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

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
Salt Lake City Field Office
Utah County Jail
Spanish Fork, Utah

May 8-10, 2012
________________________________
FOR INTERNAL USE ONLY. This document may contain sensitive commercial, financial, law
enforcement, management, and employee information. It has been written for the express use of the
Department of Homeland Security to identify and correct management and operational deficiencies. In
reference to OPR Directive 17006.1, issued 09/22/05; any disclosure, dissemination, or reproduction of
this document, or any segments thereof, is prohibited without the approval of the Assistant Director,
Office of Professional Responsibility.

COMPLIANCE INSPECTION
UTAH COUNTY JAIL
SALT LAKE CITY FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...............................................................................................1
INSPECTION PROCESS
Report Organization .................................................................................................5
Inspection Team Members .......................................................................................5
OPERATIONAL ENVIRONMENT
Internal Relations .....................................................................................................6
Detainee Relations ...................................................................................................6
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................7
Detention Files .........................................................................................................8
Environmental Health and Safety ..........................................................................10
Special Management Unit (Administrative Segregation) ......................................12
Use of Force ...........................................................................................................13

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO),
conducted a Compliance Inspection (CI) of the Utah County Jail (UCJ), Spanish Fork, Utah, on
May 8-10, 2012. UCJ, which opened on July 20, 1997, is owned and operated by the Utah
County Sheriff’s Office (UCSO). The facility serves as a regional jail for males and females
arrested by area law enforcement jurisdictions. U.S. Immigration and Customs Enforcement
(ICE) has placed male and female detainees of all classification levels (Level I – lowest threat;
Level II – medium threat; Level III – highest threat) at UCJ for periods in excess of 72 hours
under an Intergovernmental Service Agreement (IGSA). The average daily detainee population
is 187. The average length of stay at UCJ is 27 days. UCJ has a total bed capacity of 1,212 with
250 beds available for ICE detainees. Additional detention space is available at the facility for
ICE detainees upon request. At the time of the inspection, UCJ housed a total of 175 detainees:
169 male detainees (12 Level I; 112 Level II; 45 Level III), and six female detainees (three Level
II; three Level III). Food service is provided in-house by UCJ staff. UCJ provides medical care
in-house utilizing a contracted physician. In June 2010, UCJ received accreditation from the
National Commission on Correctional Health Care (NCCHC).
The ICE Office of Enforcement and Removal Operations (ERO), Field Office Director, Salt
Lake City, Utah (FOD/Salt Lake City) is responsible for ensuring facility compliance with ICE
policies and the NDS. An Assistant Field Office Director (AFOD) located at FOD/Salt Lake
City is assigned direct oversight responsibility of UCJ. ICE does not have any staff permanently
assigned to the facility.
The total number of UCJ staff employed at the facility is (b)(7)e The Deputy Chief is the highest
ranking official at UCJ and is responsible for oversight of daily operations. In addition to the
Deputy Chief, UCJ supervisory staff consists of (b)(7)eLieutenants. The facility employs (b)(7)e
Deputy Sheriffs. The remaining (b)(7)eUCJ staff is comprised of non-corrections staff, such as
medical personnel, kitchen cooks, maintenance workers, and records clerks.
In February 2011, ODO conducted a Quality Assurance Review (QAR) of UCJ. ODO reviewed
a total of 24 NDS and recorded 41 deficiencies.
In August 2011, the ERO Detention Standards Compliance Unit contractors, MGT of America,
Inc., conducted an annual review of the ICE NDS. UCJ received an overall rating of
“Acceptable” and was found to be in compliance with all 35 standards reviewed.
During this CI, ODO reviewed a total of 18 NDS. Fourteen standards were fully compliant, and
11 deficiencies were identified in the remaining four standards: Detention Files (4 deficiencies),
Environmental Health and Safety (5), Special Management Unit – Administrative Segregation
(1), and Use of Force (1).
This report details all deficiencies and refers to specific, relevant sections of the ICE NDS. OPR
will provide ERO a copy of the report to assist in developing corrective actions to resolve the 11
identified deficiencies. At the conclusion of the inspection on May 10, 2012, ODO conducted a
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closeout briefing with UCJ and ERO management to discuss deficiencies requiring immediate
attention in the areas of Environmental Health and Safety, Special Management Unit –
Administrative Segregation, and Use of Force. Overall, ODO found the majority of the 11
deficiencies to be administrative in nature.
There were no deficiencies under the Detainee Grievance Procedures NDS. Detainees at UCJ
filed 23 grievances between May 2011 and March 2012. UCJ maintains a grievance log to
document and track grievances filed by detainees. UCJ is in the process of transitioning to an
electronic grievance tracking system. ODO reviewed all grievances in detail. Of the 23
grievances reviewed, 17 (74%) were complaints related to issues such as detainees being
excluded from the voluntary work program, the length of visitation time, etc., three (14%)
pertained to religious services, one (4%) pertained to medical care, one (4%) pertained to
recreation, and one (4%) pertained to funds and personal property. ODO reviewed five
randomly selected grievances (22%) for timeliness and confirmed responses were provided to
detainees within 72 hours in accordance with the NDS.
There were five deficiencies identified under the Environmental Health and Safety NDS. UCJ
management has a system for storing, issuing, and maintaining inventories of hazardous
materials. Hazardous substances are stored in a fire resistant storage cabinet in the maintenance
area. However, ODO found two aerosol cans labeled “Extremely Flammable” and three small
propane cylinders on an open shelf in the tool room. These items were not included on the
inventory and were not stored in the fire resistant cabinet. The deficiencies were corrected onsite
by adding the items to the inventory and placing them in the appropriate storage cabinet.
UCJ maintains a master index of chemicals and their locations, and a master listing of Material
Safety Data Sheets (MSDS). ODO verified the index is reviewed semi-annually as required;
however, a copy of the index has not been supplied to the local fire department and did not
include a listing of emergency phone numbers. Meeting these NDS requirements supports the
safety and well-being of detainees, visitors, and staff. Informing the local fire department of all
chemicals stored at UCJ facilitates emergency response in the case of an emergency involving
flammables, chemical poisoning, or accidental contamination.
Four deficiencies were identified under the Detention Files NDS. ODO reviewed 20 randomly
selected active detention files, and 15 randomly selected inactive detention files. None of the 20
randomly selected active files contained a Form I-385 (Alien Booking Record) or a classification
worksheet. The NDS requires these forms to be included in detention files to facilitate the
proper classification of detainees. This is a repeat deficiency from the February 2011 ODO
inspection. None of the15 randomly selected inactive detention files contained a properly
executed Form I-203 (Order to Detain or Release Alien), because the box ordering release had
not been checked. ERO management stated that this deficiency would be addressed and
corrected immediately, and properly completed forms will be provided to UCJ prior to the
release of detainees from UCJ custody. This NDS requirement promotes safety and security by
ensuring that only eligible and vetted detainees are released.

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No deficiencies were identified under the Food Service NDS. Food Service is provided by UCJ
employees with support from UCJ inmates. No detainees work in food service. Documentation
of pre-employment health screenings was available for all food service employees and inmate
workers. ODO observed the staff is actively involved in the preparation and service of meals to
ensure that food items are correctly prepared, served at the appropriate temperatures, and
properly presented. ODO verified religious and medically prescribed meals are provided and
properly documented. The kitchen is well equipped and maintained in a high state of
cleanliness.
There were no deficiencies identified under the Medical Care NDS. Medical services at the UCJ
are provided by the Utah County Sheriff’s Office. UCJ is accredited by the NCCHC. ODO
toured the medical clinic, reviewed policies and procedures, examined medical records, verified
medical staff credentials, inspected staff clinical files, and interviewed the Health Services
Administrator (HSA), Nursing Supervisor, Mental Health Coordinator, the dentist,(b)(7)enurses,
and other staff. ODO reviewed 30 detainee medical records and confirmed that intake screening,
tuberculosis testing, medications, treatment for special and chronic needs, and follow up care are
administered in accordance with the standard. Consent for treatment was obtained in all cases
reviewed. Detainees access medical care by completing written medical requests available in
English and Spanish and submitting them to an RN when medication is dispensed, which occurs
twice daily. ODO verified medical requests are triaged, and detainees are seen for sick call in a
timely manner.
Physician trained RNs conduct physical examinations (PE) at UCJ. ODO verified the physician
reviewed the PE in each of the 30 cases reviewed, and all 30 detainees received a PE the same
day as intake, which is well within the 14-day timeframe required by the NDS. This expedites
the identification of medical issues requiring attention. ODO cites this as a best practice.
Medical follow up for detainees with chronic care needs occurs every three months; however,
appointments are scheduled sooner if medically indicated. The UCJ system for tracking chronic
care cases uses an electronic medical record system developed by medical staff. The system
helps ensure follow up appointments are scheduled and completed, which supports timely access
to care. ODO cites the use of an electronic medical record system as a best practice.
UCJ operates an SMU for male detainees and one for female detainees. Both SMUs are well
ventilated, adequately lit, appropriately heated, and maintained in a sanitary condition. All cells
are equipped with a sink, toilet, and single concrete bed with a mattress. Written procedures are
in place to temporarily segregate detainees for administrative reasons. Detainees are assigned to
administrative segregation while awaiting a disciplinary hearing on serious rules violations.
SMU is not used for detainees with mental health issues. Detainees with significant mental
health issues are not held at UCJ.
One deficiency was identified under the Special Management Unit – Administrative Segregation
NDS. There were no male or female detainees in administrative segregation during the CI.
However, a review of the detention files of four male detainees recently placed in administrative
segregation confirmed that not one of the four detainees had received a segregation order.
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Failure to issue segregation orders violates the NDS as well as established written procedures at
UCJ. This is a repeat deficiency from the February 2011 ODO inspection. Issuing and
providing detainees with a copy of a segregation order informs the detainee of the reason for
placement in segregation and ensures due process.
No deficiencies were identified under the Staff-Detainee Communication NDS. ICE
Immigration Enforcement Agents (IEA) and Supervisory Detention and Deportation Officers
(SDDO) conduct weekly announced and unannounced visits to housing units to address detainee
concerns and inquiries as required by the Model Protocol on Staff-Detainee Communication.
IEAs from the Provo, Utah sub-office perform the scheduled weekly detainee liaison visits at the
UCJ. These visits are documented in an ICE dedicated logbook located in each housing unit.
There were no deficiencies identified under the Suicide Prevention and Intervention NDS. ODO
reviewed facility policy, the suicide prevention training curriculum, and(b)(7)emedical and(b)(7)enonmedical staff training records. ODO inspected cells used for suicide watch, and interviewed
medical staff and the training manager. ODO verified that no detainees were placed on suicide
watch during the 12 months preceding the CI. Local policy is current and exceeds NDS
requirements. UCJ Staff conducts monitoring checks every 15 minutes that are electronically
documented utilizing a computerized wand system. This wand system ensures detainee safety
and officer accountability. UCJ acknowledges staff members who identify and take appropriate
action when signs of suicidal ideation are observed. Staff are recognized via cash awards or
certificates of appreciation in order to support heightened awareness and proactively prevent
detainee suicides. ODO cites this as a best practice.
There was one deficiency identified under the Use of Force NDS. By definition, an immediate
use of force situation is created when a detainee’s behavior constitutes a serious and immediate
threat to self, staff, another detainee, property, or the security and orderly operation of the
facility. A calculated use of force incident is warranted when no immediate threat is posed, and
there is sufficient time to potentially diffuse the situation without resorting to force. UCJ
management stated there had been no reports of calculated or immediate use of force incidents
involving detainees since the February 2011 ODO Inspection; however, while ODO was
reviewing the files of detainees previously placed in administrative segregation, an incident
report dated April 28, 2012, documented an immediate use of force used to stop a fight between
two detainees when one detainee refused to obey an order to cease. Officers put the aggressive
detainee on the floor and applied restraints. Incident reports and medical evaluations of the
detainees were completed, but there was no After-Action Review as required by the NDS and
facility policy. This deficiency was corrected onsite. An After-Action Review of the incident
that occurred on April 28, 2012, was conducted and documented. UCJ management provided a
copy of the After-Action Review to ERO and ODO. UCJ has a comprehensive policy governing
the Use of Force. Law enforcement staff receives training in Use of Force techniques during the
initial 11-week Utah Law Enforcement Training Academy. Post academy, staff completes eight
hours of Use of Force training annually, and 40 hours of refresher training every two years.

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

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

INSPECTION TEAM MEMBERS

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

Special Agent (Team Leader)
Detention and Deportation Officer
Special Agent
Contract Inspector
Contract Inspector
Contract Inspector

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ODO, Phoenix
ODO, Phoenix
Creative Corrections
Creative Corrections
Creative Corrections
Utah County Jail
ERO Salt Lake City

OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed supervisory ICE and UCJ staff, including the UCJ Deputy Chief, a Lieutenant,
and the ERO AFOD. ODO also interviewed an SDDO and a Corrections Officer. UCJ staff
stated that ERO personnel conduct weekly visits to detainee housing units at the facility. UCJ
management stated the county is under budgetary constraints. At the time of the inspection,
there were (b)(7)e vacant deputy positions. During interviews, ICE and UCJ personnel stated the
working relationship between the two agencies is positive, and morale is high.
ICE management stated they have the necessary resources to carry out their duties and
responsibilities, but the permanent assignment of a Detention Service Manager (DSM) would
greatly enhance the efficiency of ERO by providing additional guidance and oversight of
operations at UCJ.

DETAINEE RELATIONS
ODO interviewed four male and four female detainees to assess the overall detention conditions
at UCJ. The detainees stated they are treated with dignity and respect, and they receive daily
recreation, send and receive mail, use the telephones, and have access to grievance forms. All
detainees have seen Immigration Enforcement Agents and Deportation Officers visit the housing
units on a regular basis, and all knew how to contact ICE ERO. None of the male detainees
complained about medical, but three of the four (75%) female detainees complained that medical
responses to their sick call requests had taken too long. ODO confirmed that all three females
had been seen by medical staff within two days of submitting their sick call requests, which is in
compliance with the NDS.

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 18 NDS and found UCJ fully compliant with the following 14
standards:
Access to Legal Material
Admission and Release
Detainee Grievance Procedures
Detainee Handbook
Disciplinary Policy
Food Service
Funds and Personal Property
Medical Care
Special Management Unit (Disciplinary Segregation)
Staff-Detainee Communication
Suicide Prevention and Intervention
Telephone Access
Terminal Illness, Advance Directives, and Death
Tool Control
As these 14 standards were compliant at the time of the review, a synopsis for these areas was
not prepared for this report.
ODO found deficiencies in the following four standards:
Detention Files
Environmental Health and Safety
Special Management Unit (Administrative Segregation)
Use of Force
ODO findings for each of these standards are presented in the remainder of this report.

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DETENTION FILES (DF)
ODO reviewed the Detention Files standard at UCJ to determine if files are created containing
all significant information on detainees housed at the facility for over 24 hours, in accordance
with the ICE NDS. ODO reviewed detention files, logbooks, policies and procedures, toured the
admissions and release area, and interviewed staff.
As part of the intake process, staff creates a detention file when a detainee is admitted to the
facility. ODO randomly selected 20 active and 15 inactive detention files for review to
determine if required documentation was present.
All of the 20 active detention files reviewed contained original photographs, personal property
inventory sheets, and receipts for property and baggage. None of the 20 active files reviewed
contained Form I-385 (Alien Booking Record) or a classification work sheet, which are required
by the NDS to be in every detention file (Deficiency DF-1). A Form I-385 contains a picture of
the detainee, fingerprints, the alien registration number, and in and out booking dates. A
Detainee Classification System-Primary Assessment Form is used to evaluate criminal history.
ICE requires the use of a classification form as a guide for placing detainees into housing units
with detainees of the same or compatible classification levels. This is a repeat deficiency from
the February 2011 ODO inspection.
All 15 inactive detention files reviewed contained a Form I-203 (Order to Detain or Release), but
the box for release was not properly checked, and the date and time that an official authorized the
release were not indicated on the forms. Officers must mark the designated release box and note
the date and time of release, then sign the bottom of the I-203. All 15 inactive files were missing
the original I-385 (Deficiency DF-2). ODO determined ERO failed to provide UCJ with a Form
I-203 authorizing a detainee’s release for each of the 15 inactive files reviewed. ICE ERO stated
this issue would be corrected immediately, and a properly executed I-203 will be provided to
UCJ prior to the release of every detainee in the future.
UCJ does not permit the removal of detention files from the processing area. All contents of the
detention files are scanned and are accessible from the UCJ server. The NDS requires facilities
to have a logbook to document when detention files are checked in and out from the processing
area (Deficiency DF-3). Although detention files have been digitized, the original files continue
to be maintained at UCJ. The NDS requires a tracking system for those hard files. A log enables
facility management to track the original detention files if they get lost or misplaced. This is a
repeat deficiency from the February 2011 ODO inspection.
ERO does not create and maintain detention files at the ERO Field Office, because detention
files are created and filed at UCJ (Deficiency DF-4). The AFOD stated that this will not be
addressed due to lack of resources, and a request for a waiver for this requirement has been
submitted to ERO HQ and is awaiting approval.

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STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DF-1
In accordance with the ICE NDS, Detention Files, section (III)(B)(1)(a)(b), the FOD must ensure
the detainee detention file will contain either originals or copies of forms and other documents
generated during the admissions process. If necessary, the detention file may include copies of
material contained in the detainee’s A-file.
The file will, at a minimum, contain the following:
a. I-385, Alien Booking Record; one or more original photograph(s) attached;
b. Classification Work Sheet.
DEFICIENCY DF-2
In accordance with the ICE NDS, Detention Files, section (III)(E)(2)(3), the FOD must ensure
staff will insert into the released detainee’s detention file copies of completed release documents,
the original closed-out receipts for property and valuables, the original I-385 and other
documentation, and the officer closing the detention file will make a notation (on the
acknowledgement form, if applicable) that the file is complete and ready for archiving.
DEFICIENCY DF-3
In accordance with the ICE NDS, Detention Files, section (III)(F)(2)(a-e), the FOD must ensure
that at a minimum, a logbook entry recording the file’s removal from the cabinet will include:
a. The detainee’s name and A-number;
b. Date and time removed;
c. Reason for removal;
c. Signature of person removing the file, including title and department;
d. Date and time returned; and
e. Signature of person returning the file.
DEFICIENCY DF-4
In accordance with the ICE NDS, Detention Files, section (IV), the FOD must ensure the field
office with IGSA-facility jurisdiction shall create and maintain detention files on all detainees
admitted to IGSA facilities. These files shall contain the same material (forms and other
documents) as SPC/CDF [Service Processing Center/Contract Detention Facility]detention files,
to the extent possible, given that they are created by the field office. For example, if the field
office takes and holds detainee property, the detention file shall contain the G-589’s [sic] and I77’s [sic]. The file shall also contain copies of all I-203’s [sic] and the G-385 related to the
alien. The IGSA shall forward all documents relating to the individuals [sic] detention to the
INS field office of jurisdiction for inclusion into the detention file.

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ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Environmental Health and Safety standard at UCJ to determine if the facility
maintains high standards of cleanliness and sanitation, safe work practices, and control of
hazardous materials and substances, in accordance with the ICE NDS. ODO toured the facility,
interviewed staff, and reviewed policies and documentation of inspections, hazardous chemical
management, and fire drills.
The facility has a system for storing, issuing, and maintaining inventories of hazardous materials.
Hazardous substances are stored in a fire resistant storage cabinet in the maintenance area.
While inspecting the area, ODO found two aerosol cans labeled “Extremely Flammable” and
three small propane cylinders on an open shelf in the tool room. These items were not included
on the inventory (Deficiency EH&S-1), and were not stored in the fire resistant storage cabinet
(Deficiency EH&S-2). UCJ management added the items to the inventory, and they were placed
in the appropriate storage cabinet prior to completion of the CI.
UCJ maintains a master index of chemicals and their locations, and a master listing of Material
Safety Data Sheets (MSDS). ODO verified the index was reviewed semi-annually as required by
the NDS; however, a copy of the index had not been supplied to the local fire department, and
there was no listing of emergency phone numbers (Deficiency EH&S-3).
Monthly fire drills were conducted on each shift, and documentation is on file. Reports for water
and pest control services are current and readily available. ODO verified the emergency power
generator is tested weekly for a period of 40 minutes and documented, but testing of the
generator by an external generator service company has not occurred for more than two years
(Deficiency EH&S-4). UCJ management stated the cost of testing by an external company is
prohibitive.
Barbering services are provided by a contractor who visits the facility once a week. Detainees
pay $9.00 for a haircut. Indigent detainees are provided service at no charge. Detainees with
less than $1 on their account for 14 consecutive days are declared indigent. Barbering takes
place in housing unit dayrooms. Sanitation regulations are not posted (Deficiency EH&S-5).
This deficiency was cited during the February 2011 Quality Assurance Review. ODO was
unable to confirm adherence to sanitation regulations in practice, because the contract barber was
not on site during the review.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EH&S-1
In accordance with ICE NDS, Environmental Health and Safety, section (III)(A), the FOD must
ensure every area will maintain a running inventory of the hazardous (flammable, toxic, or
caustic) substances used and stored in that area.

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DEFICIENCY EH&S-2
In accordance with ICE NDS, Environmental Health and Safety, section (III)(F)(1), the FOD
must ensure any liquid or aerosol labeled “Flammable” or “Combustible” must be stored and
used as prescribed on the label, in accordance with the Federal Hazardous Substances Labeling
Act, to protect both life and property.
DEFICIENCY EH&S-3
In accordance with ICE NDS, Environmental Health and Safety, section (III)(C), the FOD must
ensure the Maintenance Supervisor or designate will compile a master index of all hazardous
substances in the facility, including locations, along with a master file of MSDSs. He/she will
maintain this information in the safety office (or equivalent), with a copy to the local fire
department. Documentation of the semi-annual reviews will be maintained in the MSDS master
file.
The master index will also include a comprehensive, up-to-date, list of emergency phone
numbers (fire department, poison control center, etc.).
DEFICIENCY EH&S-4
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(O), the FOD
must ensure the emergency power generator will also receive quarterly testing and servicing
from an external generator-service company.
DEFICIENCY EH&S-5
In accordance with ICE NDS, Environmental Health and Safety, section (III)(P)(1)(4), the FOD
must ensure the [barbering] operation will be located in a separate room not used for any other
purpose.
Each barbershop will have detailed hair care sanitation regulations posted in a conspicuous
location for the use of all hair care personnel and detainees.

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SPECIAL MANAGEMENT UNIT (SMU)
Administrative Segregation (AS)
ODO reviewed the Special Management Unit – Administrative Segregation standard at UCJ to
determine if the facility has procedures in place to temporarily segregate detainees for
administrative reasons, in accordance with the ICE NDS. ODO toured each SMU, interviewed
staff, and reviewed policies, logbooks, and detainee files.
UCJ operates one SMU for male detainees and one for female detainees. They are separate.
Both are well ventilated, adequately lit, appropriately heated, and maintained in a sanitary
condition. All cells are equipped with a sink, a toilet, and a single concrete bed with a mattress.
There are written procedures in place to temporarily segregate detainees for administrative
reasons. UCJ management stated the primary reason for assignment to administrative
segregation is to await a disciplinary hearing for a serious rules violation. Facility staff and the
ICE supervisor stated the SMU is not used for detainees with mental health issues. Detainees
with significant mental health issues are not held at UCJ. There were no detainees in
administrative segregation during the review.
ODO reviewed the files of four detainees previously placed in administrative segregation. None
contained administrative segregation orders (Deficiency SMU-1). Failure to issue segregation
orders violates the NDS as well as UCJ established written procedures. This is a repeat
deficiency from the February 2011 ODO inspection. A hearing notice is issued to all detainees
charged with rules violations. The notice states the detainee will see the Disciplinary Hearing
Officer, but does not order or address placement in the SMU. The notice does not apply to
detainees who may be assigned to the SMU for other reasons. Providing detainees with a copy
of the segregation order informs them of the reason for the assignment and ensures due process.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SMU-1
In accordance with the ICE NDS, Special Management Unit - Administrative Segregation,
section (III)(B), the FOD must ensure a written order shall be completed and approved by a
supervisory officer before a detainee is placed in administrative segregation, except when
exigent circumstances make this impracticable. In such cases, an order shall be prepared as soon
as possible. A copy of the order shall be given to the detainee within 24 hours, unless delivery
would jeopardize the safety, security, or orderly operation of the facility.

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USE OF FORCE (UOF)
ODO reviewed the Use of Force standard at UCJ to determine if necessary Use of Force is
utilized only after all reasonable efforts have been exhausted to gain control of a subject, while
protecting and ensuring the safety of detainees, staff and others, preventing serious property
damage, and ensuring the security and orderly operation of the facility, in accordance with the
ICE NDS. ODO toured the facility, inspected equipment, and reviewed the local policies,
training records, and other pertinent documentation.
UCJ has a comprehensive policy governing the Use of Force. Staff receives training in use of
force techniques during the initial 11-week Utah Law Enforcement Training Academy. Post
academy, staff completes eight hours of use of force training annually and 40 hours of refresher
training every two years. UCJ management does not use four-point restraints, but uses a restraint
chair and a restraint stretcher to move combative detainees. UCJ management stated that a
restraint chair or stretcher has never been used on a detainee.
ODO confirmed there had been no reports of calculated or immediate use of force incidents
involving detainees since the February 2011 ODO inspection. By definition, an immediate use
of force situation is created when a detainee’s behavior constitutes a serious and immediate
threat to self, staff, another detainee, property, or the security and orderly operation of the
facility. A calculated use of force incident is warranted when no immediate threat is posed, and
there is sufficient time to potentially diffuse the situation without resorting to force. UCJ
management stated there had been no reports of calculated or immediate use of force incidents
involving detainees since the February 2011 ODO Inspection; however, while ODO was
reviewing the files of detainees previously placed in administrative segregation, an incident
report dated April 28, 2012, documented an immediate use of force used to stop a fight between
two detainees when one detainee refused to obey an order to cease. Officers put the aggressive
detainee on the floor and applied restraints. Incident reports and medical evaluations of the
detainees were completed, but there was no After-Action Review as required by the NDS and
facility policy (Deficiency UOF-1). This deficiency was corrected onsite. An After-Action
Review of the incident that occurred on April 28, 2012, was conducted and documented. UCJ
management provided a copy of the After-Action Review to ERO and ODO. UCJ has a
comprehensive policy governing the Use of Force. Law enforcement staff receives training in
Use of Force techniques during the initial 11-week Utah Law Enforcement Training Academy.
Post academy, staff completes eight hours of Use of Force training annually, and 40 hours of
refresher training every two years.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use of Force, section (III)(K), the FOD must ensure written
procedures shall govern the use-of-force incident review, whether calculated or immediate, and
the application of restraints. The review is to assess the reasonableness of the actions taken
(force proportional to the detainee's actions), etc. IGSA will pattern their incident review process
after INS. INS shall review and approve all After Action Review procedures.
Office of Detention Oversight
May 2012
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Utah County Jail
ERO Salt Lake City

The After-Action Review Team shall complete and submit its After-Action Review Report to the
OIC within two working days of the detainee’s release from restraints. The OIC shall review
and sign the report, acknowledging its finding that the use of force was
appropriate/inappropriate.

Office of Detention Oversight
May 2012
OPR 201207727

14

Utah County Jail
ERO Salt Lake City