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

Office of Detention Oversight
Compliance Inspection
Enforcement and Removal Operations
ERO Detroit Field Office
Seneca County Jail
Tiffin, Ohio

June 16–18, 2015

 

COMPLIANCE INSPECTION
for the
SENECA COUNTY JAIL
TIFFIN, OHIO
TABLE OF CONTENTS
EXECUTIVE SUMMARY
Overall Findings...................................................................................................................2
Findings by National Detention Standard (NDS) 2000 Major Categories ..........................3
INSPECTION PROCESS .............................................................................................................4
DETAINEE RELATIONS ............................................................................................................5
INSPECTION FINDINGS
DETAINEE SERVICES
Detainee Grievance Procedures ...........................................................................................7
Staff-Detainee Communication ...........................................................................................7
Telephone Access ................................................................................................................8
SECURITY AND CONTROL
Environmental Health and Safety ........................................................................................8
HEALTH SERVICES
Medical Care ........................................................................................................................8

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*

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INSPECTION TEAM MEMBERS

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

Office of Detention Oversight
June 2015
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Lead Inspections and Compliance Specialist
ODO
Inspections and Compliance Specialist
ODO
Inspections and Compliance Specialist
ODO
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections
1

Seneca County Jail
ERO Detroit

 

EXECUTIVE SUMMARY
The Office of Detention Oversight (ODO) conducted a compliance inspection of the Seneca
County Jail (SCJ) in Tiffin, Ohio, from June 16 to 18, 2015.1 SCJ opened in 1994 and is owned
and operated by the Seneca County Sheriff’s Office. Enforcement and Removal Operations
(ERO) began housing detainees at SCJ in 1994 pursuant to an Intergovernmental Service
Agreement (IGSA), under the oversight of ERO’s Field Office Director (FOD) in Detroit,
Michigan.
ERO staff members are not assigned
Capacity and Population Statistics
Quantity
to the facility and a Detention
Services Manager is not assigned to ICE Detainee Bed Capacity2
80
the facility.
An SCJ Jail Average ICE Detainee Population3
52
Administrator is responsible for Male Detainee Population (as of 06/16/2015)
26
oversight of daily facility operations
Female Detainee Population (as of 06/16/15)
1
and is supported by (b)(7)epersonnel.
Seneca County Sheriff’s Office provides medical and food services. The facility holds no
accreditations. The facility is not contractually obligated to comply with the ICE PerformanceBased National Detention Standards (PBNDS) 2011, Sexual Abuse and Assault Prevention and
Intervention (SAAPI) standard but, made efforts to comply.4

OVERALL FINDINGS
In July 2010, ODO conducted an
inspection of SCJ under the National
Detention Standards (NDS) 2000,
reviewing the facility’s compliance
with 22 standards and finding the
facility
compliant
with
four
standards. There were a total of 45
deficiencies in the remaining 18
standards.

Inspection Results
Compared

FY 2010
(NDS 2000)

FY2015
(NDS 2000)

Standards Reviewed

22

15

Deficient Standards
Overall Number of
Deficiencies
Deficient Priority
Components

18

5

45

11

N/A

N/A

0

2

Corrective Actions Initiated

In FY2015, ODO conducted an inspection of SCJ under the NDS 2000, reviewing the facility’s
compliance with 15 standards and finding the facility compliant with ten standards. ODO found
11 deficiencies in the remaining five standards. Finally, ODO identified two opportunities where
the facility initiated corrective action during the course of the inspection.5

                                                            
1

Male and female detainees with low, medium and high security classification levels are detained at the facility for
longer than 72 hours.
2
Data Source: ERO Facility List Report as of June 22, 2015.
3
Ibid.
4
The facility has written policy and procedures for a Sexual Abuse and Assault Prevention and Intervention
program and has appointed a SAAPI compliance manager. All staff members, contractors and volunteers receive
facility provided SAAPI training.
5
Corrective actions, where immediately implemented, best practices and ODO recommendations, as applicable,
have been identified in the Inspection Findings section and annotated with a “C”, “BP” or “R”, respectively.

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Seneca County Jail
ERO Detroit

 

FINDINGS BY NDS 2000 MAJOR CATEGORIES
NDS 2000 STANDARDS INSPECTED6

DEFICIENCIES

Part 1 – Detainee Services
Access to Legal Material
Admission and Release
Detainee Classification System
Detainee Grievance Procedures
Detainee Handbook
Food Service
Funds and Personal Property
Staff-Detainee Communication
Telephone Access
Sub-Total

0
0
0
3
0
0
0
2
3
8

Part 2 – Security and Control
Environmental Health and Safety
Special Management Unit (Administrative)
Special Management Unit (Disciplinary)
Use of Force
Sub-Total

1
0
0
0
1

Part 3 – Health Services
Medical Care
Suicide Prevention and Intervention
Sub-Total

2
0
2

Total Deficiencies

11

                                                            
6

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

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June 2015
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Seneca County Jail
ERO Detroit

 

INSPECTION PROCESS
Every fiscal year, the Office of Detention Oversight (ODO), a unit within U.S. Immigration and
Customs Enforcement’s (ICE) Office of Professional Responsibility (OPR), conducts
compliance inspections at detention facilities in which detainees are accommodated for periods
in excess of 72 hours and with an average daily population greater than ten to determine
compliance with the applicable ICE National Detention Standards (NDS) 2000, the PerformanceBased National Detention Standards (PBNDS) 2008 or 2011.
During the compliance inspection, ODO reviews each facility’s compliance with those detention
standards that directly affect detainee health, safety, and/or well-being.7 Any violation of written
policy specifically linked to ICE detention standards, ICE policies, or operational procedures that
ODO identifies is noted as a deficiency. ODO will highlight any deficiencies found involving
those standards that ICE has designated with either the PBNDS 2008 or 2011 to be “priority
components.”8 ICE considers those components to be of critical importance, given their impact
on facility security and/or the health and safety, legal rights, and quality of life of detainees in
ICE custody.
Immediately following an inspection, ODO hosts a closeout briefing in person with both facility
and ERO field office management to discuss their preliminary findings, which are summarized
and provided to ERO in a preliminary findings report. Thereafter, ODO provides ERO with a
final compliance inspection report to: (i) assist ERO in working with the facility to develop a
corrective action plan to resolve identified deficiencies; and (ii) provide senior ICE and ERO
leadership with an independent assessment of the overall state of ICE detention facilities. The
reports enable senior agency leadership to make decisions on the most appropriate actions for
individual detention facilities nationwide.

                                                            
7

8

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

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June 2015
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Seneca County Jail
ERO Detroit

 

DETAINEE RELATIONS
ODO interviewed 25 detainees, who volunteered to participate. None of the detainees made
allegations of mistreatment, abuse, or discrimination. The majority of detainees reported being
satisfied with facility services, with the exception of the complaints below:


Admission and Release: Two detainees alleged they were strip-searched upon admission
to the facility.
o



Food Service: One detainee alleged food service staff does not wear gloves or hairnets
when serving or handling food.
o



Action Taken: The intake staff notified ODO that detainees are not strip-searched
upon admission and are afforded the opportunity to shower in private during the
admission process. ODO reviewed the admission processing of newly arriving
detainees and did not observe any detainee being strip-searched. Further, a
review of 25 active detainee detention files did not have documentation stating
detainees were strip-searched.

Action Taken: Food service staff notified ODO that staff assigned to food service
wear gloves and hairnets when serving or handling food. ODO observed the
preparation and serving of lunch during the inspection and verified food services
staff wears hairnets and gloves when serving or handling food.

Medical Care: Five detainees alleged they were not receiving appropriate medical care.
One detainee alleged he has foot pain due to an accident that occurred prior to arriving at
SCJ and also has arthritis. The detainee alleged he was only prescribed Tylenol. One
detainee alleged during admission he complained of a toenail issue that has not been
addressed. Two detainees alleged they were diabetic and not receiving the appropriate
meals. One detainee stated he was experiencing pain and numbness in his left arm and
hand. The detainee alleges he was seen by a physician and given a seven day supply of
medication, but continues to have pain.
o

Action Taken:
ODO consulted with medical staff about the aforementioned allegations.
Medical services notified ODO the detainee, with allegations of foot pain, arrived
on May 2, 2015 complaining of foot arthritis and the following day the detainee
was approved for a bottom bunk and given a second bed mat. On May 5, 2015, a
health assessment was completed and medical staff noted the detainee had a
history of foot arthritis but did not have any complaints at the time of the
assessment. On June 2, 2015, the detainee requested special shoes and medical
provided a new pair. The detainee was also advised by medical staff to return the
shoes if they did not work for him. No further sick call requests have been
submitted.

Office of Detention Oversight
June 2015
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Seneca County Jail
ERO Detroit

 

Medical services notified ODO the detainee, with allegations of toenail issues,
was seen on May 27, 2015, for a physical exam. During the exam there were no
complaints of toenail issues. On June 16, 2015, there was a sick call request for
shoes, and the detainee was supplied new shoes. No further sick call requests
have been received.
Medical services notified ODO, the detainees with allegations of not receiving
appropriate meals, are being provided diabetic meals. ODO observed food
service provide the diabetic meals to the detainees during the inspection.
Medical services notified ODO the detainee with allegations of pain and
numbness in his left arm and hand was seen by a physician on May 25, 2015 and
provided prednisone. The detainee has not requested to be seen by medical for
further evaluation.

Office of Detention Oversight
June 2015
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Seneca County Jail
ERO Detroit

 

INSPECTION FINDINGS
DETAINEE SERVICES
DETAINEE GRIEVANCE PROCEDURES (DGP)
ODO reviewed the facility handbook and policy and procedures, which do not reference a
grievance committee. ODO’s findings were confirmed in an interview with staff, who verified
the facility does not have a grievance committee (Deficiency DGP-19).
ODO reviewed the detention files of detainees who filed a grievance and did not find a copy of
any grievance. The facility maintains copies of all grievances but does not place a copy of the
grievance in the detainee’s detention file (Deficiency DGP-2 10 ). An interview with staff
confirmed grievances are not placed in the detainee’s detention file.
ODO found four grievances that involved officer misconduct and determined through interview,
that SCJ did not inform ERO of the grievances. Due to ERO not being notified of the
grievances, an investigation of the alleged officer misconduct was not conducted (Deficiency
DGP-311). ODO discussed the four grievances with both ERO and facility management.
STAFF-DETAINEE COMMUNICATION (SDC)
ODO was advised by facility staff that an Immigration Enforcement Agent (IEA) conducts
unannounced visits to the facility, but information could not be verified because there are no
specific procedures for documenting visits (Deficiency SDC-1 12 ). ODO’s review of the
facility’s sign-in and housing logs revealed there were no ERO staff signatures. In addition,
ERO informed ODO they do not document any visit to the facility.
ODO reviewed Facility Liaison Visit Checklists from June 2014 to June 2015 and determined
ERO is not visiting the facility on a weekly basis and are not thoroughly completing the checklist
(Deficiency SDC-213).

                                                            
9

“The OIC must allow the detainee to submit a formal, written grievance to the facility’s grievance committee.”
See ICE NDS 2000, Standard, Detainee Grievance Procedures, Section (III)(A)(2).
10
“A copy of the grievance will remain in the detainee’s detention file for at least three years.” See ICE NDS 2000,
Standard, Detainee Grievance Procedures, Section (III)(E).
11
“CDFs and IGSA facilities must forward detainee grievances alleging officer misconduct to INS. INS will
investigate every allegation of officer misconduct.” See ICE NDS 2000, Standard, Detainee Grievance Procedures,
Section (III)(F).
12
“Each facility shall develop a method to document the unannounced visits, and ICE will document visits to
IGSAs.” See ICE NDS 2000, Standard, Staff-Detainee Communication, Section (III)(A)(1).
13
“Model protocol forms should be completed weekly for all Service Processing Centers (SPCs), and Contract
Detention Facilities (CDFs). For Inter-Governmental Service Agreements (IGSAs) facilities housing ICE detainees
the model protocol should be completed weekly for regularly used facilities and each visit for facilities, which are
used intermittently.” See Change Notice, National Detention Standards, Staff-Detainee Communication, Model
Protocol, dated June 15, 2007

Office of Detention Oversight
June 2015
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Seneca County Jail
ERO Detroit

 

TELEPHONE ACCESS (TA)
The facility handbook informs detainees of the rules regarding the use of the telephones, but a
copy of the telephone rules are not posted in the housing units where detainees can easily see
them (Deficiency TA-114).
Corrective Action:
The facility initiated corrective action during the course of the
inspection by posting the rules regarding the use of the telephones in the housing areas
(C-1).
ODO reviewed the Telephone Serviceability Worksheets from June 2014 to June 2015 and
determined they are not completed weekly and are not thoroughly completed when done
(Deficiency TA-215).
A notification on each telephone advises detainees that calls may be recorded or monitored, but
the facility handbook does not notify detainees their calls are subject to recording or monitoring
(Deficiency TA-316).
Corrective Action:
The facility initiated corrective action during the course of the
inspection by updating the handbook with notification for detainees that calls are subject
to monitoring and posting change notices in the housing areas (C-2).

SECURITY AND CONTROL
ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
The facility’s fire and safety officer reported he conducts weekly and monthly inspections;
however, these inspections are not documented (Deficiency EH&S-117).

HEALTH SERVICES
MEDICAL CARE (MC)
In three out of 30 records, the physician did not document review of the physical examinations
within 14 days of the detainee’s arrival at the facility. The physician’s review in these three
cases was completed outside the required 14 days set in the NDS (Deficiency MC-118).
                                                            
14

“As described in the ‘General Provisions’ standard, the facility shall provide telephone access rules in writing to
each detainee upon admittance, and also shall post these rules where detainees may easily see them.” See ICE NDS
2000, Standard, Telephone Access, Section (III)(B).
15
“The Field Office Director (FOD) shall ensure that all phones in all applicable facilities are tested on a weekly
basis.” See Change Notice, National Detention Standard, Staff-Detainee Communication, dated April 4, 2007.
16
“If telephone calls are monitored, the facility shall notify detainees in the detainee handbook or equivalent
provided upon admission.” See ICE NDS 2000, Standard, Telephone Access, Section (III)(K).
17
“A qualified departmental staff member will conduct weekly fire and safety Inspections; the maintenance (safety)
staff will conduct monthly inspections. Written reports of the inspections will be forwarded to the OIC for review
and if necessary, correction action determinations. The maintenance supervisor or designate will maintain
inspection reports and records of corrective action in the safety office.” See ICE NDS 2000, Standard,
Environmental Health and Safety, Section (III)(L)(2).

Office of Detention Oversight
June 2015
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Seneca County Jail
ERO Detroit

 

An interview with medical staff revealed the facility does not have an on-site dentist. Initial
dental screenings are performed by registered nurses within 14 days of the detainee’s arrival,
during the health appraisal (Deficiency MC-219).

                                                                                                                                                                                                
18

“The health care provider of each facility will conduct a health appraisal and physical examination on each
detainee within 14 days of arrival at the facility. Health appraisals will be performed according to NCCHC and
JCAHO standards.” See ICE NDS 2000, Standard, Medical Care, Section (III)(D).
19
“An initial dental screening exam should be performed within 14 days of the detainee’s arrival. If no on-site
dentist is available, the initial dental screening may be performed by a physician, physician’s assistant, or nurse
practitioner.” See ICE NDS 2000, Standard, Medical Care, Section (III)(E).

Office of Detention Oversight
June 2015
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Seneca County Jail
ERO Detroit