ICE Detention Standards Compliance Audit - Ramsey County Adult Detention Facility, Saint Paul, MN, ICE, 2009

ICE Detention Standards Compliance Audit - Ramsey County Adult Detention Facility, Saint Paul, MN, ICE, 2009

• June 2, 2016 • Locations: United States of America -> Minnesota • Topics: Corrections Audits, Immigration

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Department of Homeland Security
Immigration and Customs Enforcement
Office of Detention and Removal

•

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

ICE Detention Standards Review Worksheet
Local Jail- IGSA
State Facility - IGSA
ICE Contract Detention Facility
Name
'...."....., Adult Detention
Address (Street and Name)
425 Grove Street
City, State and Zip Code
St.
Minnesota 55102
County
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
b6,b7c
Undersheriff
Name and Title of Reviewer-In-Charge
b6,b7c

Date[s] of Review
November 17-1 2009
Type of Review
~ Headquarters
0 Operational

o Special Assessment

o Other

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

TABLE OF CONTENTS

•

DETAINEE SERVICES STANDARDS (SECTION I) .......................................................................... 3
ACCESS TO LEGAL MATERIALS .......................................................................................................... .
ADMISSION AND RELEASE ................................................................................................................. .
CLASSIFICATION SYSTEM .................................................................................................................. .
CORRESPONDENCE AND OTHER MAIL ................................................................................................ .
DETAINEE HANDBOOK ....................................................................................................................... .
FOOD SERVICE ................................................................................................................................... .
FUNDS AND PERSONAL PROPERTy ..................................................................................................... .
DETAINEE GRIEVANCE PROCEDURES ................................................................................................. .
GROUP PRESENTATIONS ON LEGAL RIGHTS ....................................................................................... .
ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS .................................................... .
MARRIAGE REQUESTS ....................................................................................................................... .
NON-MEDICAL ESCORTED TRIPS ....................................................................................................... .
RECREATION ..................................................................................................................................... .
RELIGIOUS PRACTICES ....................................................................................................................... .
ACCESS To TELEPHONES ................................................................................................................... .
VISITATION ........................................................................................................................................ .
VOLUNTARY WORK PROGRAM .......................................................................................................... .
HEALTH SERVICES STANDARDS (SECTION II) ......................................................................... 29
HUNGER STRIKES .............................................................................................................................. .
ACCESS TO MEDICAL CARE ............................................................................................................... .
SUICIDE PREVENTION AND INTERVENTION ......................................................................................... .
TERMINAL ILLNESS, ADVANCED DIRECTIVES AND DEATH ................................................................ .

•

SECURITY AND CONTROL STANDARDS (SECTION III) ............................................................. 38
CONTRABAND .................................................................................................................................... .
DETENTION FILES .............................................................................................................................. .
DISCIPLINARY POLICy ....................................................................................................................... .
EMERGENCY PLANS ........................................................................................................................... .
ENVIRONMENTAL HEALTH AND SAFETy ............................................................................................ .
HOLD ROOMS IN DETENTION FACILITIES ........................................................................................... .
KEy AND LOCK CONTROL .................................................................................................................. .
POPULATION COUNTS ........................................................................................................................ .
POST ORDERS .................................................................................................................................... .
SECURITY INSPECTIONS ..................................................................................................................... .
SPECIAL MANAGEMENT UNIT (ADMINISTRATIVE SEGREGATION) ...................................................... .
SPECIAL MANAGEMENT UNIT (DISCIPLINARY SEGREGATION) ........................................................... .
TOOL CONTROL ................................................................................................................................. .
TRANSPORTATION (LAND) ................................................................................................................ .
USE OF FORCE ................................................................................................................................... .
STAFFIDETAINEE COMMUNICATIONS ................................................................................................. .
DETAINEE TRANSFER STANDARD ...................................................................................................... .

NOTE: FOR EACH STANDARD RATED BELOW ACCEPTABLE, FACILITIES MUST ATTACH A PLAN OF ACTION FOR BRINGING
OPERATIONS INTO COMPLIANCE. EACH FACILITY SHOULD EXAMINE THE ENTIRE WORKSHEET TO IDENTIFY AREAS OF
IMPROVEMENT, INCLUDING THOSE STANDARDS WHERE AN OVERALL FINDING OF ACCEPTABLE WAS ACHIEVED.

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 2 of69

•

SECTION I

DETAINEE SERVICES STANDARDS

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 3 of69

ACCESS TO LEGAL MATERIALS
POLICY: FACILITIES HOLDING ICE DETAINEES SHALL PERMIT DETAINEES ACCESS TO A LAW LIBRARY, AND PROVIDE LEGAL MATERIALS,
EQUIPMENT DOCUMENT COPYING PRIVILEGES, AND THE OPPORTUNITY TO PREPARE LEGAL DOCUMENTS.

The facility provides a designated law library for
detainee use.

The law library contains all materials listed in the "Access to Legal
Materials" Standard, Attachment A. The listing of materials is posted
in the law
The
number of chairs, is well lit, and is

The facility has no space
dedicated to a law library. Only
Lexis Nexis access is provided
to detainees who request access
to legal materials. This access is
.
.
.
rooms.
There is no physical law library
and as a result, materials are not
is no designated law

Where provided, the Lexis Nexis library is updated and is current.

persons and organizations are permitted to submit published
legal material for inclusion in the legal library. Outside published
material is forwarded and reviewed by ICE prior to inclusion.

There is a designated ICE or facility employee who inspects, updates,
and maintains/replaces legal materials and equipment on a routine
basis.
Detainees are offered a minimum 5 hours per week in the law library.
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
Detainees may request materials not currently in the law library. Each
request is reviewed and, where appropriate, an acquisition request is
timely initiated.
Requests for copies of court decisions are
accommodated within 3 - 5 business
Detainees are permitted to assist other detainees, voluntarily and free
of charge, in researching and preparing legal documents, consistent
with
Illiterate or non-English-speaking detainees without legal
representation receive access to more than just English-language law
books after .
their need for
Detainees may retain a reasonable amount of personal legal material in
the general population and in the special management unit. Stored
materials are accessible within 24 hours of a written
housed in Administrative Detention and
units have the same law

New Lexis Nexis diskettes were
received during the inspection
and did not work. ICE was
contacted and advised of the
problem. Functioning
replacement discs were
provided. Records exist which
document use of Lexis Nexis by
detainees.
There is no physical law library.
Detainees only access is through
Lexis Nexis and as a result,
materials submitted by outside
persons or organizations would
not be available to detainees.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 4 of69

on any matter are not subjected to
~ ACCEPTABLE

DEFICIENT

OAT-RISK

o
o REPEAT FINDING

REMARKS:

Adult Detention Facilit has no hysical law library and only provides access to legal materials through Lexis
.
.
Nexis. Any detainee desiring access to legal materials can make a request. nstructlOns or ma·n
housing unit. The shift Lieutenant then provides the computer and discs to the detainee for use within the attached multi-purpose
room. Documentation was provided which substantiated detainee use of the system.
During the inspection, ICE provided updated Lexis Nexis discs, however, these discs did not function properly. A second set was
provided and it wa determined to be operational.
b6,b7c

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_UDITOR'S

•

11-19-09
IGNATURE I DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 5 of69

ADMISSION AND RELEASE
POLICY: ALL DETAINEES WILL BE ADMITIED AND RELEASED IN A MANNER THAT ENSURES THEIR HEALTH, SAFETY, AND WELFARE. THE
"-''''''''J'V'''' PROCEDURE WILL, AMONG OTHER THINGS INCLUDE: MEDICAL SCREENING; A FILE-BASED ASSESSMENT AND CLASSIFICATION
BODY SEARCH; AND A SEARCH OF PERSONAL BELONGINGS, WHICH WILL BE INVENTORIED, DOCUMENTED, AND
AS NECESSARY.

In-processing includes an orientation of the facility. The orientation
includes: Unacceptable activities and behavior, and corresponding
sanctions; How to contact ICE; The availability of pro bono legal
services, and how to pursue such services; schedule of programs,
services, daily activities, including visitation, telephone usage, mail
service, religious programs, count procedures, access to and use of
the law library and the general library; sick-call procedures, and the
detainee handbook.
Medical screenings are performed by medical staff or persons who
have received specialized training for the purpose of conducting an
initial health
.

[8J

o
o
o

ICE field office.
All new arrivals are 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
Detainees are stripped searched only when cause has been
established and not as routine policy. Non-criminal detainees are
not strip-searched but are patted down, unless reasonable suspicion
is established.
standard governs all personal property searches.
use or have a similar contraband standard. Staff
prepares a complete inventory of each detainee's possessions. The
detainee receives a
Staff completes Form 1-387 or similar form for CDFs and IGSAs for
every lost or missing property claim. Facilities forward all 1-387
claims to ICE.
Detainees are issued appropriate and sufficient clothing and bedding
for the climatic conditions.
The facility provides
replenishes personal hygiene items as
needed. Gender-specific items are available. ICE Detainees are not
for these items.

b6,b7c

This was confirmed by ICE Agents.

C09

oAUDlTOR'SSIGNATURE/DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 6 of69

CLASSIFICATION SYSTEM

CmL

POLICY: ALL FACILITIES WILL DEVELOP AND IMPLEMENT A SYSTEM ACCORDING TO WHICH ICE DETAINEES ARE CLASSIFIED. THE
SYSTEM WILL ENSURE THAT EACH DETAINEE IS PLACED IN THE APPROPRIATE CATEGORY, PHYSICALLY SEPARATED
DET AlNEES IN OTHER CATEGORIES
O~"'~._~l'IJ!,l'Il~

The facility has a system for classifying detainees. In
CDFs and IGSAs, an Objective Classification System or
similar is used.
The facility classification system includes:
• Classifying detainees upon arrival;
• Separating from the general population those
individuals who cannot be classified upon
arrival; and
• The first-line supervisor or designated
classification specialist reviewing every
classification decision.
The intake/pI
19 officer
work-folders, Afiles, etc. to identify and da:s:sify each new arrival.
Staff uses only information that is factual, and reliable to
determine classification assignments. Opinions and
unsubstantiated! unconfirmed reports may be filed but
are not used to score detainees classifications.
-leveL
H~ing
Lents ar~sed~ cl :+':.
A detainee's classification-level does not affect hislher
recreation opportunities.
Detainees recreate with
l-''''I:SVll:S of similar classification rle~ion!lti()m:
Dc
work assignments are based upon classification
designations.
c1: ,.c: ion
process
includes
'<>cc,,"ccrn,
~lassification. At IGSA's, detainees may
request rea,:~e~~ment 60 days after arrival.
Procedures exist for a detainee to appeal their
classification assignment. Only a designated supervisor
or classification specialist has the authority to reduce a
classification-level on appeal.
Classification appeals are resolved within five business
days and detainees are notified of the outcome within 10

[]

REMARKS

business~s.
rh~>:ifir.!lti()n

designations may be appealed to a higher
authority, such as the Warden or equivalent.
The Detainee Handbook or equivalent for IGSAs
explains the classification levels, with the conditions and
restrictions applicable to each.
~ ACCEPTABLE

DEFICIENT

OAT-RISK

REPEAT FINDING

b6,b7c

[9-09

AUDITOR'S SIGNATURE / DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 7 of69

The rules for correspondence and other mail are posted in
each housing or common area, or provided to each detainee
via a detainee handbook.
The facility provides key information in languages other than
English; In the language(s) spoken by significant numbers of
detainees. List
Incoming mail is distributed to detainees
24 hours or 1
business
after it is received and .
Outgoing mail is delivered to the postal service within one
business day of its entering the internal mail system
weekends and

[gI

correspondence without
Staff does not inspect incoming special Correspondence for
physical contraband or to verify the "special" status of
enclosures without the detainee
Staff is
from reading or copying incoming special
ence.
is only authorized to inspect outgoing correspondence or
er 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
facili ta te criminal
rre:spcmdenc:e to a politician or to the media is processed as
and is not read or
The official authorizing the rejection of incoming mail sends
written notice to the sender and the addressee.
The official authorizing censorship or rejection of outgoing
mail
the detainee with
written notice.
Staff maintains a written record of every item removed from
detainee mail.
The Warden or equivalent monitors staff handling of
discovered contraband and its disposition. Records are
to date.
accurate and
The procedure for safeguarding cash removed from a detainee
protects the detainee from loss of funds and theft. The
amount of cash credited to detainee accounts is accurate.
Standard

uest.
taff disposes of prohibited items found in detainee mail in
accordance with the "Control and Disposition of Contraband"
Standard or the similar
in IGSAs.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 80f69

CORRESPONDENCE AND OTHER MAIL
POLICY: ALL FACILITIES WILL ENSURE THAT DEfAINEES SEND AND RECEIVE CORRESPONDENCE IN A TIMELY MANNER, SUBJECT TO
LIMITATIONS REQUIRED FOR THE SAFEfY, SECURITY, AND ORDERLY OPERATION OF THE FACILITY. OrHER MAIL WILL BE PERMITTED,
~ TO THE SAME LIMITATIONS. EACH FACILITY WILL WIDELY DISTRIBUTE ITS GUIDELINES CONCERNING CORRESPONDENCE AND
. MAIL.
Every indigent detainee has the opportunity to mail, at
government expense, reasonable correspondence about a legal
0
0
~
matter, in three one ounce letters per week and packages
deemed ne~e~~llry by ICE.
The facility has a system for detainees to purchase stamps and
for mailing all special correspondence and a minimum of 5
0
~
0
lence per week.
pieces of general VVll
The facility provides writing paper, envelopes, and pencils at
~
0
0
no cost to ICE detainees.
~ ACCEPTABLE

DEFICIENT

OAT-RISK

o REPEAT

FINDING

b6,b7c
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 9 of69

DETAINEE HANDBOOK
POLICY: EVERY OIC WILL DEVELOP A SITE-SPECIFIC DETAINEE HANDBOOK TO SERVE AS AN OVERVIEW OF, AND GUIDE TO, THE
ltNllVN POLICIES, RULES, AND PROCEDURES IN EFFECT AT THE FACILITY. THE HANDBOOK WILL ALSO DESCRIBE THE SERVICES,
tOGRAMK 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.
Cr
RF.MARKS
II~
YES
No NA
The netJ'linee handbook is written in English and translated into
0
~
0
Spanish, or into the next m
lcvdlent Lan!!ua!!e(s).
The handbook is "uppll
by the facility orientation
~
0
0
video, where one is provided.
All staff members receive a handbook and training regarding
~
0
0
the handbook contents.
The handbook is revised as necessary and there are procedures
in place for immediately communicating any revisions to staff
~
0
0
and detainees.
There an annual review of the handbook by a designated
~
0
0
committee or staff member.
The netJ'linee h:mcihook addresses the following Issues:
• Personal Items permitted to be retained by the
detainee; and
~
0
0
• Initial issue of clothes, bedding and personal hygiene
items.
The detainee hJ'lncihook states in clear language the basic
~
0
0
,;J,ilitie>:
detainee l'
The handbook clearly outlines the methods for classification of
detainees, explains each level, and explains the classification
~
0
0
appeals process .
. The h,mcihonk states when a medical examination will be
~
0
0
I cindeci
handbook describes the facility, housing units, dayrooms,
~
0
0
in-dorm activities, and special hOll>:!n!> units.
The handbook describes official count times and count
procedures; meal times and feeding procedures; procedures for
medical or religious diets; smoking policy; clothing exchange
~
0
0
schedules; and, if authorized, clothes washing and drying
~dl.lre>l and
~rso~ygien~ractict::s.
The handbook describe times and procedures for obtaining
disposable razors, and allows that detainees attending court
0
0
~
will be afforded the ul-'1-'urtunity to shave first.
The handbook describes barber hours and hair cutting
~
0
0
restrictions.
The handbook describes the telephone policy; debit card
procedures; direct and free calls; locations of telephones; policy
~
0
0
when telephone demand is high; and policy and procedures for
emergency phone calls.
l!!.
The handbook addrciSiSciS religious p>VlSll
~
0

The handbook states times and procedures for commissary or
vennin!> machine usage, where available.
The h:mnhook descfloes the netJ'linee VUIUUl<ll 'work pI UlSlal1!.
The handhook dl;;""I1U"" the library location and hours of
UP"laUUl1, and law library p>v""dUl"" and schedules.
The handhook describes attorney and regular visitation hours,
nolicie>:. anAYrocedllres.
h"ndhook d"cribe, the fucility e~t,.h"nd poliey.
handbook describes the facility visiting hours and
ledule. al!d visiting rules and regulations

0
i

[]

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 10 of69

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,
~M8' AND OPPORTUNITIES AVAILABLE THROUGH VARIOUS SOURCES, INCLUDING THE FACILITY, ICE, PRIVATE ORGANIZATIONS,
EVERY DETAINEE WILL RECEIVE A COpy OF THIS HANDBOOK UPON ADMISSION TO THE FACILITY.
LOMPul'lENTS
YES
No
NA
RF.MARK~

The

~lmcihnnk

describes the correspondence policy and

rX'I

VI UvIJUUI IJ~.

The handbook describes the detainee disciplinary policy and
procedures, including:
• Prohibited acts and severity scale sanctions;
• Time limits in the Disciplinary Process; and
•
c.
of the ~ .
. lary Process.
The grievance section of the handbook explains all steps in the
grievance process - Including:
• Informal (if used) and formal grievance procedures;
• The appeals process;
• In CDF facilities: procedures for filing an appeal of a
gripvlln~p with ICE.
• Staffi'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 Dt;va1 LllllJllI of Homeland Security.
The detainee handhook de~cTihe~ the medical sick call
pIUvlJdun;~ for general population and ""51-:gation.
The handbook describes the facility recreation policy including:
• Outdoor recreation hours.
• Indoor recreation hours.
handbook describes the detainee dress code for daily
jiving;_ and work assi!mmpnh;:
The handbook specifies the rights and responsibilities of all
detainees.
~ ACCEPTABLE

DEFICIENT

OAT-RISK

Only indoor recreation is offered at the
facility.

REPEAT FINDING

b6,b7c
b6,b7c

1-19-09

AUDITOR'sisIGNATURE / DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 11 of69

FOOD SERVICE
POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NUfRITIOUS AND APPETIZING MEALS, PREPARED IN
lrrrlRn4NC-E WITH THE IDGHEST SANITARY STANDARDS.

In;

The food service program is under the direct supervision of a
Qrofessionally trained and certified food serVIce
administrator. Responsibilities of cooks and cook foremen
are in writing. The Food Service Administrator (FSA)
determines the responsibilities of the Food Service Staff.
The Cook Supervisor 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 OeVlce.
All knives not in a secure cutting room are physically
secured to the workstation and staff directly supervises
detainees using knives at these workstations. Staff monitors
the condition of knives and dining utensils.
When necessary, special procedures govern the handling of
food items that pose_a security threat.
Operating procedures include daily searches (shakedowns)
of detainee work areas.
The FSA monitors staff implementation of the facility's
-r Ilation counts procedures.
Staff is trained in count

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
dC:Sl'fiptions to ensure they are accurate and up-to-date.
The Cook Foreman or equivalent instructs newly assigned
detainee workers in the rules and procedures of the food
service d~partment.
During orientation and training session(s), the CS explains
and demonstrates:
• Safe work practices and methods;
• Safety features of individual products/pieces of
equipment; and
Training
covers the safe handling of hazardous
•
material[s] the detainees are likely to encounter in
their work.
The Cook Supervisor documents all training in individual
detainee detention files.
Detainees at CDFs are paid in accordance with the
"Voluntary Work Program" standard. Detainee workers at
IGSAs are subject to local and state rules and regulations
"l:Safding detainee pay.
Detainees are served at least two hot meals every day. No
than 14 hours elapse between the last meal served and
le first meal of the following day.

YES

Detainees or inmates are not assigned to work
in the food service area.

RF.MARKS

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 12 of69

FOOD SERVICE
POLICY:

EVERY FACILITY WILL PROVIDE DEfAINEES IN ITS CARE WITH NUfRITIOUS AND APPEfIZING MEALS, PREPARED IN

ACCORDANCE WITH THE HIGHEST SANITARY STANDARDS.

C't

II"

cafeteria style operations, a transparent "sneeze guard"
l:'~v,,,,,,,, both the serving line and salad bar line.
The facility has a standard 35-day menu cycle. IGSAs use a
35 day or similar~tem for rotating meals.
The FSA or facility considers the ethnic diversity of the
facility's detainee population when developing menu cycles
(Provide p.xHmnlp.8).
A .registe!ed dietitian conclnct>: a complete nutritional
,1·
of every master-"ycle menu nlHnnecl
The FSA has established procedures to ensure that items on
the master-cycle menu are prepared and presented according
to a~~'
.r! recipes.
The Cook Foreman has the authority to change menu items if
necessary.
LliJl b each substitution, along with its
• If yes, .l.
JU1S1
• With copy to FSA
All staff and IOlu1llt:t:ns know and adhere to written "food
.l.
p"
ion' 1J1Ul;t:UUlt:1S.
Detainees whose religious beliefs require the adherence to
particular religious dietary laws are referred to the Chaplain
or FSA.
A common-fare menu available to detainees whose dietary
requirements cannot be met on the main line.
• Changes to the planned common-fare menu can be
made at the facility level;
• Hot entrees are offered three times a week;
• The common-fare menus satisfy nutritional
recommended daily allowances (RDAs);
• Staff routinely provide hot water for instant
beverages and foods;
Common-fare meals are served with:
0
• Disposable plates and utensils .
• Reusable plates and utensils .
Staff
use
separate cutting boards, knives, spoons,
•
scoops, etc. to l:'l\:;l:'al~ the common-fare diet items.
A supervisor at the command level must approve a
detainee's removal from the Common-Fare ~iv5wm.
The Warden, in conjunction with the chaplain and/or local
religious leaders, provides the FSA a schedule of the
ceremonial meals for the follo~ 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.

•

YES

RRMARKS

All meals are served in the housing units.

The FSA is the only individual authorized to
change menu items. If the FSA is not on site,
"/hp

tTIll<>t

<lnrl

U;"P

.~~m'
T'-

,1 nr;nr

to any menu changes being made.

There is no common-fare menu provided at
this facility. However, staff advised that all
special requests for meals are honored, if
approved, by program staff, medical staff,
and/or the chaplain.

A common-fare menu is not provided at this
facility.
A common fare menu is not provided at this
facility. Requests for special meals are
A by the chHnlHin
hUJlul~d, if

While there is no common-fare menu in place
at this facility, staff informed us that they do
accommodate all special requests for meals if
these requests are approved by program staff,
medical staff, and/or the chaplain.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page l3 of69

FOOD SERVICE
POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NUTRITIOUS AND APPETIZING MEALS, PREPARED IN
ACCORDANCE WITH THE HIGHEST SANITARY STANDARDS.
RI?MAIlK~
YES No
NA
~
(ITS
food service program addresses medical diets.
~
D
D
Satellite-feeding programs follow guidelines for proper
sanitation.
Hot and cold foods are maintained at the prescribed, "safe"
temperature(s) while being served.

All meals are provided in nutritionally adequate portions.

Food is not used to punish or reward detainees based upon
behavior.
The food service staff instructs detainee volunteers on:
• Personal cleanliness and hygiene;
• Sanitary techniques for preparing, storing, and
serving food; and
• The sanitary operation, care, and maintenance of
equinmp.nt
LVv.yVUV worKillg ill me lUUU st:rVlct: uvl'aHIIlt:llL
,with food safety and sanitation requirements.

D
D

Standard operating procedures include weekly inspections of
all food service areas, including dining and food-preparation
areas and equipment.
I>:?
• Who conducts the .
Equipment is inspected for compliance with health and
safety codes and regulations.
• When was the most recent inspection?
• Which agency conducted the inspecl~vu?
~ of discrepancies are forwarded to the Warden or
irrnated department head, and corrective action is
~r.hp'';inlp.n ~d r.omnlp.tp.n
Standard procedure includes checking and documenting
temperatures of all dishwashing machines after each meal.
Staff documents the results of every refrigerator/freezer
temperature check.
The cleaning schedule for each food service area IS
conspicuously posted.
Procedures include inspecting all incoming food shipments
for damage, contamination, and pest infestation.
Storage areas are locked when not in use.

~ ACCEPT ABLE

D DEFICIENT

AT-RISK

Detainees or inmates are not assigned to work
in the food department.

The Ramsey County health department
inspection was conducted on 11119/09.

Storage rooms are located outside the
perimeter of the facility and are inaccessible to
any detainees.

D REPEATFINDlNG

REMARKS:
Food services at this facility are provided under a private contract. Only contractual food service employees are authorized access to
the food preparation area and food storage areas. Although storage areas were unlocked at various times during the inspection, they
are located in areas which are not accessible by detainees or inmates. Detainees and inmates are not assigned to work in food services.
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Page 14 of69

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
JV'-,UIV=l~ ATION AND RECEIPTING OF SURRENDERED PROPERTY; AND THE INITIAL AND REGULARLY SCHEDULED INVENTORYING OF ALL

HANDLED

separated, stored, and are

valuables during in-processing to the
funds and valuables.
Staff searches arriving detainees and their personal property for
contraband.
Staff procedures follow written policy for returning forgotten property
to detainees.
discrepancies are immediately reported to the CDEO or Chief

The facility attempts to notify an out-processed detainee that he/she
left property in the facility:
• By sending written notice to the detainee's last known
address;
• Via certified mail; and
• The notice state that the detainee has 30 days in which to
claim the property, after which it will be considered
abandoned.
The facility disposes of abandoned property in accordance with
written procedures.
• If a CDF/IGSA
the

~
~
~

countmg any money
an
automatic counting machine counts
and stores the

REMARKS:

ily

fue 'equirement, ofthe NDS ,egru-ding f""d, and p.,.,omu pmperty.

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Ph.D. /11-19-09

DAUDITOR'S SIGNATURE / DATE

•

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Page 15 of69

DETAINEE GRIEVANCE PROCEDURES
POLICY: EVERY FACILITY WILL DEVELOP AND IMPLEMENT STANDARD OPERATING PROCEDURES (SOPS) FOR ADDRESSING DETAINEE
IN TIMELY FASHION. EACH STEP IN THE PROCESS WILL OCCUR WITHIN THE PRESCRIBED TIME FRAME. AMONG OTHER
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.

Written procedures provide for the informal resolution of oral
grievances (Not mandatory).
• If yes, the detainee has up to five days within which to make
hislher 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
identify emergency
them.
are documented or substantiated cases of staff harassing,
disciplining, penalizing, or otherwise retaliating against a detainee
who lodged a complaint:
• If yes, explain.

forward any grievance
official or in a CDF

cgJ ACCEPT ABLE

DEFICIENT

Procedures include maintaining a Detainee Grievance Log.
• If not, an alternative acceptable record keeping system is
maintained.
• "Nuisance complaints" are identified in the records.
• For quality control purposes, staff document nuisance
complaints received but not filed.
Staff is

o
o

officer
ICE.
OAT-RISK

There were no cases reported of
staff harassing, disciplining,
penalizing, or otherwise
retaliating against a detainee who

The facility does maintain a log
that tracks grievances by housing
unit. The requirement of
identifying "Nuisance
complaints" is specific to
SPC's/CDF's. The facility does
not track nuisance

o
o

REPEAT FINDING

REMARKS:

A grievance tracking system has recently been implemented by the facility. Grievances are logged by housing unit.
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-19-09

~ AUDITOR' SIGNATURE/DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 16 of69

GROUP LEGAL RIGHTS PRESENTATIONS
POLICY:

FACILITIES HOUSING ICE DEfAINEES SHALL PERMIT AUTHORIZE PERSONS TO MAKE PRESENTATIONS TO GROUPS OF
FOR THE PURPOSE OF INFORMING THEM OF U.S. IMMIGRATION LAW AND PROCEDURES, CONSISTENT WITH THE SECURITY AND
OPERATION OF EACH FACILITY. ICE ENCOURAGES SUCH PRESENTATIONS, WHICH INSTRUCT DEfAINEES ABOUT THE
IMMIGRATION SYSTEM AND THEIR RIGHTS AND OPTIONS WITHIN IT.

[gI CHECK HERE IF No GROUP PRESENTATIONS WERE CONDUCTED WITHIN THE PAST 12 MONTHS.
ACCEPTABLE OVERALL AND CONTINUE ON WITH NEXT PORTION OF WORKSHEET.
The Field Office is responsive to requests by attorneys and accredited
for
Upon receipt of concurrence by the Field Office Director, the facility
or authorized ICE Field Office ensures timely and proper notification
to
or accredited
The facility follows policy and procedure when rejecting or requesting
modifications to objectionable material provided or presented by the
or accredited

Documentation is submitted and maintained when any detainee is
denied permission to attend a presentation and the reason(s) for the
denia1.
When the number of detainees allowed to attend a presentation is
limited, the facility provides a sufficient number of presentations so
that all detainees
attend.
Detainees in segregation, unable to attend for security reasons, may
request separate sessions with presenters.
Such requests are
documented.
when necessary to assist attorneys and other
make the

Group presenters who have had their privileges suspended are notified
in writing by the Field Office Director or designee; and the reasons for
suspension are documented. The Headquarters Office for Detention
and Removal, Field Operations and Detention management Division,
is notified when a group or individual is suspended from making
The facility plays ICE-approved videotaped presentations on legal
at the request of outside organizations.
of the Group Legal Rights Presentation policy, including
is available to detainees

rgJ ACCEPT ABLE

o DEFICIENT

o
o

o
o
o

OAT-RISK

o REPEAT FINDING

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FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 17 of69

MARK STANDARD AS

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,

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, temperature-appropriate,
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); and
One
footwear.

•

One mattress;
One blanket;
Two sheets;
One pillowcase;
• One towel; and
• Additional blankets are issued based on local weather
conditions.
Detainees assigned to
areas are clothed in accordance
with the
'etamelO!s are provided clean clothing, linen and towels.
• Socks and undergarments - exchanged daily.
• Outer garments - twice weekly.
• Sheets - weekly.
• Towels - weekly.
• Pillowcases -

•
•
•

Vn'I1L""" al~taunee workers are permitted to exchange outer garments
more ITP{111,>ntll"
~ ACCEPT ABLE

D DEFICIENT

AT-RISK

D REPEAT FINDING

REMARKS:

b6,b7c

o AUDITOR'S

•

D. 111-19-09

IGNATURE/DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 18 of69

MARRIAGE REQUESTS
POLICY: ALL DEfAINEE MARRIAGE

WILL RECEIVE CASE-BY-CASE CONSIDERATION FROM leE MANAGEMENT.

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

I2l

The Field Office Director reviews every marriage request rejected by a
Warden/Ole or IGSA.
are documented.
It is standard practice to require a written request for permission to

I2l

The written request includes a signed
or comparable
documentation from the intended
marital intent.
The Warden/Ole
detainee and
When permission is
hislher decision.
provides the detainee with a place and time to make

I2l

b6,b7c

D AUDITOR'S SI

ATURE/DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 19 of69

NON-MEDICAL EMERGENCY ESCORTED TRIPS
POLICY: THE IMMIGRATION AND CUSTOMS ENFORCEMENT (ICE) MAY PROVIDE DETAINEES WITH STAFF-ESCORTED TRIPS INTO THE

FOR THE PURPOSE OF VISITING CRITICALLY ILL MEMBERS OF THE DETAINEE'S IMMEDIATE FAMILY, OR FOR ATTENDING

\,II

AL"

I2J STANDARD N/A: CHECK TmS BOX IF ALL ICE NON-MEDICAL EMERGENCY ESCORTED TRIPS ARE HANDLED ONLY BY THE ICE
FIELD OFFICE OR SUB-OFFICE IN CONTROL OF THE DETAINEE CASE.
COl\!
RVMADKl<
ITI;
YES
No
NA
The Field Office Director considers and approves, on a case-by-case
basis, trips to an immediate family member's:
D
D
D
Funeral; or
• Deathbed
The facility recognizes mother, father, brother,
, spouse, child,
D
D
D
"''''I'>-jJeU'''"l, and foster parent as "immecliMe family"
The IGSA facility notifies ICE of all detainee requests for non-medical
D
D
D
escorts.

•

The detainee's DeporLauVll Officer reviews the file before forwarding
len dation. to the approvmg official.
a detainee's request. with
Each recommendation addresses the individual's suitability for travel;
e.g.,.the kind of "U}''''' ""<Vll required.
Each escort includes~ tw~c~
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 comnletion of the trip.
Escorting officers have the discretion to increase or decrease minimum
restraints in accordance with written procedures and classification
level of the detainee.
Escort officers are precluded from accepting gifts/gratuities from a
or detainee's relative or friend for any reason.
officers ensure that detainees:
• Conduct themselves in a manner that does not bring discredit to
the ICE;
Do
not violate federal, state, or local laws;
•
Do
not purchase, possess, use, consume, or administer narcotics,
•
other drugs, or intoxicants;
Make no unauthorized phone calls; and
• Know they are subject to search, urinalysis, breathalyzer, or
"ullljJClrable test upon return.
Standard procedure requires the immediate return to the facility of any
detainee who violates trip rules.

n
L...J

•

D ACCEPTABLE

D DEFICIENT

AT-RISK

D REPEAT FINDING

REMARKS:

b6,b7c

(A
/
11-19-09
b6,b7c
AUDITOR'S SIGNATURE / DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 20 of69

RECREATION
POLICY: IT IS ICE POLICY TO PROVIDE ACCESS TO RECREATIONAL PROGRAMS AND ACTIVITIES TO ALL ICE DEfAINEES, TO THE EXTENT
POSSIBLE, UNDER CONDITIONS OF SECURITY AND SUPERVISION THAT PROTECT THEIR SAFEfY AND WELFARE.

«;

~ _.",,<TS

C....
facilitYhas a recreation 1'1V.,U:Ull and facility.
A recreational specialist (for facilities with more than 350 A.
s)
tailors the 1l1Vb'am activities and offerings to the detainee nonulation
Regular maintenance keeps recreational facilities and equipment in good
condition.
The recreational specialist or trained equivalent supervises detainee
recreation workers.
The recreational specialist or trainee equivalent oversees recreation
1l1V¥,ramS for speci~l J, "" "in a units (SHU) and snecir,]-npprl" detainees.
DctYlVvllH; offer "prlp'ltary activities. e.g. board games, cards, tel~.
Outside activities are restricted to limited-contact sports.

YES
~

EaCh Op.tl'linpp, has the opportunity to participate in daily

IZI

IY1

l::::J

J...l

~inees have access to l<O"l1O<1UVll actiV1LI1O" outside the housing units
for at least one hour daily, 5 days a week.
Staff checks all items for damage and condition when equipment is
returned.
Staff ""nrllll't" searches of recreation areas before~nd after ~e.
Alllt::l.'It::<111Ull areas under "on"tl'lnt staff "UJJt::1 VIMUll.
Supervising staff is equipped with radios.
The facility provides detainees in the SHU at least one hour of outdoor
recreation time daily, five times per week.
Detainees in disciplinary/administrative segregation receive a written
pvnl"n"tion when a panel revokes hislher recreation pnvileges.
JJlugrams or relio;"",, ct\;UVIUt::S are available to rlptl'linpp"
olunteers 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 v
LIS.
,-,
• ".,. " .. uu.... is u ..". "u, check this box. No Iurtner Imor
If the facility has no outside recreation, are detainees considered for
transfer after six months?
• If yes, written procedures ensure timely review of all eligible
detainees.
Case officers make written transfer recommendations about every sixmonth detainee to the Ole.
TheOlC~
lLS all rlpt,,;npp-transfer rlp"i"i"n" whether~es or no-,The detainee's written decision for or against an offered transfer
documented in hislher A-file.
Staff n"tinp" the detainee's legal representative of hislher decision to
accepvdecline a transfer.
If
is available, the ICE Districts routinely review transfer
eli!!ibilitv for all detainees after 60 days.
The A-file of every detainee who is held more than 60 days without
access to recreation contains either a transfer-waiver signed by the
detainee, or the OIC's written determination of the detainee's
inpliqibility for transfer.
The detainee's legal representative is notified of the detainee's/OIC's
decision .

IZI
IZI

IZI

[J If

•

~ ACCEPTABLE

DDEFICIENT

lJ
lJ

Detainees are not assigned as
recreation workers.

Olltsioe acti' ..
at the facility.

[J
[J
Olltooor recreation not
provided at this facility.

The facility does not require
volunteers to sign a waiver of
liability.

...1

D REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 21 of69

are not offered

Recreation available only in
me nousm unItS.

. is__ ~~whe}!

D AT-RISK

REMARKS

lis'~
..]I
; uuen::u.

REMARKS:

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1-19-09

AUDITOR'S SIGNATURE / DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 22 of69

RELIGIOUS PRACTICES
POLICY: FACILITIES WILL PROVIDE ICE DEfAINEES OF ALL FAITHS WITH REASONABLE AND EQUITABLE OPPORTUNITIES TO P ARTICIP ATE
THE PRACTICES OF THEIR FAITH, LIMITED ONLY BY THE CONSTRAINTS OF SAFEfY, SECURITY, THE ORDERLY OPERATIONS OF THE
AND BUDGEfARY CONSIDERATIONS.

•
The facility accommodates recognized holy-day observances by:
• Providing special meals, consistent with dietary restrictions;
• Honoring fasting requirements;
• Facilitating religious services; and
restrictions.
is allowed religious items in hislher immediate

items.

represented by clergy may conduct their own
services within
allowances.
Detainees in the Special Management Unit are allowed to participate
in religious practices unless otherwise documented for the safety and
security of the facility.
~ ACCEPTABLE

D DEFICIENT

D
AT-RISK

The facility does not document
when a detainee is not allowed
to participate due to safety and
concerns.

D REPEAT FINDING

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/11-19-09

b AUDITOR SSIGNATURE/DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 23 of69

DETAINEE TELEPHONE ACCESS
POLICY: ALL FACILITIES HOUSING ICE DEYAINEES WILL PERMIT DEYAINEES' REASONABLE AND ROT ITT ART ,R ACCESS TO TELEPHONES.
RRMARKS

YES

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

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

The tacll1ty a,
,uaUUH momtors reparr progress and takes
appropriate measures to ensure that required repairs are begun
and completed timely.

[]

On 11117/09, the OIG phone number was
tested, and it was working.

The OIG phone number is operational at
this facility.

D
0

•

IllS

allowed access to telephones during established
facility waking hours.
Upon admittance, .J
are made aware of the facility's
telenhone access policy.
~ss rules_ are~ed in hom:incrJ.11lits.
The facility makes a reasonable effort to provide key
information to detainees in languages spoken by any significant
portion of the facility's nonnbtion
Telephones are provided at a minimum ratio of one telephone
per 25 detainees in the facility population.

D
are afforded a reasonable degree ofprivacy 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 noncollect (special access) calls.
~ Acc", ,011, Me at no ,hMge to the .p'"in~o

OIG phone number for reporting abuse is programmed into
detainee phone system and the phone number was checked
by the im:np.doT during the review.
In facilities unable to fully meet this requirement initially
because of limitations of its telephone service, ICE makes
alternate arrangements to provide required access within 24
hours of a req~ 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 List".
Special arrangements are made to allow detainees to speak by
telephone with an immediate family member detained in another
Facility.
Any tel enh one restrictions are documented.
The facility has a system for taking and delivering emergency
detainee telephone messages.

D
0

Emergency phone call messages are immediately given to
detainees.

np.tainpp" are allowed to return emergency phone calls as soon
as no""ihl p
Detainees in disciplinary segregation are allowed phone calls
relating to the detainee's immigration case or other legal matters,
indmlincr consultation calls.
n
disciplinary segregation are allowed phone calls to
r.on"nlarlembassyofficials.
in disciplinary segregation are allowed phone calls for
.emergencies.
n,
in administrative ;l,
and 1-'1 UL"',",U '''' custody are

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 24 of69

DETAINEE TELEPHONE ACCESS
POLICY: ALL FACILITIES HOUSING ICE DETAINEES WILL PERMIT DETAINEES' REASONABLE AND

the same telephone privileges as those in general
When detainee phone calls are monitored, notification is posted
by detainee telephones that phone calls made by the detainees
be monitored.
. Access calls are not monitored.
~ ACCEPTABLE

b6,b7c

D DEFICIENT

D
AT-RISK

D
D REPEAT FINDING

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11-19-09
~ AUDITOR S SIGNATURE / DATE

•

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Page 25 of69

VISITATION
POLICY:

ICE SHALL PERMIT DETAINEES TO VISIT WITH FAMILY, FRIENDS, LEGAL REPRESENTATIVES, SPECIAL INTEREST GROUPS, AND

€:NEWS MEDIA.
COMlru1'IJ!,1'lI:!l

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

_YES

RRMARKS

The visitation schedule and rules are available to the public.

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

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

A general visitation log is maintained.

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

IL>I

The requirement on visitation by minors is complied with.

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

Minors are allowed to visit.

LV LU" J!UUU",
Ul""'" "vu" ", a
Visitors are searched and identified according to standard
requirements.
~ V1MlUI

e,m

After that time, on request, ICE considers a transfer, when
possible, to a facility that will allow minor visitation. At a
monthly visits are allowed.
1P.P.>l in special housing are afforded visitation.

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

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

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

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

The decision to permit or deny a tour is not delegated below
the level ofField Office Director.

Private consultation rooms are available for attorney meetings.
There is a mechanism for the detainee and hislher
'''J!' """HLaLIVe to ex ch lin !1e documents.
Ires governing detainee
The~ are written
When strip searches are required after every contact visit with a
legal representative, the facility provides an option for noncontact visits with legal, "J!'
~es.
Prior to each visit, legal service providers and assistants are
identified per the standard.

Provi~i()m

~'"'

for NGO visitation, as stated in the Detention

ace eomplied mil>.
enforcement officials who request to visit with a detainee
are referred to the ICE Field Office for approval.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 26 of69

VISITATION
POLICY: ICE SHALL PERMIT DETAINEES TO VISIT WITH FAMILY, FRIENDS, LEGAL REPRESENTATIVES, SPECIAL INTEREST GROUPS, AND
THE NEWS MEDIA.

detainees or aliens in proceedings, requesting to visit
~i1 a detainee, are referred to the OIC or ICE Field Office.
Procedures are in place, consistent with the detention standard,
for examinations by independent medical service providers and
experts.

rgJ ACCEPT ABLE

D DEFICIENT

rgJ

AT-RISK

Ifrequested, this would be addressed by ICE
staff. However, neither ICE staff nor
facility staff could ever recall this u~fring;

D REPEAT FINDING

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{ AUDITOR' SIGNATURE/DATE

•

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Page 27 of69

VOLUNTARY WORK PROGRAM
POLICY: IN EVERY FACILITY OFFERING A VOLUNTARY WORK PROGRAM, ICE DETAINEES WILL HAVE THE OPPORTUNITY TO WORK AND
MONEY BY PARTICIPATING. WHILE NOT LEGALLY REQUIRED, ICE AFFORDS DETAINEE WORKERS BASIC OCCUPATIONAL SAFETY
HEALTH ADMINISTRATION (OSHA) PROTECTIONS.

~ CHECK HERE IF ICE DETAINEES ARE NOT AUTHORIZED TO WORK AT THE IGSA FACILITY. MARK NA ON FORM G-324A, PAGE

3 AND MOVE TO NEXT SECTION.
0

ml'lT~

Does the facility have a voluntary work program?
Do ICE detainees participate?
r
111 meets neatness and cleanliness
is.
: hot
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 I'iv5HUU.
Where possible, physically and mentally challenged detainees
}laH~"~}lat'" in the }II VIOl atu.
The facility comnlies with work-hour requirements for ~
not
exceeding:
• Eight hours a day and Forty hours a week.
Detmnee volunteers generally work according to fixed schedule.
If 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 !-'IVb laU1.
The voluntary work program meets:
• OSHA, NFPA, ACA standards
staff screen and formally certify detainee food service

•

[I;.

• Before the assignment begins; and
As a matter of written }II
r
receIve safety equipment! training sufficient for the
assi!1TIment.
Proper procedure is followed when an ICE detainee is injured on the
job.

YES

RRMARKS

Detainees can work in janitorial

[gJ

[]

[gJ

!2$]

[gJ

m~~i

Detainees are not assigned to
work in the food services area.

•

[gJ ACCEPT ABLE

D DEFICIENT

AT-RISK

D REPEAT FINDING

REMARKS:

b6,b7c

b6,b7c
/ 11-19-09
, AUDITOR'S SIGNATURE / DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 28 of69

•
SECTION II

HEALTH SERVICES STANDARDS

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 29 of69

HUNGER STRIKES

CTNFFS

ALL FACILITIES WILL FOLLOW STANDARD GUIDELINES FOR THE MEDICAL AND ADMINISTRATIVE MANAGEMENT OF ICE
ENGAGING IN HUNGER STRIKES. By MONITORING OF THE HEALTH AND WELFARE OF THE INDIVIDUAL DETAINEES, FACILITIES
STRIVE TO SUSTAIN THEIR LIVES.

POLICY:

COMPONENTS

YES

When a detainee has refused food for 72 hours, it is standard practice
for staff to refer him/her to the medical department.
CDFs and IGSAs immediately report a hunger strike to the ICE.
The facility has established procedures to ensure staff respond
immediately to a hunger strike.

REMARKS

The Hunger Strike Protocol requires
that any detainee refusing food is
referred to the medical dtpuitment.
The local ICE officer reports all
hunger strikes to DHS.
The Hunger Strike Protocol
addresses this issue.

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

The Hunger Strike Protocol does not
require isolation of a hunger striker.

staif records the weight and vital signs of a hunger-striking
detamee at least once every 24 hours.

The OlC of the facility obtains a hunger strikers consent before
medical treatment.

The Hunger Strike Protocol does not
address housing considerations.
lhe Hunger StrIke ~ lULUvUl md1Cates
that medical staff are to assess the
detainee every 2-3 days.
Medical consent is assumed and
written consent is only obtained for
invasive or dental
A review of the file of a recent
hunger striker indicated this policy
was not followed.
Meals are y" •• ~y~ based on the
facility routine. Formal
documentation is not required by
current facility policy.
This is not required by policy and
has not been noted in medical
records. No restrictions have been
placed on hunger strikers. As a
result, they have the same access to
water and other beverages as before
starting a hunger strike.
The removal of food is not required
by policy or procedure.
The Hunger Strike Observation
Record and Clinical Assessment
form is completed and frequently
reflects meals eaten or missed.
However, these records are not
r.()mnlptpo on a daily basis.
The Hunger Strike Protocol
addresses this issue.
Staff does not document all
treatment attempts.
According to the supervising nurse,
medical staff has not received
specialized training regarding hunger
strikes.

Mpo.ir.ll

lrp~

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

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

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

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

Staff maintains the hunger strikers supply of drinking water/other
beverages.

During a hunger strike, staff removes all food items from the hunger
strikers living area.
Staff is directed to record the hunger strikers fluid intake and food
consumption; Does staff always use Hunger Strike Monitoring Form 1839 or similar IGSA form.

i
I

The medical staffhas written procedures for treating hunger strikers.

D ACCEPTABLE

~ DEFICIENT

AT-RISK

D REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 30 of69

REMARKS:

The facility Hunger Strike Protocol does not comply with the NDS regarding hunger strikes. The facility protocol reflects the
procedures implemented by the local psychiatrist. In specific, detainees on a hunger strike are not isolated and access to food is not
.estricted. Medical follow-up occurs every 2-3 days or "as may be needed" due to any medical issue that arises.
The Hunger Strike Protocol was re-written during the inspection to reflect the NDS requirements for ICE detainees. All prior policies
and procedures will continue to apply to non-ICE detainees. It should be noted that, at the time of the inspection, the revised Hunger
Strike Protocol for ICE detainees had not been approved by jail administrators nor had it been signed-off on by the local psychiatrist.
b6,b7c

b6,b7c

III-J9-09

bAUDITOR'S SIGNATURE / DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 31 of69

ACCESS TO MEDICAL CARE

•

POLICY: EVERY FACILITY WILL ESTABLISH AND MAINTAIN
THE GENERAL WELL-BEING OF ICE DETAINEES.

COMPONENTS

YES

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

REMARKS

The facility has access to a PHS/DlHS Managed Health Care
Coordinator.
The medical staff is large enough to provide, examine, and
treat the facility's detainee population.

The facility has sufficient space and equipment to afford
detainee privacy when receiving health care.
The medical facility has its own restricted-access area. The
restricted access area is located within the confines of the
secure perimeter.
The medical facility entrance includes a holding/waiting
room.

The medical unit is located within a
secure perimeter with restricted access.

The medical facility's holding/waiting room is under the
direct supervision of custodial staff.

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

Medical screening includes a Tuberculosis (TB) test.
• Every arriving detainee receives a TB test during the
admission process;
• Detainee's TB-screening does not occur more than
one business day after hislher arrival at the facility;
and
• Detainees not screened are housed separate from the
general population.

•

The facility medical staff are public
health service employees. All of the
staff have current and appropriate
licenses.
Correctional officers complete a
medical screening at the time of intake.
Sick call slips are available in all of the
housing units. The nursing staff collects
the sick call slips on a daily basis.
The facility utilizes the Treatment
Authorization Request to contact PHS.
The facility has medical staff on-site
seven days a week, twenty-four hours
per day.
The facility has a fully equipped health
care unit with two exam rooms.

The facility's in-processing procedures for arriving detainees
include medical screening.
All detainees have access to and receive medical care.

•

ACCREDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR

The holding room is contained within
the medical unit. Detainees are brought
in one-at-a-time for evaluations.
Detainees in the waiting area are under
the direct supervision of a correctional
officer.
A drinking fountain is in the waiting
room.
Inactive medical records are stored in
an office within the medical unit.
Active medical records are kept in
unlocked file cabinets within the
"secure" medical unit.
The pharmacy is located behind a
locked door. Medications are
dispensed from medication carts.
All TB tests are performed within a day
of admittance except for those
detainees that arrive late on Friday.
Those that arrive late on Friday receive
the test on Monday and are housed in
general population. Upon arrival,
temperatures of all detainees are taken.
Verbal assessments are utilized to
assess the possibility of active TB.
Any individuals who are of concern
receive a chest X-ray. Seventeen charts
were reviewed. It was noted that
screening had occurred within one day.
Screening of a detainee who arrived on
Friday was completed on Monday.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 32 of69

All detainees receive a mental-health screening upon arrival.
It is conducted:
• By a health care provider or specially trained officer;
and
to a
unit.
• Before a detainee's
The facility health care provider promptly reviews all 1-794s
(or equivalent) to identify detainees needing medical
attention.

The health care provider physically examines/assesses
arriving detainees within 14 days of admission/arrival at the

Mental health screening is conducted
by a specially trained correctional
officer as part of the initial screening
process.
Initial intake information is recorded on
forms which are computerized. The
forms are printed out at the nurse's
station. Any "yes" responses which
indicate a medical issue receive
immediate attention.
A review of seventeen charts indicated
the physicals had been completed in a

in the Special Management Unit have access to

Staff provides detainees with health services (sick call)
request slips daily, upon request.
•
Request slips are available in languages other than
English, including every language spoken by a
sizeable number of the facility's detainee population.
•
Service-request slips are delivered in a timely
fashion to the health care
The facility has a written plan for 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
uired.
The plan includes an on-call provider.
The plan includes a list of telephone numbers for local
ambulance and hospital services.
The plan includes procedures for facility
health care consistent with
Detention staff is trained to respond to
emergencies within a 4-minute response time.

this

Sick call slips are available and they
are collected daily by nursing staff and
reviewed regularly for disposition.
However sick call slips are only written
in English.

Policy 5.10, Emergency Health Care
Ancillary Services, covers this issue.

A list of all on-call providers is
available at all staff
There are several hospitals and trauma
centers in the local area. They are
accessed
911.
This standard not met by the current

•

staff is used to distribute medication, a health care
trains these officers.
The medical unit keeps written records of medication that is
distributed.

available to all detainees,
those in Special Management Unit.
Requests are submitted to the housing
unit officer who gives it to the nurse,
daily. This process was observed
during a nurse's visit to a pod to pass
out medication.

D
D

Most staff are trained in CPR/AED.
Not all staff are trained in first aid since
there is 24-hour medical coverage.
Due to the size of the facility and since
all housing units are accessed via an
elevator, it is unlikely medical
responses occur in four minutes.
Only medical staff administer
medications .
Medication Administration Records
are utilized to document the medication
that has been distributed.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 33 of69

•

-ul<;'

The Form 1-819 (or IGSA equivalent) is used to notify the
Warden/Facility of a detainee that has special medical needs.

A signed and dated consent form is obtained from a detainee
before medical treatment is administered.
Detainees use the 1-813 (or IGSA equivalent) to authorize the
release of confidential medical records to outside sources.
The facility health care provider is given advance notice prior
to the release, transfer, or removal of a detainee.
Detainee's medical records or a copy thereof, are available
and transferred with the detainee.
Medical records are placed in a sealed envelope or other
container labeled with the detainee's name and A-number and
marked "MEDICAL CONFIDENTIAL".

When a special needs detainee arrives,
a Shift Activity Report is generated
from the initial interview. This form is
delivered to .ail administrators.
Consent is assumed unless invasive
treatment occurs.
The Minnesota Release of Information
form is utilized in all cases.
ICE regularly notifies the detention
center of all im endin transfers.
Medical records are transferred with all
detainees.
A sealed manila folder marked
"Medical Confidential," is utilized for
all transfers.

REMARKS:

The facility has a small self-contained medical unit that has full time medical coverage. A physician, nurse practitioner, psychiatrist,
and dentist are available on a weekly basis. RN's and Certified Medical Assistants are available 24 hours per day, seven days a week.
The unit provides adequate medical care. Any unusual or specialized treatment is provided at the local hospitals .
b6,b7c
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 34 of69

Every new staff member receives suicide-prevention training. Suicideprevention training occurs during the employee orientation program.

Training prepares staff to:
• Recognize potentially suicidal behavior;
• Refer potentially suicidal detainees, following facility
procedures; and
• Understand and
A health-care provider or specially trained officer screens all detainees
for suicide potential as part of the admission process.
• Screening does not occur later than one working day after the
Written procedures cover when and how to refer at-risk detainees to
medical staff and
are followed.
The facility has a designated isolation room for evaluation and
treatment.

The designated isolation room does not contain any structures or
smaller items that could be used in a suicide attempt.
staff has approved the room for this purpose.

Staff observes and documents the status of a suicide-watch detainee at
least once every 15 minutes.

[gI ACCEPTABLE

DDEFICIENT

Medical staff provide suicide
identification and prevention training
during the employee orientation

The curriculum was reviewed and it
was noted that these topics are
covered.

A mental health screening conducted
by a specially trained correctional
officer is a part of the initial intake.

AT-RISK

Policy 19.55, Suicide Assessment
and Preventio covers this issue.
The cells in housing units SA and 5B
have been designated for suicidal
detainees. These are standard cells
located on the male and female
Suicidal detainees are issued Kevlar
smocks after all clothing has been
removed.
The medical staff have not formally
inspected the rooms and designated
them as suicide rooms.
The current policy calls for
observation within 15-20 minutes.
Staff reported that checks are usually
15 minutes.
D REPEAT FINDING

REMARKS:

The current suicide prevention and intervention program is acceptable. It is recommended that policies be revised to more accurately
reflect the procedures followed during a suicide watch.
The Suicide Assessment and Prevention Policy was changed to reflect the need for 15-minute watches. At the time of the inspection,
the policy had not yet been signed off on by the medical staff.
b6,b7c

b6,b7c

Ph.D.

11-19-09

AUDITOR'S SIGNATURE / DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 35 of69

Detainees who are chronically or terminally ill are transferred to an appropriate
offsite medical facility.

The facility or appropriate ICE office promptly notifies the next of kin of the
detainee's medical condition, to include:
• The detainee's location; and
The limitations
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
wishes to
another to make advance decisions for him or her.
The guidelines provide the detainee the opportunity to have a private attorney
prepare the documents.
There is a policy addressing "Do Not Resuscitate Orders"

with a "Do Not Resuscitate" order in the medical record receive
therapeutic efforts short of resuscitation?

;'""UH"",,_"

HUf"H~U~

The facility notifies the DIHS Medical Director and Headquarters' Legal
Counsel of the name and basic circumstances of any detainee with a "Do Not
Resuscitate" order in the medical record. In the case of IGSAs, this notification
is made
the local ICE TP.T1TP'<f'ntllttvf'
The facility has written procedures to address the issues of organ donation by
detainees.
The facility has written procedures to notify ICE officials, deceased family
members and consulates, when a detainee dies while in Service.

The facility has a policy and procedure to address the death of a detainee while
in transport.

At all ICE locations the detainee's remains disposed of in accordance with the
provisions detailed in this standard.

In the event that neither family nor consulate claims the remains, the Field
Office schedules an indigent's burial, consistent with local procedures.
• If the detainee's is a U.S. military veteran, is the Department of
Veterans Affairs notified?

The facility transfers all
terminally ill detainees to an
appropriate medical setting.

accepted at this facility.
Detainees requiring this will
be transferred.
Terminally ill detainees are
not accepted.
Detainees having "Do Not
Resuscitate Orders" are not
at this

Detainees having "Do Not
Resuscitate Orders" are not
accepted at this facility.

No organ donation
procedure exists for this
faci
The facility has no written
policy regarding any
detainee death that may
occur.
ICE staff is responsible for
all transports. The facility
has no written policy
regarding any detainee
death that
occur.
The facility has no written
policy regarding any
detainee death that may
occur.
There have been no
detainee deaths at the
facility. The facility has no
written policy regarding any
detainee death that may
occur.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 36 of69

An original or certified copy of a detainee's death certificate is placed in the
subject's a-file.

The facility follows established policy and procedures describing when to
contact the local coroner regarding such issues as:
Who will perform the autopsy;
Obtaining state approved death certificates; and
Local
of the bo
ICE staff follows established procedures to properly close the case of a
deceased detainee.

The facility does not have a

•
•
•

~ ACCEPTABLE

o DEFICIENT

OAT-RISK

detainee deaths at the
facility. The facility has no
written policy regarding any
detainee death that may
occur.

addresses this standard.

There have been no
detainee deaths.

o REPEAT FINDING

REMARKS:

.here have been no detainee deaths at this facility. All seriously ill detainees are transferred to a more appropriate setting. Policies do
not currently exist which identify the procedures to be followed if a death occurs in the facility or during emergency medical transport.
Staff advised that a policy is being developed.
b6,b7c

-<I
b

b6,b7c

11-19-09

AUDITOR'S S GNATURE / DATE

•

FOR OFHCIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 37 of 69

•

SECTION III

•

SECURITY AND CONTROL STANDARDS

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 38 of69

CONTRABAND
POLICY: ALL DETENTION FACILITIES WILL ENSURE THE PROPER HANDLING AND DISPOSAL OF ALL CONTRABAND. DoCUMENTATION OF
CONTRABAND DESTRUCTION IS RFomRFO.

facility follows a written procedure for handling illegal
contraband. Staff inventory, hold, and report it when necessary to the
proper tluthUllLY for ~~"ihlp. seizure.
Contmh:mcl that is government property is retained as evidence for
11 cli"~mlmm:y action or criminal PIU"C\';UL~Ull
Staff returns property not needed as evidence to the proper authority.
Written procedures cover the return of such property.

o
o
o
o
o
o

Altered property is destroyed following documentation and using
established p'V"'IOduHO".
Before confiscating religious items, the Ole or designated investigator
contacts a religious authority.
Staff follows written procedures when destroying hard contraband that
is illegal.
Hard contraband that
illegal (under ~rimiml1 statutes) may be
and used tor OrnCIal use, e.g. trammg purposes.
If yes, under specific circumstances and using specified written
procedures. Hard contraband is secured when not in use.

l1OWllllOU

~ ACCEPTABLE

DEFICIENT

OAT-RISK

o
o
o
o
o
o
o
o

FlI~ilitv noli~" clOp." not address
the issu~ of hard contraband
being utilized for official use.

REPEAT FINDING

REMARKS:

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 39 of69

DETENTION FILES
POLICY: EVERY FACILITY WILL CREATE A DETENTION FILE FOR EVERY ICE DETAINEE BOOKED INTO THE FACILITY, EXCLUDING ONLY
AINEES SCHEDULED TO DEPART WITHIN 24 HOURS. THE DETENTION FILE WILL CONTAIN COPIES AND, IN SOME CASES, THE ORIGINAL
SPECIFIED DOCUMENTS CONCERNING THE DETAINEE'S STAY IN THE FACILITY: CLASSIFICATION SHEET, MEDICAL QUESTIONNAIRE,
ETC.

A detention file is created for every new arrival whose stay will
exceed 24 hours.
originals or copies of
The detainee detention file
documentation and forms
the admissions
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
•
and the

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.
closing
detention file makes a notation that the file
The
and
be archived.
copies and sends documents from the file when
requested by supervisory personnel at the receiving facility
or office.
Appropriate staff has access to the detention
and other
departmental requests are accommodated by making a request for
the file. Each file is properly logged out and in by a representative
ofthe
t.

Grievances are not kept in detainee
files.

secure control center. A computer
file is also maintained.

Files are allowed to be removed from
the secured area. All uniformed staff
have access to files.

b6,b7c
b6,b7c

t AUDITOR'

•

/11-19-09
SIGNATURE/DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 40 of69

DISCIPLINARY POLICY
POLICY: ALL FACILITIES HOUSING ICE DETAINEES ARE AUfHORIZED TO IMPOSE DISCIPLINE ON DETAINEES WHOSE BEHAVIOR IS NOT IN

COMPLIANCE WITH FACILITY RULES AND REGULATIONS.

iENTIS

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
orre~~ry.

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 ofnhv";",,,l exercise
-'.
Th", nil",,, _of ,,()nihld
for violations are
1" and
defined in writing and communicated to all detainees verbally and in
writing.
The following items are conspicuously posted in Spanish and English,
and other dominate languages used in the facility:
• Rights and Responsibilities
• Prohibited Acts
• Disciplinary Severity Scale
• Sanctions
When minor rule violations or prohibited acts occur, informal
resolutions are vm;~raged __
and Notice of Charges are promptly forwarded to the
lated supervisor.
Incident reports are investigated within 24 hours of the incident. The
Unit Disciplinary Committee (UDC) or equivalent does not convene
before an investigation ends.
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
theUDC;
• Considers written reports, statements, physical evidence, and
oral testimony;
• Hears pleadings by detainees and staff representatives;
• Bases its findings on the preponderance of evidence; and
only authorized sanctions
• T.
A staff HO!'" ltative is available if requested for a detainee facing a
cii""inlinary heilrimr.
The facility permits hearing postponements or continuances when
conditions warrant such a continuance. Reasons are documented.
The duration of punishment set by the OIC, as recommended by the
disciplinary panel, does not exceed established sanctions. The
maximum time in disciplinary segregation is limited to 60 days for a
single offense.
Written procedures govern the handling of confidential-informant
.f'r LH1<1L~VH.
Standards include criteria for recognizing "substantial

e::

YES

irl",,,,,,,,"

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 41 of69

R .....MARKS

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

committee/panel
OAT-RISK

o
o

REPEAT FINDING

REMARKS:

The facility has a comprehensive disciplinary policy. A disciplinary hearing, observed during the inspection, was conducted in a
thorough and professional manner.
b6,b7c
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 42 of69

EMERGENCY (CONTINGENCY) PLANS
POLICY ALL FACILITIES HOLDING ICE DETAINEES WILL RESPOND TO EMERGENCIES WITH A PREDETERMINED STANDARDIZED PLAN TO

.;RR~

THE HARMING OF HUMAN LIFE AND THE DESTRUCTION OF PROPERTY. IT IS RECOMMENDED THAT SPCS AND CDFs ENTER INTO
VIA MEMORANDUM OF UNDERSTANDING (MOU), WITH FEDERAL, LOCAL AND STATE AGENCIES TO ASSIST IN TIMES OF
;y

C01VlrV1'l1'.1'I ,.,

YES

Policy precludes detainees or detainee groups from exercising control
or authority over other detainees.

L2SJ

Detainees are protected from:
• Personal abuse
• Corporal punishment
• Personal injury
• Disease
• Property damage
• Harassment from other detainees
Staff is trained to identify signs of detainee unrest.
• What type of training and how often?

~ .• +'1'

.l'l'r

~,~..

,1,

;n"t",~

£.

'An An

f'",..,

,~,,,t,

r/",t, ;n

and m~ to the Officer In Charge (Ole)
There is a designated person or persons responsible for emergency
plans and their implementation. Sufficient time is allotted to the person
or group for u<:;v'-'
lPnt and' ,1.
ltMi()n of the pla~
The plans address the following issues:
• Confidentiality
• Accountability (copies and storage locations)
• Annual review procedures and schedule
Revisions
.~~
plans include a comprehensive general section with
lVV,,-rU'''''' applicable to most emergency situations.
Mtit11rlP"

The issues of confidentiality,
accountability, annual reviews,
and revisions are not addressed
in the current facility policy.

The current facility policy does
not include a comprehensive
general section.

•

The facility has cooperative contingency plans with applicable:
• Local law enforcement agencies
State agencies
Federal a!!encies
All staff receives copies of Hostage Situation Management policy and

•
•

1-'1

lrp"

Staff is trained to disregard instructions from hostages, regardless of
rank. Within 24 hours after release, hostages are screened for medical
and psych()1mr ica1 effects.
Emergency plans include emergency medical treatment for staff and
detainf~e" during and after an incident.
Food service maintains at least 3 days' worth of emergency meals for
staff and detainees.
Written plans identify locations of shut-off valves and switches for all
utilities (water, gas, electric).

•

RF.MARKS

The current facility policy does
not identify locations of shut
off valves and switches for all
utilities .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 43 of69

Written procedures cover:
• WorkIFood Strike
• Disturbances
• Escapes
• Bomb Threats
• Adverse Weather
• Internal Searches
• Facility Evacuation
• Detainee Transportation System Plan
• Internal Hostages
• Civil Disturbances

REPEAT FINDING

REMARKS:

It is recommended that the facility consider revising current emergency plans to address the deficiencies noted. This will enhance
staff response to emergencies and comply with the NDS regarding Emergency (Contingency) Plans.
b6,b7c

b6,b7c

_UDITOR'S

•

11-19-09
IGNATURE! DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 44 of69

ENVIRONMENTAL HEALTH AND SAFETY
EVERY FACILITY WILL CONTROL FLAMMABLE, TOXIC, AND CAUSTIC MATERIALS THROUGH A HAZARDOUS MATERIALS
AM THE PROGRAM WILL INCLUDE, AMONG OTHER THINGS, THE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN
IANf'F WITH APPLICABLE STANDARDS (E.G., NATIONAL FIRE PROTECTION ASSOCIATION [NFPA]); IDENTIFICATION OF
"ThTf'OMPJ\TffiLE MATERIALS. AND SAFE-HANDLING PROCEDURES
0
RRMARKS
II!;
YES
No
NA
The facility provides cleaning
The facility has a system for storing, issuing, and maintaining
inventories of hazardous materials.
services through a private
contractual vendor. Two
cleaning storage closets were
D
!Xl
D inspected. Numerous containers
and aerosol spray cans were
identified. Inventories were not
maintained in the areas.
Constant inventories are maintained for all tlammahle. toxic, and
!Xl
D
D
caustic substances used/stored in each section of the facility.
The manufacturer's Material Safety Data Sheet (MSDS) file is up-todate for every hazardous substance used.
• 1 ne Illes nSf all sIorage areas, i:UIU 1l1\.OlUUC a 1-'1(111L ula):;l alll
!Xl
0
0
and legend.
• The MSDSs and other information in the files are available to
pdsonnel manallinll the facility's safety pWbHUH.
All personnel using flammable, toxic, and/or caustic substances follow
the prescribed procedures. They:
D
D
!Xl
• Wear personal protective equipment; and
• Report hazards and spills to the designated official.
rk areas.
The MSDSs are readily "''''~~"ihle staff and detainees in
!Xl
D
D
POLICY:

•

Hazardous materials are always issued under proper supervision .
• Quantities are limited; and
• Staff always "UP"" "",-," detainees using these substances.
All "flammable" and ""mllbustible" materials (liquid and aerosol) are
stored and used a\.O\.Ourding to label l'
l~nillltion~
Lighting fixtures and electrical equipment installed in storage rooms
and other hazardous areas meet National Electrical Code requirements.
The facility has sufficient ventilation, and provides and ensures clean
air exchanges throughout all buildings.
"onilitionillg ducts are not blocked or
Vents return vents, and
obstructed in cells or anywhere in the facility.
Living units are maintained at appropriate temperatures in accordance
with industry standards. (68 to 74 degrees in the winter and 72 to 78
degrees in the summer.)
Shower and sink water temperatures do not exceed the industry
standard of 120 dtgrtoc".
All toxic and caustic materials are stored in their original containers in
a secure area.

Excess flammables, combustibles, and toxic liquids are disposed of
jJlupcuyand in accordance with MSDSs.
Staff directly supervise and account for products with methyl alcohol.
Staff receives a list of products containing diluted methyl alcohol, e.g.,
shoe dye. All such products are clearly labeled. "Accountability"
includes issuing such products to detainees in the smallest workable
quantities.
~PlOyee and detainee wUng flammable, toxk,
cau,t;,
receives advance training in their use,~age, and ili~no~" 1

!Xl

Contents of spray bottles in
areas were not properly
identified.

No methyl alcohol is stored in
the facility.

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
Page 45 of69

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
\Cr.OROANCF. WITH APPLICABLE STANDARDS (E.G., NATIONAL FIRE PROTECTION ASSOCIATION [NFPA]); IDENTIFICATION OF
'ATIDLE MATF.RIAT"~ AND SAFE-HANDLING PROCEDURES
("".
REMARKS
I'IIEl'Il~
YES
No
NA
The facility complies with the most current edition of applicable
codes, standards, and regulations of the National Fire Protection
~
0
0
Association and the Occupational Safety and Health Administration
(OSHA).
A technically qualified officer conducts the fire and safety inspections.
Fire alarm and sprinkler
inspections have been
contracted to a private vendor.
0
~
0
Other fire and safety duties have
been assigned to three
unqualified employees.
files of insnection reports.
The Safety Office (or officer)
~
LJ
lJ
The facility has an approved fire prevention, control, and evacuation

~
The plan requITes:
• Monthly fire inspections;
• Fire protection equipment strategically located throughout the
facility;
• Public posting of emergency plans with accessible
building/room floor plans;
• Exit signs and directional arrows; and
• An area-specific exit diagram conspicuously posted in the
diagrammed area.
Fire drills are conducted and documented monthly.

sanitation program covers barbering operations.

The barber shop 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.
Standard cleaning practices include:
• Using specified equipment; cleansers; disinfectants and
detergents.
• An established schedule of cleaning and follow-up

Fire inspections are conducted
on a quarterly basis.
Fire protection equipment is
located throughout the facility.

Fire drills are conducted on a
lj Utll Lcdy basis.
Barber services are conducted in
a multipurpose room adjacent to
the hom:imr unit.
No area has been specifically
designated nor equipped to
serve as a barber shop.
The facility operates an informal
barbering program. Sanitation
standards are not posted.
The health care unit practices
proper disposal of needles and
other sharp objects. However,
written procedures were not in
place at the initiation of this
inspection. During the
inspection, a policy was created
to correct this issue and
·rI. rI on 11-19-09.
Ladles, spoons and spatulas in
the kitchen are not inventoried,
nor stored in a secured area.

;n.-

facility follows standard cleaning procedures.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 46 of69

A licensed medical waste contractor disposes of infectiouslbiohazardous waste.
Staff is
to prevent contact with blood and other body fluids and
written
are followed.
Do the methods for handling/disposing of refuse meet all regulatory
uirements?
A licensed/Certifiedffrained pest-control professional inspects for
rodents, insects, and vermin.
• At least monthly.
• The pest-control program includes preventative spraying for
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

ACCEPTABLE

DEFICIENT

OAT-RISK

Emergency power generators
are tested on a monthly basis.

o REPEAT FINDING

~MARKS:
Although a number of concerns have been identified and are noted, the facility is clean, well organized, and lacks general hazards. It
is recommended that facility policy and practice be reviewed and modified to address the concerns noted. Staff advised that the
process of inventorying cleaning supplies is being modified. Toxic and harmful materials are being eliminated or minimized and
being replaced with equipment designed to dispense non-toxic, environmentally safe, cleaning solutions in controlled volumes.
b6,b7c

b6,b7c

11-19-09

UAUDITOR'S SIGNATURE I DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 47 of69

HOLD ROOMS IN DETENTION FACILITIES
POLICY: HOLD ROOMS WILL BE USED ONLY FOR TEMPORARY DETENTION OF DETAINEES AWAITING REMOVAL, TRANSFER, EOIR

beds, or other related make-shift sleeping apparatus are
use inside hold rooms.
and ceilings of the hold rooms are tamper and escape

is a written evacuation plan that includes a designated officer
to remove detainees from hold rooms in case of fire andlor building
evacuation.
An appropriate emergency service is called immediately upon a
determination that a medical
exist.
~ ACCEPT ABLE

DEFICIENT

o
o
o

o
OAT-RISK

o REPEAT FINDING

REMARKS:

The hold rooms in the facility are located in the Intake/Reception area. There are an adequate number of hold rooms which are well
lighted, clean, and under constant staff supervision .
b6,b7c
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 48 of69

KEY AND LOCK CONTROL

(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
IT IS THE POLICY OF THE ICE SERVICE TO MAINTAIN AN EFFICIENT SYSTEM FOR THE USE, ACCOUNTABILITY AND MAINTENANCE
. ALL KEYS AND LOCKS.
(

m~,

The security officer[s], or equivalent in IGSAs, has attended an
approved locksmith training l'wyaHl.
The security officer, or equivalent in IGSAs, has responsibly for all
administrative duties and IC/;jJuHsibilities 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 aU 1'1CV"HL~V" maintenance documentation.
Facility policies and procedures address the issue of compromised
keys and locks.
The security officer. or eaUlvalent in IGSAs. ~velops policy and
procedures to ensure safe combinations integrity.
Only dead bolt or dead lock functions are used in detainee accessible
areas.
Only authorized locks (as specified in the Detention Standard) are
used in detainee accessible areas.
Grand maste~ keying "J"'''W'' are prohibited.
All worn or discarded keys and locks are cut up and properly disposed
of
andlo; ,h,;o, "" pwhimtoo from u'" 00 ,ell d""".
entrance/exit door locks to detainee living quarters, or areas with
occupant load of 50 or more people, conform to:
• Occupational Safety and Environmental Health Manual, Ch.
3',
• National Fire Protection Association Life Safety Code 101.
The vl'""dtional keyboard is sufficient to accommodate all the facility
key rmgs, including keys III use, and is located in a secure area.
Procedures are in place to ensure that key rings are:
• Identifiable;
• The numbers of keys are cited; and
• Keys cannot be removed.
E:.u"rgency keys are availahle for all areas of the facility.
The facilitie~ use a key accountability system.
Authorization is nece~~llry to issue any 1 ""LU,",'''U 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.

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 immediatelv notified.

•

YES

IZl

[]

~
~

IZl

D
D
0

RF.MARKS

IHCIC iilC HU /;iiICS
inner perimeter.

lllC

All keys are not counted on a
daily basis. This component is
~necific to SPC's/CDF's.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 49 of69

Willilli

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
POLICY IT IS THE POLICY OF THE ICE SERVICE TO MAINTAIN AN EFFICIENT SYSTEM FOR THE USE, ACCOUNT ABILITY AND MAINTENANCE
ALL KEYS AND LOCKS.

•

Detainees are not pennitted to handle keys assigned to staff.

[gJ ACCEPT ABLE

D DEFICIENT

AT-RISK

D REPEAT FINDING

REMARKS:

Key rings are counted at the beginning and end of each shift. .
b6,b7c
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 50 of69

POPULATION COUNTS
POLICY: ALL DETENTION FACILITIES SHALL ENSURE AROUND-THE-CLOCK ACCOUNTABILITY FOR ALL DETAINEES. THIS REQUIRES THAT
CONDUCT AT LEAST ONE FORMAL COUNT OF THE DETAINEE POPULATION PER SHIFT, WITH ADDITIONAL FORMAL AND INFORMAL

rgJ ACCEPT ABLE

D DEFICIENT

AT-RISK

The 2:00 p.m. count was
observed in housing unit IB. It
was noted that the assigned
officer counted several
detainees who were underneath

D REPEAT FINDING

.MARKS:

Facility policy indicates that detainees must be standing inside hislher cell in plain view of the officer conducting the count.
Observation of a count conducted in housing unit IB noted that the officer did not require detainees to stand at their cell door.
Detainee wrist bands were not checked.
b6,b7c
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•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 51 of69

POST ORDERS
POLICY: ICE PROVIDES OFFICERS ALL NECESSARY GUIDANCE FOR CARRYING OUT THEIR DUTIES. THIS GUIDANCE INCLUDES THE POST
ESTABLISHED FOR EVERY POST, WHICH ARE REVIEWED AT LEAST ANNUALLY, AND GIVEN TO EACH OFFICER UPON ASSIGNMENT

order
The OlC or Contract / IGSA equivalent has signed and dated the last
page of every section.

Procedures keep post orders and logbooks secure from detainees at all
times.
Every
officer qualifies with the post weapon(s) before

o
o

Armed-post post orders provide instructions for escape attempts.

The facility does not have
armed

a log. The
~ ACCEPT ABLE

At the time of the inspection,
the Post Orders did not contain a
~llr,por'Ji ~r'r' S initials.

OAT-RISK

o
o

REPEAT FINDING

REMARKS:

The facility does not currently require a supervisor to sign or date the last page of each Post Order or subsequent changes. At the time
of the inspection, Post Orders were current and had recently been updated.
b6,b7c
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 52 of69

SECURITY INSPECTIONS
POLICY: POST ASSIGNMENTS IN THE FACILITY'S HIGH-RISK AREAS, WHERE SPECIAL SECURITY PROCEDURES MUST BE FOLLOWED, WILL
RESTRICTED TO EXPERIENCED PERSONNEL WITH A THOROUGH GROUNDING IN FACILITY OPERATIONS.
0
IEl'IT:S
YES
No
NA
The facility has a comprehensive security inspection policy. The
policy specifies:
• Posts to be inspected;
• Required inspection forms;
D
D
~
• Frequency of inspections;
• Guidelines for checking security features; and
• Procedures for reporting weak spots, inconsistencies, and
..l.t
other areas needin!! ;"111-'1'
Every officer is required to conduct a security check of hislher
~
D
D
fI!';!';iP11eci area. The results are documented.
D,
ltation of s"vuii',y in!';nectioTI!'; is kept on file.
~
D
D
Procedures ensure that recurring 1'1'1.
and a failure to take
~
D
D
corrective action are H01-'Vl '''u to the <11'1'I~1'11l1t\; manaQ"er.
The fron
officer checks the ID of "~ljOne \;11t\;lll1g or
1':/1
r1
II
lL::.I
L......J
L......J
exiting the facility.
All visits are officially recorded in a visitor logbook or electronically
recorded.
The facility has a secure visitor pass system.
Every Control Center officer receives speci(llizeci
The Control Center is staffed around the clock.
Policy restricts staff access to the Control Center.
n,
are restricted from access to the Control Center.
r,
icflti()n!'; are centralized in the Control Center.
~ monitor all vehicular traffic entering and leaving the facility.
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; and
• Name of employee responsihle for the vehicle during the visit
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
,pnt!';
Tools being taken into the
area of the facility are inventoried
before~rin~ and prior to di;;1-'<1!tUl\;.
The SMU entrance has a sally port.
Written procedures govern searches of detainee housing units and
J'ers~ areas.
Housing area "C<11 ehc" occur at irregular times.
Every search of the SMU and other hOll!';tnP units IS
Storage and supply rooms, walls, light and plumbing fixtures,
accesses, and drains, etc., undergo frequent, irregular searches. These
searches are documented.
~fences, and exits, including exterior windows, are inspected for
once each shift.

~
~

No vehicles enter the secure
perimeter of the facility.

No vehicles are allowed within
the secure perimeter of the
facility.

~
~
~

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 53 of69

RF.M"'UI<'~

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.

procedures include:
Perimeter alarm system tests;
Physical checks of the perimeter fence; and
the results.
~ ACCEPTABLE

D DEFICIENT

D
D

AT-RISK

D
D REPEAT FINDING

REMARKS:

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 54 of69

SPECIAL MANAGEMENT UNIT (SMU)
(ADMINISTRATIVE SEGREGATION)
THE SPECIAL MANAGEMENT UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL
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 rDISCIPLINARY C"I,
;A.TION]" STANnARD).

COMrul'lEl'I I~

..
The Administrative Segregation unit provides non-pullltlve
protection from the general population and individuals undergoing
disciplinary segregation.
• Detainees are placed in the SMU (administrative) III
accordance with written criteria.
In exigent circumstances, staff may place a detainee in the SMU
(administrative) before a written order has been approved.
• A copy of the order given to the detainee within 24 hours.
The OIC (or equivalent) regularly reviews the status of detainees in
administrative detention.
• A supervisory officer conducts a review within 72 hours of
the detainee's nl
III the SMU
LaLu'::).
A supervisory officer conducts another review after the detainee has
spent seven days in administrative segregation, and:
• Every week thereafter for the first month; and
• 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
ju ~ti fi ~Hti on ?
The detainee is given a copy of the decision and justification for each
review.
• The detainee is given an opportunity to appeal the reviewer's
decision to someone else in the facility.
The OIC (or equivalent) routinely notifies the Field Office Director
(or staff officer in charge of IGSAs) any time a detainee's stay in
administrative detention exceeds 30 days.
• Upon notification that the detainee's administrative
segregation has exceeded 60 days, the FD forwards written
notice to HQ Field Op"rations Branch Chieffor DRO.
The OIC or equivalent) reviews the case of every detainee who
objects to administrative segregation after 30 days in the SMU.
• A written record is made of the decision and the
justification.
• The detainee receives a copy of this record.
The detainee is given the right to appeal to the OIC (or equivalent)
the conclusions and recommendations of any review conducted after
the detainee have remained in administrative segregation for seven
consecutive days.
Administratively segregated detainees enjoy the same general
privileges as detainees in the general nonnhtion
The SMUis:
• Well ventilated;
• Adequately lighted;
• Appropriately heated; and
• Maintained in a sanitary condition.
All cells are CyUll-'l-'CU with beds.
•
Every bed is securely_ fastened to the floor or wall.

•

YES

[gl

REMARKS

[gl

Status reviews are not
conducted within 72 hours of
placement in Administrative
Segreg" ,on

[gl

Periodic status reviews are not
conducted for detainees placed
in Administrative Segregation.

Since formal reviews are not
conducted, detainees are not
given a copy of the placement
decision and/or justification

[gl

Formal reviews are not
conducted. Therefore, appeals
by detainees are not possible.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 55 of69

SPECIAL MANAGEMENT UNIT (SMU)
(ADMINISTRATIVE SEGREGATION)
POLICY: THE SPECIAL MANAGEMENT UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL
THE SPECIAL MANAGEMENT UNIT WILL CONSIST OF TWO SECTIONS. ONE, ADMINISTRATIVE SEGREGATION, HOUSES
ISOLATED FOR THEIR OWN PROTECTION; THE OTHER FOR DETAINEES BEING DISCIPLINED FOR WRONGDOING (SEE THE
-"~PF('TAT MANAGEMENT UNIT (DISCIPLINARY SEGREGATIQl'I}" STA}\InARl)).
C'l
RF.MARKS
It;NlS
YES
NA
No
The number of detainees in any cell does not exceed the occupancy
limit.
• When occupancy exceeds recommended capacity, do basic ~
D
D
living standards decline?
• Do criteria for objectively assessing living standards exist?
• If yes, are the criteria included in the written !11~\';t:;~iucS?
The segregated detainees have the same opportunities to
exchange/launder clothing, bedding, and linen as detainees in the
~
D
D
general nonlllHtion
Detainees receive three nutritious meals per day, from the general
population's menu of the day.
~
D
D
• Do detainees eat only with lli"n"""hlp utensils?
• Is food ever used as nnni"hmP.tlt?
Each detainee maintains a normal level of personal hygiene in the
SMU.
D
D
• The detainees have the opportunity to shower and shave at ~
least three times a week.
• Ifnot, pxnlHin
The detainees are provided:
• Barbering services;
• Recreation privileges m accordance with the "Detainee
Recreation" standard;
Non-legal
reading material;
•
Religious
material;
~
D
D
•
• The same correspondence privileges as detainees in the
general population;
Telephone
access similar to that of the general population;
•
and
• Personal legal material.
A health care professional visits every detainee at least three times a
week.
~
D
D
• The shift supervisor visits each detainee daily.
• VVeekendsandholidays.
Procedures comply with the "Visitation" standard.
~
D
D
• The detainee retains visiting privileges; and
• The visiting room is available during normal visiting hours.
Visits from clergy are allowed.
~
lJ
LJ
Detainees have the same law-library access as the general population.
• Are they required to use the law library ~ Separately, or
D
D
~
DAs a group?
Are legal materials brought to them?
The SMU maintains a permanent log of detainee-related activity,
~
D
D
e.g. meals served, .IO".IOaUVll, visitors etc.
SPC procedures include completing the SMU Housing Record (1888) immediately upon a detainee's placement in the SMU.
D
D
~
• Staff completes the form at the end of each shift.
• CDFs and IGSA facilities use Form 1-888 (or local
equivalent).

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 56 of69

SPECIAL MANAGEMENT UNIT (SMU)
(ADMINISTRATIVE SEGREGATION)
POLICY: THE SPECIAL MANAGEMENT UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL
VLl"H'-Jn. THE SPECIAL MANAGEMENT UNIT WILL CONSIST OF TWO SECTIONS.
ONE, ADMINISTRATIVE SEGREGATION, HOUSES
'''''''''-'''" ISOLATED FOR THEIR OWN PROTECTION; THE OTHER FOR DETAINEES BEING DISCIPLINED FOR WRONGDOING (SEE THE
MANAGEMENT UNIT
ST

Staff record whether the detainee ate, showered, exercised, and took
any applicable medication during every shift.
• Staff logs record all pertinent information, e.g., a medical
condition, suicidaVassaultive behavior, etc;
• The medical officer/health care professional signs each
individual's record during each visit; and
• The housing officer initials the record when all detainee
serVices are
or at the end of the shift.
A new record is created for each week the detainee is in
Administrative Segregation.
• The weekly records are retained in the SMU until the
detainee's return to the

o ACCEPTABLE

Iz;J DEFICIENT

OAT-RISK

o REPEAT FINDING

REMARKS:

It is recommended that the facility consider initiating a formal review of detainees within 72 hours of being placed in Administration
Segregation. It is also recommended that the facility develop a process which provides the detainee with a copy of the decision and
justification for placement in Administration Segregation. It is also recommended that the facility develop a process that enables a

detainee the

to appeal the decision regarding placement of Administration Segregation.

b6,b7c
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 57 of69

SPECIAL MANAGEMENT UNIT
(DISCIPLINARY SEGREGATION)
EACH FACILITY WILL ESTABLISH A SPECIAL MANAGEMENT UNIT IN WHICH TO ISOLATE CERTAIN DETAINEES FROM THE
POPULATION. THE SPECIAL MANAGEMENT UNIT WILL HAVE TWO SECTIONS, ONE FOR DETAINEES IN ADMINISTRATIVE
~~F(iRF.(iA.TION; THE OTHER FOR DETAINEES BEING SEGREGATED FOR DISCIPLINARY REASONS.
(
RRMARKS
11:0;
No
NA
YES
Officers placing detainees in disciplinary segregation follow written
0
0
~
plul,;cdun;;1;.
The sanctions for violations committed during one incident are
~
0
0
limited to 60 days.
A completed Disciplinary Segregation Order accompanies the
detainee into the SMU.
~
0
0
• The detainee receives a copy of the order within 24 hours of
nlacement in ;1;
lary se~re~ation
Standard procedures include reviewing the cases of individual
detainees housed in disciplinary detention at set intervals.
~
0
0
• After each formal review, the detainee receives a written copy
of the decision and supporting reasons.
The conliitions ot confinement ill the SMU are pwpv{tlonal to the
~
0
0
amount of control neceSSllry to protect detainees and staff.
have fewer privileges than
Detainees in disciplinary ""151
0
~
0
those housed in
,uau '" segff>n~~ion
Living conditions in disciplinary SMUs remain the same regardless
of behavior.
0
0
• If no, does staff prepare written documentation for this ~
action?
• Does the OIC sign to indicate dppi0val.
Every detainee in disciplinary segregation receives the same humane
0
~
0
regardless of offense.
quarters used for segregation are:
• Well-ventilated.
• Adequately lighted.
~
0
0
• Appropriately heated.
• Maintained in a sanitary condition.
AT.

All cells are equipped with beds that are securely fastened to the
floor or wall of the cell.
The number of detainees confined to each cell or room is limited to
the number for which the space was designate.
• Does the OIC approve excess occupancy on a temporary
basis?
When a detainee is segregated without clothing, mattress, blanket, or
pillow (in a dry cell setting), a justification is made and the decision
is reviewed each shift. Items are returned as soon as it is safe.
T'
in the SMU have the same opportunities to exchange
clothin!!. heddin!!. etc., as other detainees.
Detainees in the SMU receive three nutritious meals per day, selected
from the Food Service's menu of the day.
• Food is not used as mmi'lhment
Detainees are allowed to maintain a normal level of personal
hygiene, including the opportunity to shower and shave at least three
times/week.
Detainees receive, unless documented as a threat to security:
• Barbering services;
• Recreation privileges;
• Other-than-Iegal reading material;
• Relivioll'l material;

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 58 of69

SPECIAL MANAGEMENT UNIT
(DISCIPLINARY SEGREGATION)

EACH FACILITY WILL ESTABLISH A SPECIAL MANAGEMENT UNIT IN WHICH TO ISOLATE CERTAIN DETAINEES FROM THE
POPULATION. THE SPECIAL MANAGEMENT UNIT WILL HAVE TWO SECTIONS, ONE FOR DETAINEES IN ADMINISTRATIVE
,ATION; THE OTHER FOR DETAINEES BEING SEGREGATED FOR DISCIPLINARY REASONS.
n
H~
YES
No
NA
RRMADK~
• The same correspondence privileges as other detainees; and
• Personal legal material.
When phone access is limited by number or type of calls, the
following areas are exempt:
• Calls about the detainee's immigration case or other legal
matters;
D
D
• Calls to consular/embassy officials; and
• Calls during family emergencies (as determined by the
OlC/Warden).
A health care professional visits every detainee in disciplinary
segregation every week day.
D
D
•
The shift supervisor visits each segregated detainee daily
• W(>"Jn,nrl~ and holidays,
SMU detainees are allowed visitors, in accordance with the
Facility policy does not allow
"Visitation" standard.
visitation while housed in
Disciplinary Segregation. Staff
D
D
indicated that special provisions
are made for ICE detainees.
SMU detainees receive legal visits, as provided in the "Visitation"
standard.
D
D
• Legal service providers are notified of security concerns
arising before a visit.
Visits from clergy are allowed.
• The clergy member is given the option of visiting/not
visiting the segregated detainee.
D
D
•
Violent/uncooperative detainees are 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 caseD
D
by-case basis.
•
Staff documents every incident of denied access to the law
library.
All detainee-related activities are documented, e.g. meals served,
Numerous log books were
recreation activities, visitors, etc.
reviewed in the Disciplinary
Segregation Unit. The logbooks
D
D
contained incomplete
information regarding detainee
activities.
The SPC's, the Special Management Housing Unit Record (1-888or
equivalent), is prepared as soon as the detainee is placed in the SMU.
• All 1-888s are filled out by the end of each shift.
D
D
• The CDF/IGSA facility use Form.
• 1-888 (or equivalent local form) .
POLICY:

>O"J_a,~,..,A',TL

•

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Page 59 of69

SPECIAL MANAGEMENT UNIT
(DISCIPLINARY SEGREGATION)
POLICY: EACH FACILITY WILL ESTABLISH A SPECIAL MANAGEMENT UNIT IN WHICH TO ISOLATE CERTAIN DETAINEES FROM THE
'IOmc,1V1cL POPULATION. THE SPECIAL MANAGEMENT UNIT WILL HAVE TWO SECTIONS, ONE FOR DETAINEES IN ADMINISTRATIVE

SMU staff record 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

Numerous log books were
reviewed in the Disciplinary
Segregation Unit. The logbooks
contained incomplete
information regarding detainee
activities.

SMU.

•

The SMU retains these records until the detainee leaves the
SMU.

REMARKS:

The Disciplinary Segregation Unit is a well run unit that provides all required services. The unit is clean, well lit and staff conduct
themselves in a professional manner. Personal observation indicated that activity logbooks, in several cases, were incomplete.
Although facility policy does not permit visits for inmates in Disciplinary Segregation, facility and ICE staff interviews indicated
special provisions for visits are made for an ICE detainee placed in the Disciplinary Segregation Unit.
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Page 60 of69

TOOL CONTROL
POLICY: IT IS THE POLICY OF ALL FACILITIES THAT ALL EMPLOYEES SHALL BE RESPONSIBLE FOR COMPLYING WITH THE TOOL CONTROL
. THE MAINTENANCE SUPERVISOR SHALL MAINTAIN A COMPUTER GENERATED OR TYPEWRITTEN MAsTER INVENTORY LIST OF
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.
n
RFMARKS
U;I'U:S
YES
NA
No
tool
control
There is an individual who is responsible for U"V"l'
D
~
D
·htv.
procedure and an insnection system to insure
Department heads are responsible for implementing this standard in
~
D
D
their departments.
Tool inventories are required for the:
• Maintenance Department;
At the time of the inspection,
• Medial Department;
D
D tool control inventories did not
~
• Food Service Department;
exist.
• Electronics Shop;
• Recreation Department; and
• Armory.
Thp f"r.ilit" h"" " nolir.v for thp rp(11Ihr invpntorv of 'til tools .
At the tune 01 the m'T
• The policy sets minimum time lines for physical inventory D
tool control inventories did not
~
D
and all necessary documentation.
exist.
• ICE facilities use AMIS bar code labels when l"I{U~"U.
The facility has a tool classification system. Tools are classified
At the time of the inspection,
according to:
tools were not classified as
D
D
~
Restricted (dangerouslhazardous); and
restricted or non-restricted.
• Non-Restricted (non-h: lUUU:».
Department heads are responsible for implementing tool-control
~
D
D
-,-

•

1'1 U""UUl "".

~ facility h'" pnlici~ ""d pm"dur", in pia"" to en,ure that .u too),
. marked and readily identifiable.
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 is readily notice.
Each facility has procedures for the issuance of tools to staff and
detainees.
The facility has policies and procedures to address the issue of lost
tools. The policy and procedures include:
• Verbal and written notification;
• Procedures for detainee access; and
• Necessary documentation/review for all incidents of lost
tools.
Broken or worn out tools are surveyed and disposed of in an
appropriate and secure manner.

•

~ DEFICIENT

At the time of the inspection,
tools were not marked.

At the time of the inspection,
the facility did not have an
approved tool storage system.

All private or contract repairs and maintenance workers under contract
to ICE, or other visitors, submit an inventory of all tools prior to
admittance into or dt;;pru lUI" from the facility.

D ACCEPTABLE

At the time of the inspection,
the facility did not have a policy
or procedure to address the issue
of lost tools.
At the time of the inspection,
the facility did not have a policy
or procedure to address the
disposal of broken or worn out
tools.

AT-RISK

D REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 61 of69

REMARKS:

It is recommended that the facility develop and implement a tool control system which complies with the NDS and addresses the
deficiencies noted above.

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'f
oAUDITOR'S
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IL4r-19-09
GNATURE/DATE

e
FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 62 of69

TRANSPORTATION
(LAND TRANSPORTATION)
• THE IMMIGRATION AND NATURALIZATION SERVICE WILL TAKE ALL NECESSARY PRECAUfIONS TO PROTECT THE LIVES,
, AND WELFARE OF OUR OFFICERS, THE GENERAL PUBLIC, AND THOSE IN ICE CUSTODY DURING THE TRANSPORTATION OF
DETAINEES. STANDARDS HAVE BEEN ESTABLISHED FOR PROFESSIONAL TRANSPORTATION UNDER THE SUPERVISION OF EXPERIENCED
AND TRAINED DETENTION ENFORCEMENT OFFICERS OR AUfHORIZED CONTRACT PERSONNEL.

~ STANDARD NA: CHECK THIS BOX IF ALL ICE TRANSPORTATION IS HANDLED ONLY BY THE ICE FIELD OFFICE OR SUB-OFFICE
IN CONTROL OF THE DETAINEE CASE.
RRMARKS
NA
YES
COMrVl'll'.l'Il"
NQ
Transporting officers comply with applicable local, state, and federal
motor vehicle laws and regulations. Records support this finding of
D
D
D
comoliance.
Every transporting officer required to drive a commercial size bus has
a valid Commercial Driver's License (CDL) issued by the state of
D
D
D
<;;lllJ.lluyment.
Supervisors m~int~in rec()~ for each vehicle Ul'.'-':'."LVI
D
D
D
Officers use a checklist during every vehicle inspection.
,.,.
,.
VP"HlVIHLY, aHU
\.HU""l'" 1 "PVl'
U
U
U
Deficiencies
are
corrected
before
the
vehicle goes back into
•
serVIce.
Transporting officers:
• Limit driving time to 10 hours in any 15 hour period;
• Drive only after eight consecutive off-duty hours;
• Do not receive transportation assignments after having been
on duty, in any capacity, for 15 hours;
D
D
• Drive a 50-hour maximum in a given work week; a 70-hour D
maximum during eight consecutive days;
• During emergency conditions (including bad weather),
officers may drive as long as necessary and safe to reach a
,..lin!! the lO-hour limit.
safe "1'
Two officers with valid CDLs required in any bus transporting
detainees.
D
D
• When buses travel in tandem with detainees, there are two D
qualified officers per vehicle.
ied driver may transport an empty vehicle.
• An nn:
Before the start of each detail, the vehicle is thoTml!!hly ~, _1.
[J
[J
D
Positive iilp.ntifir.Mion of all ilp.t~inp.p." being transported is l;Vliflllll<;;U.
[]
[]
[]
All detainees
searched immediately prior to boarding the vehicle
D
D
D
by staff controlling the bus or vehicle.
The facility ensures that the number of detainees transported does not
D
D
D
exceed the vehicles manufacturer's
ICY level.
I\VL""Ll '" vests are plV Vlu"d to all transporting officers.
lJ
lJ
lJ
The vehicle crew conducts a visual count once all passengers are on
board and seated.
D
D
• Additional visual counts are made whenever the vehicle D
makes a scheduled or unscheduled stop.
Policies and procedures are in place addressing the use of restraining
D
D
D
<;;4
It on~rtatio!!. vehicles.
Officers ensure that no one contacts the detainees.
D
D
• One officer remains in the vehicle at all times when detainees D
are nTp."pnt
Meals are provided during long distance transfers.

i
I

-0

The meal, meet the minimum die""" ,truulru-ru.," identified

by dieticians utilized by ICE.
vehicle crew in"npr.t" all Food Service nir.k-un" befo~~ing

[]

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 63 of69

TRANSPORTATION
(LAND TRANSPORTATION)
POLICY: THE IMMIGRATION AND NATURALIZATION SERVICE WILL TAKE ALL NECESSARY PRECAUTIONS TO PROTECT THE LIVES,
AND WELFARE OF OUR OFFICERS, THE GENERAL PUBLIC, AND THOSE IN ICE CUSTODY DURING THE TRANSPORTATION OF
'ATNFFS. STANDARDS HAVE BEEN ESTABLISHED FOR PROFESSIONAL TRANSPORTATION UNDER THE SUPERVISION OF EXPERIENCED
AND TRAINED DETENTION ENFORCEMENT OFFICERS OR AUTHORIZED CONTRACT PERSONNEL.

IZI STANDARD NA:

CHECK THIS BOX IF ALL ICE TRANSPORTATION IS HANDLED ONLY BY THE ICE FIELD OFFICE OR SUB-OFFICE
IN CONTROL OF THE DETAINEE CASE.
('j
RF.M.~DIl'Ii:
YES
NA
mNTI;
No
delivery (food wrapping, portions, quality, quantity, thermos-transport
containers, etc,).
• Before accepting the meals, the vehicle crew raises and
resolves questions, concerns, or discrepancies with the Food
Service representative;
Basins,
latrines, and drinking-water containers/dispensers are
•
cleaned and sanitized on a fixed schedule.
Vehicles have:
• Two-way radios;

•
•

-..-

ClIlU

Equipment boxes stocked in accordance with the Use of
Force Standard,
The :",ehicles are ~n and ~Cll~Wly ~t all times.
Personal property of a detainee transferring to another facility is:
• Inventoried;
• Inspected; and
• A """fl1n~nip." 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
• PaSSen!1p.T list includes women or minors

D ACCEPTABLE

D DEFICIENT

L.......J

[]

AT-RISK

D REPEAT FINDING

REMARKS:

{

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AUDITOR'S SIGNATURE / DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 64 of69

USE OF FORCE
POLICY: THE U.S. DEPARTMENT OF HOMELAND SECURITY AUfHORIZES THE USE OF FORCE ONLY AS A LAST ALTERNATIVE AFTER ALL

REASONABLE EFFORTS TO RESOLVE A SITUATION HAVE FAILED. ONLY THAT AMOUNT OF FORCE NECESSARY TO GAIN CONTROL
THE DETAINEE, TO PROTECT AND ENSURE THE SAFETY OF DETAINEES, STAFF AND OTHERS, TO PREVENT SERIOUS PROPERTY DAMAGE
AND TO ENSURE INSTITUfION SECURITY AND GOOD ORDER MAY BE USED. PHYSICAL RESTRAINTS NECESSARY TO GAIN CONTROL OF A
DETAINEE WHO APPEARS TO BE DANGEROUS MAYBE EMPLOYED WHEN THE DETAINEE:
(
RFMARKS
YES
No
NA
IT:S
Written policy authorizes staff to respond in an immediate-use~
D D
of-force situation without a supervisor's pI ""':'11"" 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
D D
~
others, officers must try to resolve the situation without
resorting to force.
Written policy asserts that calculated rather than immediate use
~
D D
of force is feasible in most cases.
The facility subscribes to the prescribed Confrontation
A voidance Procedures.
• Rankin!' detention officiaL health prr,f'o~~ional
and others confer before every calculated use of
force.
When a detainee must be forcibly moved and/or restrained, and
there is time for a calculated use of force, staff uses the Use-ofForce Team Technique.
• Under staff supervision.
trained in the performance of the Use-ofStaff members
Force Team Tee' aue.
All use-of-force incidents are documented and reviewed.
Staff:
• Do not use force as punishment;
• Attempt to gain the detainee's voluntary
cooperation before resorting to force;
• Use only as much force as necessary to control
the detainee; and
• Use restraints only when other nonconfrontational
means,
including
verbal
icaL
persuasion have failed or are
Medication may only be used for restraint. PUlPU""" when
authorized by the Medical AUlllUllLY as medically no'-'o~,>ary.
Use-of-Force Team follows written PIU"vUUlv" that ULLvlllPL to
)JlvVvm injury and
Lv to communi~::Ihle clisem::e(s).
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; and
When
qualified medical staff is not immediately
•
the detainee "face-up".
available, staff

[]

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 65 of69

USE OF FORCE

I
I

POLICY: THE U.S. DEPARTMENT OF HOMELAND SECURITY AUTHORIZES THE USE OF FORCE ONLY AS A LAST ALTERNATIVE AFTER ALL
OTHER REASONABLE EFFORTS TO RESOLVE A SITUATION HAVE FAILED. ONLY THAT AMOUNT OF FORCE NECESSARY TO GAIN CONTROL
THE DETAINEE, TO PROTECT AND ENSURE THE SAFETY OF DETAINEES, STAFF AND OTHERS, TO PREVENT SERIOUS PROPERTY DAMAGE
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:
RI?MADI<~
No
NA
COMPUNENIIS
YES
The shift supervisor monitors the detainee's position/condition
every two hours.
D D
• He/she allows the detainee to use the rest room at ~
these times under >:lr"lUI>.
All cip.t!linp.p. checks are logged.
l J LJ
~
In innnediate-use-of-force situations, staff contacts medical
D D
~
staff once the detainee is under control.
When the OIC authorizes use of non-lethal weapons:
Current facility policy does not require
• Medical staff is consulted before staff use pepper
medical staff consultation or review of
spray/non-lethal weapons.
D
~
D medical file prior to the use of non-lethal
• Medical staff reviews the detainee's medical file
weapons.
before use of a non-lethal weapon is authorized.
Special precautIOns are taken when l'
19 pregnant
detainees.
D D
~
are consulted
• Medical
Protective gear is worn when restraining detainees with open
D D
~
cuts or wounds.
Staff documents every use of force and/or non-routine
D D
~
!lnnlic!ltion of restraints.
It is standard practice to review any use of force and the nonD D
~
routine annlication of restraints.
All officers receive training in self-defense, confrontationiclilnr.p. techniques and the use of force to control detainees.
D D
• Specialized training is given and Officers are ~
certified in all devices they use.
In SPCs, is the Use of Force form is used? In other facilities
D D
~
~s / CDFs) is this form or its equivalent used?
~ ACCEPTABLE

D DEFICIENT

AT-RISK

D REPEAT FINDING

REMARKS:
During the past year there have been no cell extractions ofICE detainees. The facility utilizes Tasers. However, staff advised that a
Taser has not been used on an ICE detainee.
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/
11-19-09
AUDITOR'S SIGNATURE/DATE

•

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Page 66 of69

STAFF DETAINEE COMMUNICATIONS
POLICY: PROCEDURES MUST BE IN PLACE TO ALLOW FOR FORMAL AND INFORMAL CONTACT BETWEEN KEY FACILITY STAFF AND ICE
aTAFF AND ICE DETAINEE AND TO PERMIT DETAINEES TO MAKE WRITTEN REQUESTS TO ICE STAFF AND RECEIVE AN ANSWER IN AN
.C~PT ABLE TIME FRAME.
Cl
IT~
YES
No
NA
DDU" DV<'
The ICE Field Office Director ensures that weekly announced and
C0
D
D
unannounced visits occur at the IGSA.
Detention and Deportation Staff conduct scheduled weekly visits with
D
D
detainees held in the IGSA.
No postings were found in
Scheduled visits are posted in ICE detainee areas.
D
D detainee areas.
Visiting staff observe and note current climate and conditions of
D
D
confinement at each IGSA.
ICE information request Forms are available at the IGSA for use by
C0
D
D
ICE detainees.
The IGSA treats detainee correspondence to ICE staff as Special
C0
D
D
Corr
Hience
ICE staff
Is to a detainee request from an IGSA within 72
IV1
n
n
hours.
"'-'"
ICE detainees are notified in writing upon admission to the facility of
their right to correspond with ICE staff regarding their case or
C0
D
D
conditions of confinement.

C0 ACCEPTABLE

DDEFICIENT

D AT-RISK

D REPEAT FINDING

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/
T 111-19-09
ITUR's"SIGNA
I DATE

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Page 67 of69

DETAJNEETRANSFERSTANDARD
POLICY: ICE WILL MAKE ALL NECESSARY NOTIFICATIONS WHEN A DETAINEE IS TRANSFERRED. IF A DETAINEE IS BEING TRANSFERRED
THE JUSTICE PRISONER ALIEN TRANSPORTATION SYSTEM (JPATS), ICE WILL ADHERE TO JPATS PROTOCOLS. IN DECIDING
IHhlHhK TO TRANSFER A DETAINEE, ICE WILL TAKE INTO CONSIDERATION WHETHER THE DETAINEE IS REPRESENTED BEFORE THE
IMMIGRATION COURT. IN SUCH CASES, THE FIELD OFFICE DIRECTOR WILL CONSIDER THE DETAINEE'S STAGE WITHIN THE REMOVAL
PROCESS, WHETHER THE DETAINEE'S ATTORNEY IS LOCATED WITHIN REASONABLE DRIVING DISTANCE OF THE FACILITY, AND WHERE
THE IMMIGRATION COURT PROCEEDINGS ARE TAKING PLACE.
R1i'.MARK.'i:
YES
No
NA
COMlrul'll£NTS
or
legal
When a detainee is represented by legal counsel
a
representative, and a G-28 has been filed, the representative of record
is notified by the detainee's Deportation Officer.
~
D
D
• The notification is recorded in the detainee's file; and
• When the A File is not available, notification is noted within
DACS
l'I.T, :+~,
includes the reason for the transfer and the location of the
~
D
D
new facility.
The deportation officer is allowed discretion regarding the timing of
~
D
D
the notification when extenuating circumstances are involved.
-"-,,
lUI; i:lLLUIUI;Y i:lUU UI;li:lUll;l; i:lll;
t~~i:ll H
'"
LU"il .""PVU"llHUL'y LV
~
U
U
_notify faJ!!ily me~rs 11;~i:l~Ulllg a t1i:l1~1;1
Facility policy mandates that:
• Times and transfer plans are never discussed with the
detainee prior to transfer;
The
detainee is not notified of the transfer until immediately
D
D
~
•
prior to departing the facility; and
• The detainee is not pennitted to make any phone calls or have
contact with any detainee in the general non1l111tion
The detainee is provided with a completed Detainee Transfer
~
D
D
fotification Fonn.
G-391 or equivalent authorizing the removal of a detainee from
D
D
~
_a faci~ is used.
For medical transfers:
• The Detainee Immigration Health Service (or IGSA) (DIHS)
Medical Director or designee approves the transfer;
D
D
• Medical transfers are coordinated through the local ICE ~
office; and
• A medical transfer summary is completed and accompanies
the detainee.
Detainees in ICE facilities having DIHS staff and medical care are
No DIHS staff is located at the
transferred with a completed transfer summary sheet in a sealed
D
D
~
facility.
envelope with the detainee's name and A-number, and the envelope is
marked Medical Confidential.
For m,.ci i "" 1 transfers, transporting officers receive instructions
~
D
D
r",,,,,rrl;'1{! medical i~ues.
Detainee's funds, valuables, and property are returned and transferred
~
D
D
with the detainee to hislher new location.
Transfer and documentary procedures outlined in Section C and Dare
~
D
D
followed.
Meals are provided when transfers occur during nonnally schedule
~
D
D
meal times.
An A File or work folder accompanies the detainee when transferred
~
D
D
to a different field office or sub-office.
Files are forwarded to the receiving office via overnight mail no later
than one business day following the transfer.
~
D
D

~ ACCEPTABLE

D DEFICIENT

AT-RISK

D REPEAT FINDING

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
Page 68 of69

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FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 69 of69

Office ofDetention and Removal Operations

U.S. Department of Homeland Security
500 12th Street, SW
Washington, DC 20536

U.S. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

eEC 1 1 2009

Scott R. Baniecke
Field Office Director
St. Paul Minnesota Field Office

It--

r-----

Assistant Director for Detention and Removal Management
SUBJECT:

Ramsey County Adult Detention Center Annual Review

The annual review of the Ramsey County Adult Detention Center conducted on November 1719,2009, in St. Paul, Minnesota has been received. A final rating of Acceptable has been
assigned.
The G-324A worksheets provided by the Lead Compliance Inspector (LCI) indicated the
facility was deficient with the Hunger Strikes, Special Management Unit (Administrative
Segregation), and Tool Control standards. A Plan of Action is required to address these
deficiencies and the deficiencies identified in the Environmental Health and Safety standard.
The rating was based on the LCI Summary Memorandum and supporting documentation. The
Field Office Director must remedy the above deficiencies and initiate the following actions in
accordance with the Detention Management Control Program (DMCP):
1) The Field Office Director, Detention and Removal Operations, shall notify the facility
within five business days of receipt of this memorandum. Notification shall include
copies of the Form G-324A Detention Facility Review Form, the G-324A Worksheet,
LCI 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) The RA will advise the Field Office Director once the Plan of Action is approved.
4) Once a Plan of Action is approved, the Field Office Director shall schedule a follow-up
on the above noted deficiencies within 90 days.

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

Ramsey County Adult Detention Center Annual Review
Page 2 of2

The Field Office is responsible for assisting the Intergovernmental Service Agreement (IGSA)
facility to respond to the Immigration and Customs Enforcement findings when assistance is
requested. Notification to the facility shall include information that this assistance is available.
Should you or your staffhave any questions regarding this matter, please contact
Gary Mead, Deputy Assistant Director, Detention Management Division at (202) 732cc: Official File
ICE:HQDRO:EAcuna:2-5958: 12/08/2009
b2High

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

The Habeas Citebook Ineffective Counsel Side