDS, Environmental Health and Safety, section (III)(L)(3)(a)through(h),
the FOD must ensure every institution will develop a fire prevention, control, and evacuation
plan to include, among other things, the following:
a. Control of ignition sources;
b. Control of combustible and flammable fuel load sources;
c. Provisions for occupant protection from fire and smoke;
d. Inspection, testing, and maintenance of fire protection equipment, in accordance with
NFPA codes, etc.;
e. Monthly fire inspections;
f. Installing fire protection equipment throughout the facility, in accordance with NFPA 10,
Standard for Portable Fire Extinguishers;
g. Accessible, current floor plans (buildings and rooms); prominently posted evacuation
maps/plans; exit signs and directional arrows for traffic flow; with a copy of each
revision filed with the local fire department;
h. Conspicuously posted exit diagram conspicuously posted for and in each area.
DEFICIENCY EH&S-7
In accordance with ICE NDS, Environmental Health and Safety, section (III)(L)(4)(a)(b)and(c),
the FOD must ensure monthly fire drills will be conducted and documented separately in each
department.
a. Fire drills in housing units, medical clinics, and other areas occupied or staffed during
non-working hours will be timed so that employees on each shift participate in an annual
drill.
b. Detainees will be evacuated during fire drills, except in areas where security would be
jeopardized or in medical areas where patient health could be jeopardized or, in individual

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cases when evacuation of patients is logistically not feasible. Staff- simulated drills will take
place instead in the areas where detainees are not evacuated.
c. Emergency-key drills will be included in each fire drill, and timed. Emergency keys will be
drawn and used by the appropriate staff to unlock one set of emergency exit doors not in
daily use. NFPA recommends a limit of four and one-half minutes for drawing keys and
unlocking emergency doors.
DEFICIENCY EH&S-8
In accordance with ICE NDS, Environmental Health and Safety, section (III)(O), the FOD must
ensure power generators will be tested at least every two weeks. Other emergency equipment
and systems will undergo quarterly testing, with follow-up repairs or replacement as necessary.
The biweekly test of the emergency electrical generator will last one hour. During that time, the
oil, water, hoses, and belts will be inspected for mechanical readiness to perform in an
emergency situation. The emergency generator will also receive quarterly testing and servicing
from an external generator-service company. Among other things, the technicians will check
starting battery voltage, generator voltage, and amperage output.
DEFICIENCY EH&S-9
In accordance with ICE NDS, Environmental Health and Safety, section (III)(P)(1)(4), the FOD
must ensure sanitation of barber operations is of the utmost concern because of the possible
transfer of diseases through direct contact or by towels, combs, and clippers. Towels must not be
reused after use on one person. Instruments such as combs and clippers will not be used
successively on detainees without proper cleaning and disinfecting. The following standards will
be adhered to:
1. The operation will be located in a separate room not used for any other purpose. The
floor will be smooth, nonabsorbent and easily cleaned. Walls and ceiling will be in good
repair and painted a light color. Artificial lighting of at least 50-foot candles will be
provided. Mechanical ventilation of 5 air changes per hour will be provided if there are
no operable windows to provide fresh air. At least one lavatory will be provided. Both
hot and cold water will be available, and the hot water will be capable of maintaining a
constant flow of water between 105 degrees and 120 degrees.
2. Each barbershop will have detailed hair care sanitation regulations posted in a
conspicuous location for the use of all hair care personnel and detainees.

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FOOD SERVICE (FS)
ODO reviewed the Food Service standard at MCADC to determine if detainees are provided
with a nutritious and balanced diet, in a sanitary manner, in accordance with the ICE NDS. ODO
reviewed available documentation, interviewed staff, inspected the food service area, and
observed meal preparation and service.
ODO verified all menus were certified by a registered dietitian, and inspections and temperature
logs supported compliance with the standard.
Food service workers have not received pre-employment physicals (Deficiency FS-1). The Food
Service Administrator informed ODO she was unaware of the requirement for pre-employment
medical examinations. Medical clearance is critical to prevent transmission of communicable
illness by way of food items. ODO recommends current food service personnel undergo
physical examination, and the facility institute procedures to ensure future hires receive medical
clearance.

STANDARD POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with ICE NDS, Food Service, section (III)(H)(3)(a), the FOD must ensure all food
service personnel (both staff and detainee) shall receive a pre-employment medical examination.
The purpose of this examination is to exclude those who have a communicable disease in any
transmissible stage or condition. Detainees who have been absent from work for any length of
time for reasons of communicable illness (including diarrhea) shall be referred to Health
Services for a determination as to fitness for duty prior to resuming work.

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FUNDS AND PERSONAL PROPERTY (F&PP)
ODO reviewed the Funds and Personal Property standard at MCADC to determine if controls are
in place to inventory, issue receipts for, store, and safeguard detainees’ personal property, in
accordance with the ICE NDS. ODO interviewed staff, reviewed policies and procedures, and
observed the processing of detainees.
All personal property is inventoried and maintained in a secured cage in the facility basement.
Identification information for each detainee is attached to each bag. MCADC staff stated the
secured property room is accessible to any officer, rather than just to designated supervisors
(Deficiency F&PP-1). MCADC staff stated detainees are not permitted to have cash in their
possession since all funds are deposited into individual detainee accounts. Funds in a detainee’s
possession upon initial admission, or funds sent to a detainee in the form of a personal check via
the mail, are deposited into an account for the detainee to use for purchasing phone cards and/or
commissary use. MCADC has a cash box safe for temporarily holding cash and valuables,
located in the intake processing area. MCADC staff stated the cash box is only accessible to
designated supervisors and a facility accounting person. MCADC has no procedure for
inventory and audit of detainee funds, valuables, and property (Deficiency F&PP-2).
MCADC’s detainee handbook does not provide ICE detainees notice regarding the procedures to
claim property upon release, transfer, or removal. The handbook also lacks procedures for filing
a claim for lost or damaged property (Deficiency F&PP-3). Ensuring ICE detainees have clear
and comprehensive ICE and facility detainee handbooks is an essential element in ensuring
detainees are made well aware of rules, policies, and procedures. ODO recommends amending
the detainee handbook to include this information.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY F&PP-1
In accordance with the ICE NDS, Funds and Personal Property, section (III)(A)(4), the FOD
must ensure each facility shall have a secured locker for holding large valuables, accessible to
designated supervisor(s) only.
DEFICIENCY F&PP-2
In accordance with the ICE NDS, Funds and Personal Property, section (III)(F), the FOD must
ensure each facility shall have a written procedure for inventory and audit of detainee funds,
valuables, and personal property.
DEFICIENCY F&PP-3
In accordance with the ICE NDS, Funds and Personal Property, section (III)(J)(4), the FOD must
ensure the detainee handbook or equivalent shall notify the detainees of facility policies and
procedures concerning personal property, including:
4. The procedure for claiming property upon release, transfer, or removal;
5. The procedures for filing a claim for lost or damaged property.

Office of Detention Oversight
November 2011
OPR 201200575

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Morgan County Adult Detention Center
ERO Chicago

STAFF-DETAINEE COMMUNICATION (SDC)
ODO reviewed the Staff-Detainee Communication standard at MCADC to determine if
procedures are in place to allow formal and informal contact between detainees and key ICE and
facility staff, and if ICE detainees are able to submit written requests to ICE staff and receive
responses in a timely manner, in accordance with the ICE NDS. ODO reviewed logbooks and
interviewed staff.
ICE does not have staff permanently stationed at MCADC. An ICE IEA visits MCADC once a
week and an alternate IEA is available, if needed. A Deportation Officer visits the facility once a
month. ODO reviewed a logbook maintained by ERO which verifies visits with detainees and
the receipt and address of detainee requests.
ICE management officials do not conduct required unannounced visits with detainees or to
facility housing units, food service areas, the recreation area, special management units, or the
infirmary (Deficiency SDC-1). Regular unannounced visits allow ICE management to observe
the general environment at the facility and have informal conversations with facility staff and
detainees.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SDC-1
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(A)(1)(2), the
FOD must ensure ICE detainees should have the opportunity to have informal access to, and
interaction with, key facility staff members on a regular basis. In addition to informal contact
with facility staff, detainees often require regular access to key ICE staff. Often detainees in ICE
custody are unaware of or do not comprehend the immigration removal process, and staff should
explain the general process to detainees without providing specific legal advice on their
individual cases.
1. Policy and procedures shall be in place to ensure and document that the ICE Officer in
Charge (OIC), the Assistant Officer in Charge (AOIC) and designated department heads
conduct regular unannounced (not scheduled) visits to the facility’s living and activity
areas to encourage informal communication between staff and detainees and informally
observing [sic] living and working conditions.
2. The purpose for these scheduled weekly visits is to address detainees’ personal concerns
and to monitor living conditions. Facility or District detention and deportation staff in
the jurisdiction where these facilities are located shall condct these scheduled visits. The
visiting officer should be familiar with the ICE detention standards and report all
violations to the Field Director.

Office of Detention Oversight
November 2011
OPR 201200575

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Morgan County Adult Detention Center
ERO Chicago

SUICIDE PREVENTION AND INTERVENTION (SP&I)
ODO reviewed the Suicide Prevention and Intervention standard at MCADC to determine if the
health and well-being of detainees are protected by training staff in effective methods of suicide
prevention, in accordance with the ICE NDS. ODO reviewed ten staff training records, facility
policy, and the suicide prevention training curriculum, inspected the cell used for suicide watch,
reviewed the medical record of one detainee placed on suicide watch, and interviewed an RN and
jail administrative staff.
Detainees are screened for suicide risk during the intake process. All staff receives initial and
ongoing suicide prevention training, which includes the identification of suicide risk factors,
recognizing the signs of suicidal thinking and behavior, referral procedures, suicide prevention
techniques, and responding to an in-progress suicide attempt.
One detainee has been placed on suicide watch in the past year. A detainee identified by
MCADC staff as at risk for suicide was not referred for medical evaluation to determine the level
of suicide risk. MCADC staff interviewed the detainee without referring him to medical staff for
proper evaluation as required by the standard and local policy (Deficiency SP&I-1). The
MCADC staff believed the detainee was not suicidal and placed him in a cell for precautionary
observation, a lower level of observation than suicide watch that allows detainees to retain
personal property. The detainee attempted suicide while under precautionary observation and
was taken to the hospital for overnight observation. Subsequently, the detainee was returned to
MCADC under suicide watch before being transferred the next day to the Shawnee County Jail
(SCJ) located in Shawnee, Kansas. SCJ has additional resources and 24 hour nursing staff
coverage.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SP&I-1
In accordance with ICE NDS, Suicide Prevention and Intervention, section (III)(B), the FOD
must ensure detainees identified, [sic] as “at risk” for suicide will be promptly referred to
medical staff for evaluation.

Office of Detention Oversight
November 2011
OPR 201200575

16

Morgan County Adult Detention Center
ERO Chicago