Office of Detention and Removal Operations
U.s. Department of Homeland Security
425 I Street, NW
Washington, DC 20536

u.s. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

FROM:
SUBJECT:

oj
,-/>tf~ v

Ronald 1. Smith

(b)(6), (b)(7)(C)

tional Facility Plan of Action

The San Diego Correctional Facility Plan of Action (POA) dated February 4, 2005, has been
received but not accepted. The Plan of Action was developed in response to the Annual Review
conducted by the Headquarters Detention Standards Compliance Unit (DSCU) August 31 through
September 2, 2004.
The Plan of Action from the Corrections Corporation of America did not address all the deficiencies,
citing contract requirements or lack thereof. The proposed Plan of Action for detainee telephone
issues is not acceptable to ICE. The Plan of Action from the United States Public Health Service is
accepted as written.
The Field Office must 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 ofthis memorandum. Notification shall include a copy of this
memorandum.
2) The Field Office is responsible for continuing to monitor contract performance and
compliance with ICE National Detention Standards until a new contract is awarded.
Should you or your staff have any questions regarding this matter, please contact
Deputy Assistant Director, Detention Management Division at (202) 305 b2 high

b6, b7c

,

Office of Detention and Removal Operations

U.S. Depllrtment of Homeland Security
425 I Street NW
Washington. DC 20536

U. S. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

FROM:

SUBJECT:

San Diego C

ctional Facility Annual Detention Review

Headquarters Detention and Removal Operations conducted a Detention Review of the San Diego
Correctional Facility from August 31 through September 2, 2004, in San Diego, California. A final
rating of Acceptable has been assigned.
The rating was based on the Reviewer-In-Charge (RIC) Summary Memorandum and supporting
documentation. The Field Office Director must remedy the deficiencies in the RIC Memorandum,
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 oftrus memorandum. Notification shall include copies of the
Form G-324A, Detention Facility Review Form, the G-324A worksheet, RIC 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, (POA) 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 and follow-up on
the above noted deficiencies within 90 days.

Subject: San Diego Correctional Facility Annual Detention Review
Page 2
Should you or your staffhave any questions regarding this matter, please contact
Acting Deputy Assistant Director, Detention Management Division at (202) 305

b6, b7c
b2 high

,

Ar(zce of Deten/ion and Removal OperariollS

.S. Departmen t of Homeland Se(,Ulity
425 T Street. NW
Washington. DC 20536

U.S. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

Victor X. Cerda
Acting Director

FROM:

b6, b7c

b6, b7c

Reviewer-In-Charge
HQDROIDMDIDSCB
SUBJECT:

San Diego Correctional Facility Detention Review Summary Report.

The Detention Management Division, Detention Standards Compliance Branch, performed a
Headquarters Detention Review of the San Diego Correctional Facility in San Diego, California
from August 31 through September 2, 2004. This is a Contract Detention Facility (CDF) operated
by
rporation of America (CCA). The review was p
the guidance
b6, b7c
b6, b7c
of
, Reviewer-In-Charge. Team members included
, HQDRO,
b6, b7c
b6, b7c
b6, b7c
EI Paso DRO,
, Dallas DRO and
, EI Centro DIHS.
Type of Review
This review is a scheduled Headquarters Review, which is performed to determine overall
compliance with the Immigration Customs Enforcement (ICE) Detention Standards. The facility
received a previous rating of "Good" during the August 2003 review.
Review Summary
The American Correctional Association (ACA) accredited the San Diego Correctional Facility in
January 2002. The facility is currently scheduled for ACA re-accreditation. The facility also
received accreditation by the National Commission on Correctional Health Care (NCCHC) in July
2002 and the Joint Commission on Accreditation of Health Organizations (JCAHO) in August 2004.
Standards Compliance
The following information is a summary of the standards that were reviewed and overall compliance
that was determined as a result of the 2003 and 2004 detention reviews:
2003 Review
Compliant
Deficient
Repeat Deficiency

32
4

4

2004 Review
Compliant
Deficient
Repeat Deficiency

32

5
3

Memorandum for Victor X. Cerda
San Diego Correctional Facility Review Summary Report
Page 2

•

Detainee Classification System - Repeat Deficiency
•
•

The facility was found to be deficient for not using color-coded wristbands or unifonns to
categorize the detainees' custody levels.
The facility conducts classification at intake. Reclassification between 45 and 60 days after
arrival is not conducted. Subsequent reassessments are not conducted every 60 and 90 days.

Detainee Telephone Access - Repeat Deficiency
•

Detainee telephones are located in an area immediately below the housing unit television set.
This location is deficient because it does not allow detainees a reasonable degree of privacy
during telephone conversations. The facility could remedy this deficiency by moving the
unit television and by providing privacy panels.
Q

Telephone stations do not provide the standard requirement of unimpeded privacy
during use.

Access to Medical Care - Deficient
•

Detainee interviews conducted by the PHS reviewer yielded several complaints from
detainees who claimed they had to submit multiple sick call requests before being seen in the
clinic.

•

The San Diego facility experienced a sudden rise in population in early July (from an average
of approximately 1250 daily to approximately 1600 daily). All resources of the detention
facility, including DIHS, have been challenged to deal with this increased demand for
services.

•

Patient care areas of the clinic are adequate in tenns of space. However, the popUlation
growth and expanded volume of services have rendered obsolete the original space provision
of certain non-patient care areas such as the phannacy (which doubled in stafl).
Q

The opening a of a new detention facility adjacent to the ICE detention facility that
offers higher hourly wages contributed to a net loss of seven nurses in a short time
period.

Memorandum for Victor X. Cerda
San Diego Correctional Facility Review Summary Report
Page 3

•

Detention Files - Repeat Deficiency
•

Detention files are prepared at intake. Copies of grievances, complaints, disciplinary and
segregation forms are not maintained within these files for record keeping.

Staff-Detainee Communications Standard-Deficient
The Staff-Detainee Communications components are in place in order to allow for formal and
informal contact between ICE staff and detainees. Neither the facility nor the ICE office maintain an
effective monitoring tool to demonstrate that this standard is effectively being implemented. The
facility does not maintain copies of detainee request form responses. Response copies should be
maintained for a period of at least three years.
Significant Observations and Best Practices
Access to Legal Material - Best Practice
The law library is maintained and well equipped with computers and typewriters to enable detainees
to prepare their cases. The law librarian, Officer b6, b7c is very knowledgeable in the library
operation and in the requirement of access to legal material by special management detainees. The
librarian maintained security consciousness and he advised that periodic searches of the library are
performed to prevent items from being transferred between units via the library.
Food Service - Significant Observation
The kitchen was reviewed immediately after breakfast was served. During clean up, kitchen workers
assured reviewers that safety was observed. Floors were kept mopped and free of food waste to
prevent injury. Surface areas on walls and floors were well kept and clean. Food tray carts did not
show signs of grit building up near the wheel area of the cart. The kitchen is supervised by a Food
Service Administrator who has a broad and well-experienced background. Satellite feeding was
observed and food temperatures were maintained effectively. Workers practiced cleanliness by
wearing plastic gloves and hairnets.
Staff Appearance - Significant Observation
ICE and contract security staff dressed appropriately and presented a neat appearance. They seemed
very knowledgeable about their individual post assignments. Staff was also very thorough in
conducting searches of incoming personnel to prevent contraband from entering the facility via the
main entrance.

Memorandum for Victor X. Cerda
San Diego Correctional Facility Review Summary Report
Page 4

•

RIC Observations

During the last two reviews, the same deficiencies have been identified. CCA and the ICE Field
Office have failed to rectify the deficiencies, as there may be contractual issues that are involved. A
new contract is scheduled to be awarded January 1,2005. The Warden of the facility, the ICE
Officer-In-Charge and their entire staff were very supportive of the review team and assured the
team unimpeded access to the facility throughout the review. This facility is well managed.
RIC Issues and Concerns:

The facility recently commenced supporting the Arizona Border Initiative by providing bed space
for approximately 250 detainees. This added support has made it a challenge for ICE staff and the
medical unit, to manage these cases and to provide daily medical service. Staffing the medical unit
to meet the volume of health care at this facility should be a priority.
Recommended Rating and Justification:

The Reviewer-In-Charge recommended that the facility receive a rating of "Acceptable. " The
facility complies with 32-of-37 applicable ICE Detention Standards. The facility should respond to
all findings and initiate a Plan of Action in response to the deficiencies.
RIC Assurance Statement:

The fmdings of compliance and noncompliance are documented on the G-324a Inspection form and
are supported by documentation in the review file.

_~.ADQUARTERS

•

EXECUTIVE REVIEW

The signature below constitutes review of this report and acceptance by
receipt of this report to respond to aU imdings and recommendatio

uthority. OlC/CEO will have ~~ from

HQDRO EXECUTIVE REVIEW: (Please Print Name)

Victor X. Cerda
Title

Actin Director

Final Rating:

0

Superior
Good
[8] Acceptable
Deficient
OAt-Risk

o
o

Comments:
The Review Authority concurs with the Reviewer-In-Charge (RIC) recommended rating of "Acceptable"
based on the RIC Memorandum and G324A worksheets. The facility must submit a plan of action within 30 days
describing remedies for the deficiencies that are noted in the RIC Memorandum. Oversight is required to ensure
Immigration and Customs Enforcement detainees are managed according to the National Detention Standards.

Form G-324A (Rev. 8/1/01) No Prior Version May Be Used Mter 12131101

e

u.s. Department Of Homeland Security

-Detention Facility Review Form
Facilities Used Over 72 hours

U.S. Immigration and Customs Enforcement

181

o

E.
Accreditation Certificates
Accredited By:
ACA: i8I
NCCHC: 181 JCAHO: f2I
Date: 08104
Date: 01102
Date: 00102

ICE Service Processing Center
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

A. Current I
ction
Type of Review
Field Office tEl HQ Review
Date[s] of Review
Au ust 30 throu S tember 2, 2004

Problems I

Deficient D At-Risk
B. Name and Location of Facility
Name
Otay Mesa Detention Facility (ODF)
Correctional Corporation of America (CCA)
Address (Street and Name)
446 Alta Road, Suite S400
City, State and Zip Code
San Dieg<). California 921 S8
County
San Diego
Name aDd TItle of Chief Executive Ol'fiter (WlII'deniOlCISuperlntendent)
b6, b7c
Warden
'1'elephone # (Include Area Code)
;;19) 661-9119

DIstrict
SND
Distance from District Office
25 Miles

C. ICE Information
Name of Reviewer (Last Name, Title and Duty Station)
R
D&D Officer, HQ-DRO
b6, b7c
I Title of Team Members (Reviewers)
b6, b7c
Immigration Enforcement Agent
Deportation Officer
b6, b7c
Controlling Field Office
San Diego
Nearest Field or Sub· Office
Western
D CDFIIGSA I n r.ormation 001ly
Contract Number
Date of Contract or IGSA
ACL-O-C-OOOI
July 23, 1998
Basic Rates per Man-Day
91.40/ICE 900=60.00
Other Charges: (If None, Indicate N/A)
N/A
;
;
;
Estimated Man-days Per Year
ICE 334,058 (1-900) 6,793 (901-1150)

I

G. Facility History
Date BuUt
March 1999
Date Last Remodeled or Upgraded
March 2002
Date New Construction I Bedspace Added

N/A
Future Construction Planned
Date:
Current 8edspace
Future Bedspace
N/A
1453

D Yest:8JNo

I

H. Total Facility Population
Total Intake for previous 12 months
11,781
Total Mandays for Previous 12 months
446,443
Classification Level (ICE spes and CDFs Only)
L-l
L-2
L·3
349
57
355
I Adult Male
192
10
31
I Adult Female
I.

Facility Ca Ilacity
Rated
1000
I Adult Male
200
I Adult Female

Operational

1250
200

A verage Daily P
opuIatlOn
·
ICE
881
I Adult Male
243
I Adult Female

USMS
294
25

Emergency
1700
300

Other
64
0

Staff'mg Level
:
b2 high

b2 high

Form G-324A (Rev. 9/25/03) No Prior Version May Be Used After 12131103

Significant Incident Summary Worksheet
or ICE to complete its Review of your facility, the following information must be completed prior to the scheduled review dates.
The information on this form should contain data for the past twelve months in the boxes provided. The information on this form is
used in conjunction with the ICE Detention Standards in assessing your Detention Operations against the needs of the ICE and its
detained population. This form should be filled out by the facility prior to the start of any inspection.

Assault:

Offenders on
Offenders l
17

7

PHYSICAL

PHYSICAL

PHYSICAL

PHYSICAL

0

0

0

0

8

6

2

2

3

7

0

0

2

0

4

7

0

0

0

0

0

0

UNK

UNK

UNK

Assault:

Detainee on
Staff

1# Times FourlFive Point
~srraints applied/used

UNK

Offender I Detainee Medical

Referrals as a result of injuries
sustained.

o

Escapes

o

o

Grievances:

ror

11

4

122

68

19

13

7

20

Any attempted pbysical contact or physical contact that involves two or more offenders
Oral, anal or vaginal penetration or attempted penetration involving at least 2 parties, whether it is consenting or oon-consenting
Routine transportation of detaineesloffend= is not considered "forced"
Any incident that involves four or more detainees/offenders. includes gang fights. organized multiple bunger strikes, work stoppages. hostage situations,
major fires. or other large scale incidents.

Form G-324A (Rev. 9/25/03) No Prior Version May Be Used After 12131103

Access

6.
7.
8.
9.

10.
11.
12.
13.
14.
15.
I 16.
17.

Admission and Release
Classification System
Correspondence and Other Mail
Detainee Handbook
Food Service
Funds and Personal Property
Detainee Grievance Procedures
Issuance and Exchange of Clothing, Bedding, and Towels
Marriage Requests
Non-Medical Emergency Escorted Trip
Recreation

18.
19.

24.
25.
26.
27.
28.
29.
30.
31.
32.
33 .
34.
35 .
36.
37 .
38.
39.

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 Units (Administrative Segregation)
Special Management Units (Disciplinary Segregation)
Tool Control
Transportation (Land management)
Use of Force
Staff 1 Detainee Communication
Detainee Transfer
Detainee Search

All rmdings (At-Risk, Repeat Deficiency and Deficient) require wri.t teo comment describing the finding and what is necessary
to meet compliance.

Form G-324A (Rev. 9/25/03) No Prior Version May Be Used After 12131103

RIC Review Assurance Statement

By signing below, the Reviewer-In-Charge (RIC) certifies that all findings of noncompliance with policy or inadequate controls
contained in the Review Report are supported by evidence that is sufficient and reliable. Furthermore, findings of noteworthy
accomplishments are supported by sufficient and reliable evidence. Within the scope of the review, the facility is operating in
accordance with applicable law and policy, and property and resources are efficiently used and adequately safeguarded, except for the
deficiencies noted in the report.

Reviewer· In-Charge: (Print Name)
b6, b7c

b6, b7c

TItle & Duly Location

Detention and De

Se tember 13,2004

rtation Officer, HQ-DRO

Print Name & Duty Location

Print Name & Duty Location

EI Paso, Texas

b6, b7c

Print Name & Duty Location

Print Name & Duty Location
b6, b7c

Dallas, Texas .

lUC Rating Recommendation:

o Superior

o
Good
l?SJ Acceptab1e

D Deficient
OAt-Risk
RIC Comments:

Form G-324A (Rev. 9125/03) No Prior Version May Be Used After 12131103

•

•

Section I
Detainee Services Standards

Page 3
G-314A Detention Inspection Fortll Worksheet for IGSAs
Rev: 09125103

ACCESS TO LEGAL MATERIALS
Policy Facililies holding ICE detainees shall permit detainees access to a law Jtnry, and pr<Mde legal
materials, faciIties, equipment and document copying. privileges, and the opportunIyto prepare legal documents.

Components
The facility provides a designated law library for detainee
use.
The library contains a sufficient number of chairs, is well
lit and Is reasonably Isolated from noisy areas.
The law library Is adequately equipped with typewriter,
computers or both and has sufficient supplies for daily
use by the detainees.
Outside persons and organizations are permitted to
submit published legal material for inclusion in the legal
library. Outside published material is forwarded and
reviewed by the ICE prior to inclusion.
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 library.
The facility supplements Attachment A materials with
Lexis Nexis Law Ubrary.
There Is a designated employee who inspects, updates,
and maintain/replace legal material and equipment on a
routine basis. The designee proper1y disposes outdated
supplements and replaces damaged or missing material
promptly.
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 library.
Detainees may request material not currently in the law
library. Each request is reviewed and where appropriate
an acquisition request is initiate and timely pursued.
Request for copies of court decisions are accommodate
within 3 - 5 business da~.
The facility pannits detainees to assist other detainees,
voluntarily and free of charge, in researching and
preparing legal documents, consistent with security.
ICE staff ensures that illiterate or non-English-speaking
detainees without legal representation receive more than
access to English-/anguage law books after indicating
their need for helP.
Detainees may retain a reasonable amount of personal
legal material in the general population and in the special
management unit. Stored legal materials are accessible
within 24 hours of a written request.
Detainees housed in Administrative Segregation and
Disciplinary Segregation units have the same law 6brary
access as the general population, barring security
concems. Detainees denied access to legal materials
are documented and reviewed routinely for lifting of
sanctions.
All denials of access to the law library fullY documented.

A

U

NA

I2l

0

0

I2l

0

0

~

0

0

0

0

~

I2l

0

0

I2l

0

0

Remarks

Viewed six computers and
three typewriters. Tested
machines.

/

Viewed same.
Officer

b6, b7c

is assigned

to this post and is .

I2l

0

0

responsible for these
duties.
Viewed schedule.

~

0

0

~

0

0

IZI

0

0

I2l

0

0

IZI

0

0

~

0

0

[J

[]

-~

~

Page 4
G-324A Detention Irupeetion Form Worksheet for IGSAs
Rev: 09/25103

long as they are within
the same unit.

No denials

ACCESS TO LEGAL MATERIALS
Policy Facilities holding ICE detainees shan permit detainees access to a law 1baJy, and provide legal
materials, facilities, eq~and documentcopving ~ and.th.~~~__ doCunents.
.. 'fIlA
A'
Remarks
CompoMnts
No
denials
ICE Management is aware of each instance where
detainees are denied access to the law library or law
0
0
~
materials.
Detainees who seek judicial relief on any matter are not
~
0
0
subjected to reprisals, retaliation, or penalties.
):t1.~,

ACCESS TO LEGAL MATERIALS - Rating
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
standard Rating:
~ Acceptable

0

Deficient

o At-Risk

o Repeat Finding

Remarks: (Record signfflcant facts, observations,. alternate source used for verification, etc.)

b6, b7c

Page 5
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

ADMISSIONS AND RElEASE - Rating
When rated below Acceptable, faciities must attach a Plan of Action for bringing operations into
compflance. For each element found out of compliance, the plan of action Win specify remedial action and
the estimated timetable for compfiance.
Standard Rating:

[8J Acceptable 0 Deficient

o At..Risk

o Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, etc.)

b6, b7c

'j

Page 7
G-324A Detention IIIspection Form Worksheet for IGSA!
Rev: 09/25103

C~nONSYSTEM

Poley: All facilities will develop and implement a system according to which ICE de1aill8e8 are daa8ified. The
classification system will ensure that each detainee is placed in the appropriate category, physically separated
from detainees In other categories
Yes
No
Remarks
Components
NA
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 individuals who cannot be classified
upon arrival from the general population.
The
first-fine supervisor or designated
•
classification specialist reviewing every
classification decision.
The intake/processing officer reviews work-folders, Afiles, etc., to identify and classify each new arrival.
Staff use 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.
Housing assignments are based on classification-level.
A detainee's classification-level does not affect hislher
recreation opportunities. Detainees recreate with
persons of similar classification desig_nations.
Detainee work assignments are based upon
classification designations.
The classification process includes
reassessment/reclassification. Reassessments are
conducted between 45 and 60 days after arrival and
subsequent reassessments are completed every 60 to

~

0

0

I2l

0

0

[8J

0

0

~

0

0

~

0

0

[8J

0

0

~

0

0
Per Officer b6, b7c , no reclassification is done.

0

I2l

0

[8J

0

0

f.8I

0

0

cg]

0

0

0

f.8I

0

9Oda~.

The classification system includes standard procedures
for processing new arrivals' appeals. 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 business days.
Classification designations may be appealed to a higher
authority such as the Officer in Charge or equivalent.
The Detainee Handbook or equivalent for IGSAs
explains the classification levels, with the conditions and
restrictions applicable to each.

~neereceNescopy

Page 8
G-324A Detention mspection Form Worksheet for IGSAs
Rev: 09/25103

within 72 hours.

Page 13 doesn't explain
conditions and restrictions
applicable to each.

ClASSIFICATION SYSTEM - Rating
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action witl specify remedial action and
the estimated timetable for compliance.

Standard Rating:

o Acceptable

0

Deficient

o At-Risk

f8I Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, etc.)
The facility is stifl not using color-cocled uniforms or wristbands. ICE detainees are issued a green or pink
clip-on 10 card depending on gender, which can be easily removed.
Classification Officer b6, b7c also stated that no I1Klassffication is being done between 45 and 60 days after
arrival. He stated that once detainees are classified, "it's pretty much a done deal unless new information

the delain
b6, b7c

. re_:

W

Page 9
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25/03

CORRESPONDENCE AND OTHER MAIL
Policy: All facitiIIes will ensure that de1ainees send and receive correspondence ina timely manner, subject to
Imitations required for the safety, security. and orderly operation of the facility. Other mail wli be permitted,
subject to the same~. e.ctl fadlitywftJ widely distribute lis guidelines concerning correspondence and
other mail.
Yes No NA
Remarks
Components
The rules for correspondence and other mail are posted
in each housing or common area or provided to each
0
0
r8I
detainee via a detainee handbook.
The facility provides key information in languages other
[8l
than English; In the language(s) spoken by significant
0
0
numbers of detainees. List any exceptiQns.
Incoming mail distributed to detainees on the day it is
received by the facility and in no case more than 24
r8I
0
0
hours after it is received.
Outgoing mail routinely delivered to the postal service
[8l
within one day of its entering the internal mail system
0
0
(excludina weekends and holidays).
Staff records all priority, overnight, and certified mail
VIeWed (3) logs (ICE,
[8l
delivered by the U.S.P.S. and all deliveries from
0
0 Legal, and Certified Mail)
commercial alternatives to the U.S.P.S.
Staff do not open and inspect incoming general
All mail except legal mail
correspondence and other mail (mcluding packages and
is opened w/o detainees
[8l
publications) without the detainee present unless
0 present.
0
documented and authorized by the Officer-ln-Charge or
equivalent for prevailing security reasons.
Staff does not ever read incoming general
0
18'1
0
correspondence without the OIC's prior approval.
Staff does not inspect incoming special Correspondence
Unit Mgr. handles with the
[8l
for physical contraband or to verify the "special" status of
detainee
present
0
0
enclosures without the detainee ~esent.
Staff are prohibited from reading or copying incoming
181
0
0
special correspondence.
Staff are only authorized to inspect outgoing
correspondence or other mail without the detainee
present when there is reason to believe the item might
present a threat to the facility's secure or orderly
181
0
0
operation. endanger the recipient or the public, or might
facilitate criminal activity. Inspection of outgoing special
correspondence is done in the presence of the detainee
and for contraband only.
Correspondence to a politician or to the media is
pro~ as special correspondence and is not read or
181
0
0
copied.
The official authorizing the rejection of incoming mail
181
0
0
sends written notice to the sender and the addressee.
The official authorizing censorship or rejection of
outgoing mail promes the detainee with signed written
181
0
0
notice.
Staff maintains a written record of every item removed
181
0
0
from detainee mail.
The OIC monitors staff handling of discovered
Viewed documentation
contraband and its disposition. Records are accurate and
181
0
0 folder for rejected items.
up_to date.

Page 10
G-324A Detention Inspection Fonn Worksheet for IGSAs
Rev: 09125103

CORRESPONDENCE AND OTHER MAL
Policy: All facilities will ensure that detainees send and receive correspondence in a timely manner, subject to
limitations required for the safety, security, and 0fderIy operation of the facility. Other mail wiD be permitted,
subject to the same imitations. Each facility will widely disbibute Hs guidelines concerning correspondence and
other mal.
The procedure for safeguarding cash removed from a
detainee is effective. The amount of cash credited to
detainee accounts is accurate. Discrepancies are
181
0
0
documented and investigated. standard procedure
includes issuing a receipt to the detainee.
Original Detainee identity documents (e.g., passports,
are turned
181
0
0 Documents
birth certificates) are maintained A-files.
over to ICE.
staff provides the detainee an ICE-certified copy of
181
0
0
hislher identity document(s) upon request.
Prohibited items are
Staff disposes of prohibited items found in detainee mail
in accordance with the ·Control and Disposition of
returned to sender unless
0
181 0 they
Contraband" standard or the similar prevailing policy in
are illegal
IGSAs.
contrabandO.e.drugs).
Every indigent detainee has the opportunity to mail, at
Need to fill our Indigent
government expense: Correspondence about a legal
Form with Unit Mgr.
I8l
0
0
matter: At least three other letters per week: Packages
deemed necessary by ICE.
The facility has a system for detainees to purchase
stamps and for mailing all special correspondence and a
181
0
0
minimum of 5 pieces of general correspondence per
week.
The facility provides writing paper, envelopes, and
I8l
0
0 If indigent.
J:)encils at no cost to ICE detainees.
CORRESPONDENCEANDOTHERM~-~

When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:

181 Acceptable 0

Deficient

o

At-Risk

o Repeat Finding

*Remarks: (Record signifiesnt facts, observations, other sources used, etc.)

b6, b7c

Page 11
G-324A Detention Inspection Fonn Worksheet for IGSAs
Rev: 09125103

DETAINEE HANDBOOK
Policy: Every OIC will develop a site-specific detainee handbook to serve as an overview of, and guide to, the
detention policies, rules, and procedures in effect at the fadIity. The handbook wiR also describe 11'18 services,
programs, and opportunities available through various sources, including the facility, ICE, private organizations,
etc. E'J8ry detainee will receive a copy of this handbook upon admission to the facility.
.
Components
Yes
No
NA
Remarb
Viewed both handbooks.
The detainee handbook is written in English and
translated into Spanish or into the next most-prevalent
0
181
0
Language(s).
The handbook supplements the facility orientation video
181
0
0
where one is provided.
Per Assistant Warden
All staff members receive a handbook and training
181
0
0
regarding the handbook contents.
The handbook is revised as necessary and there are
procedures in place for immediately communicating any
0
0
181
revisions to staff and detainees.
There an annual review of the handbook by a
181
0
0 Revised May 2004
designated committee or staff member.
Page 2 of handbook
The detainee handbook address the following issues:
• Personal Items permitted to be retained
0
0
121
• by the detainee.
• Initial issue of clothes.
The detainee handbook states in clear language basic
121
0
0 Pages 1-2 of handbook
detainee responsibilities.
The handbook clearly outlines the methods for
Page 13 of handbook
classification of detainees, explains each level, and
181
0
0
explains the classification appeals process.
The handbook identifies: Initial issue of clothing and
Page 2 of handbook
181
0
0
bedding and personal hygienettems.
Consistent w/need as
The handbook states when a medical examination will
0 stated on page 5.
181
0
be conducted.
The handbook describes the facility, housing units,
dayrooms, In-<torm activities and special management
181
0
0
units.
The handbook describes; Official count times and count
Throughout handbook on
various pages.
procedures Meal times, feeding procedures,
procedures for medical or religious diets, additional
181
0
0
information, Smoking policy, Clothing exchange
schedules and if authorized, clothes washing and drying
procedures and expected personal hygiene practices.
See untt schedule on page
The handbook describe times and procedures for
obtaining disposable razors and allows that detainees
2 of handbook.
121
0
0
attending court will be afforded the opportunity to shave
first.

The handbook describes barber hours and hair cutting
restrictions.
The handbook describes; the telephone poHcy, debit
card procedures, direct and frees calls; Locations of
telephones; Policy when telephone demand is high;
Policy and procedures for emergency phone calls, and
the Detainee Message System.
The handbook addresses religious programming.

181

0

0

Page 5 of handbook
Page 4 of handbook

181

0

0

181

0

0

Page 12
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25/03

Page 3 of handbook

e·
DETAINEE HANDBOOK
Poley: Every OIC wli develop a aiIIHpedfic detainee handbook to serve as an oveMew of, and guide to, the
detention policies, rules, and procedures in effect altha facIly. The handbook wit also d8SCl'l)e the seNices,
programs, and opportunIies .avaiIabI81hrough variOus scuces. ~uding the faciIIty,ICE, PIMIte organizations,
etc. Every detainee will receive a ~ of this hatldbook upon adl'nission to the facIily.
Components
Yes
No
NA
Remarks
Page 6 of handbook
The handbook states times and procedures for
commissaJy or vending machine usage. (where
f81
0
0
avaIable)
The handbook describes the detainee voluntary work
0
0 Page 3 of handbook
f81
program procedures and pay procec!ures.
The handbook describes the library location and hours
f81
0
0
of operation and law library procedures and schedules.
Page 8 of handbook
The handbook describes; attomey visiIation hours;
Location of the list of pro bono legal organizations;
~
0
0
Group legal rights presentations schedule and ~n up
procedures.
Only describes search, but
The handbook describes the facility search procedures
0
~
0 nothing about contraband.
and contraband policy.
Page 7 of handbook
The handbook describes the facility visiting hours and
~
0
0
schedule and'{isiting rules and regulations.
The handbook describes the correspondence policy and
~
0
0 Page 9 of handbook
procedures.
Doesn't specify time limits
The handbook describes the detainee disciplinary policy
in the disciplinary process.
and procedures:
Including:
0
f81 0
• Prohibited acts and severity scale sanctions.
• Tme limits in the Disciplinary Process.
• Summary of Disciplinary Process.
Doesn't state how to
The grievance section of the handbook explains all
appeal. Only states the
steps in the grievance process -Including:
time
frames. Doesn't
procedures;
Informal
and
formal
grievance
•
make
mention about filing
The
appeals
process
and
step-by-step
•
an appeal with ICE,
procedures;
availability of help during
• In CDFsIIGSA facilities: procedures for filing an
appeal with ICE.
f81
0 grievence, guarantee
0
against retaliation, or how
Stalfldetainee
availability
to
help
during
the
•
to file complaint with DOJ.
grievance process
• Guarantee against staff retaliation for
filing/pursuing a grievance.
• How to file a complaint about officer
misconduct with the Department of Justice.
The handbook describes the detainee grievance
~
0
0
procedures Including appeals.
The detainee handbook describes the sick call
~
0
0
procedures for general population and segregation.
The handbook describes the faCility recreation policy
including:
• Outdoor recreation hours.
0
~
0
• Indoor recreation hours.
• In dorm leisure activities.
• Rules for television viewing.
Pages 8-9 of handbook.
The handbook describes the detainee dress code for
~
0
0
daily living; Work assignments.

Page 13
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

DETAINEE HANDBOOK
Policy: Every OIC will develop a site-specific detainee handbook to serve as an overview of, and guide to, the
detention policies, rules, and procedures in effect at the faelly. The handbook will also describe the services,
programs, and opportunities available through various sources. including the facility, ICE, private organIZations,
etc. Every detainee wi" receive a copy of this handbook upon admission to the facily.
Components
YeS
No
NA
Remartcs
The handbook specifies the rights and responsibilities of
all detainees.

!81

0

0

DETAINEE HANDBOOK - Rating
When rated below Acceptable, faciliHes must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

!81 Acceptable 0

o At~isk

Deficient

o Repeat Finding

aRemarks: (Record significant facts, observations, other sources used, etc.)
*Advisory*

The handbook was updated to reflect previously missing information, specifically information regarding the
law library and pro bono organizations. The handbook still does not contain all the information required by
the DMCP Standard. However, the G-324A Worksheet was updated and the facility was unaware of the
changes and thus had no way of knowing what new information was required to be contained in the
handbook, specifically question # 9 on page 13 of the worksheet.
The grievance section doesn't explain the appeals process. It only addresses the time frame.
The handbook doesn't address the procedure for filing an appeal with ICE or a grievance v.ffh DOJ.
The handbook doesn't address staff/detainee availability to help during the appeal process.
The handbook doesn't address the issue of guarantees against retaliation from staff for filing a grievance.
It also fails to address the following:
There was nothing found within the handbook regarding contraband policy. Only the search policy was
addressed.
The disciplinary policy and procedures don't specify time limits in the Discipline Information Section. It is
only referred in the Offense Categories Appendix in the back of the handbook. Facility stated that they

to

to
b6, b7c

Signature Date

imits In the Discipline Information Section.

9~7
J

Page 14
G-324A Detention Inspection Form Worksbeet for IGSA!!
Rev: 09/25103

FOOD SERVICE

Policy: Every facility will provide detainees in its care \Wh nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.
Components

Yes

The food service program is under the direct
supervision of a professionally trained and certified
service administrator. Responsibilities of cooks and
cook foremen are in writing. The FSA detennines the
responsibilities of the Food Service Staff.
The CS 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-<luty cook foreman maintains control of the
key that locks the device.
All knives not in a secure cutting room are physically
secured to the workstation and staff directly supervise
detainees using knives at these workstations. Staff
monitor the condition of knives and dining utensils
Special procedures govern the handling of food items
that pose a security threat.
Standard operating procedures include daily searches
(shakedowns) of detainee work areas.
The FSA monitor staffs implementation of the facility's
counting procedures. These procedures in written fonn
and staff are trained in counting procedures.
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
descriptions to ensure they are accurate and up-to-date.
The CS instructs newly assigned detainee workers in
the rules and procedures of the food service
department.
During orientation and training session(s), the CS
explains and demonstrates:
• Safe work practices and methods.
• Safety features of indMdual productsJ pieces of
equipment.
• Training covers the safe handling of hazardous
material[s] the detainee are likely to encounter
in their work.
The CS documents all training in individual detainee
detention files?
Detainees are paid in accordance with the "Voluntary
Work Program" standard or prevailing IGSA standards.

No

NA

[81

0

0

[81

0

0

Remarks
FSA has 23 years with
U.S. Navy. CS has 11
years of experience.

Also via video

[81

0

0

0

0

~

0

0

~

0

0

~

[81

0

0

Dough cutters attached to
table. No knives in
facility.
Meats are pre-cut.

None of these products
used.

2x per week

[81

0

0

181

0

0

181

0

0

[81

0

0

181

0

0

0

~

0

~

0

0

Page 15
G-324A Detention Inspeetion. Form Worksheet for IGSAs
Rev:091l5103

Viewed kitchenlfood
service area.

No centralized files in
place.
$1.00/day

FOOD SERVICE

Policy: Every facility will provide detainees in its care with nutritious and appetizing meals, prepared in
accordance with the highest sanilalY standards.
Components
Yes
NA
Remarks
No
Detainees are served at least two hot meals evelY day.
No more than 14 hours elapse between the last meal
served and the first meal of the following day.
A transparent "sneeze guard" protects both the serving
line and salad bar line.
The facility has a standard 35-day menu cycle. IGSAs
use a 35 day or similar system for rotating meals.
The FSA or facility considers the ethnic diversity of the
facility's detainee population when developing menu
cycles. (provide examples)
A registered dietitian conducts a complete nubitional
analysis of every master-cycle menu planned.
The CS has established procedures to ensure that
items on the master-cycle menu are prepared and
presented according to approved recipes.
The CS has the authority to change menu items if
necessary.
• If yes, documenting each substitution, along
with its justification
• With copy to FSA
All staff and volunteers know and adhere to written
"food preparation" procedures.
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.
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 daity allowances (RDAs).
Staff routinely provides hot water for instant
beverages and foods.
• Common-fare meals are served with:
Disposable plates and utensils.
Reusable plates and utensils.
Staff
use separate cutting boards, knives,
•
spoons, scoops, etc., to prepare the commonfare diet items.
A Supervisor at the command level must approve a
detainee's removal from the Common-Fare Program.

~

0

0

0

0

~

0

~

0

~

0

0

FSA considers Hispanic
and Asian population.

~

0

0

Dietitian.

~

0

0

~

0

0

~

0

0

~

0

.0

~

0

0

~

0

0

181

0

0

•

•
•
•

The OIC, in conjunction with the Chaplain and/or local
religious leaders, provide the FSA a schedule of the
ceremonial meals for the followinjl calendar ~.

Page 16
G-324A Detention Inspection Form Worksheet for IGSA!I

Rev: 09125103

Food is brought to pods.
28-day menu is used.

b6

is Registered

Currently 20 detainees
receiving religious meals.

FOOD SERVICE
Policy: Every facility will provide detainees in its care >Mth nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.
NA
Remarks
Components
Yes
No
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 obselVe 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
Frida~ durin{t Lent
The food service program addresses medical diets.

f8I

0

0

•

f8I

0

0

Sateliite-feeding programs follow guidelines for proper
sanitation.

f8I

0

0

Hot and cold foods are maintained at the prescribed,
"safe" temperature(s) after two hours.

f8I

All meals provided in nutritionally adequate portions.

f8I

Food is not used to punish or reward detainees based
upon behavior.

[8l

0
0
0

0
0
0

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 equipment
Everyone wor1<ing in the food service department
complies with food safety and sanitation requirements .
a. If not, explain non-compliance.
Standard operating procedures include weekly
inspections of all food service areas, including dining
and food-preparation areas and equipment.
• who conducts the inspections?
Equipment is inspected for compliance with health and
safety codes and regulations.
When was the most recent inspection?
• Which agency conducted the inspection?
Reports of discrepancies are forwarded to the OIC or
AOIC and corrective action is scheduled and
completed.
Standard procedure includes checking and
documenting temperatures of all dishwashing machines
during each meal.
Staff documents the results of every refrigerator! freezer
temperature check.

On-going

•

•

The cleaning schedule for each food service area is
conspicuously posted.

f8I

0

0

f8I

0

0

r2l

0

0

f8I

0

0

f8I

0

0

f8I

0

0

&gI

0

0

0

f8I

0

Morning and afternoon
inspections are conducted
well
as
as weekly
inspections.
June 2004 was last
inspection by San Diego
County Health Dept.
VIS maintenance log

Page 17
G-324A Detention Inspection Form Worksheet for IGSA!
Rev: 09125103

Schedule is posted
FSA's office only.

in

FOOD SERVICE
Policy: Every facility wil provide detainees in its care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.
Components
Procedures include inspecting all incoming food
shipments for damage, contamination, and pest
infestation.
Storage areas are locked when not in use.

Yes

No

NA

~

0

0

181

0

0

Remarks

FOOD SERVICE - Rating
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

I2l Acceptable 0

Deficient

o At-Risk

o Repeat Deficiency

-Remarks: (Record significant facts, observations, other sources used, etc.)
Cleaning schedule is not conspicuously posted in the kitchen area. The on/ycopy is posted in the FSA's
.
office.
Standard calls for 35-<1ay menu cycle. Facility is utilizing a 28-day menu cycle. Contract shows that facility
to uti/'
1-day menu cycle.
. n/y
b6, b7c

Page 18
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25103

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
documentation and. receipting of surrendered property; and the initial and regularty scheduled inventoryi1g of aU
funds, valuables, and other property.
Standard NA: Check this box if alICE detainee Funds, Valuables and Property are handled only by
the ICE Field Office or Sub-Office in control of the detainee case.

o

nts
C
Detainee funds and valuables are property separated
and stored away. Detainee funds and valuables are
accessible to designated supervisor{s) only.
Detainees' large valuables are secured in a location
accessible to designated supervisor(s) or processing
staff only.
Staff itemizes the baggage and personal property of
arriving detainees, including funds and valuables). E2!
IGSAs and CDFs, using a personal property inventory
form that meets the ICE standard?
staff forwards an arriving detainee's medicine to the
medical staff.
Staff searches arriving detainees and their personal
property for contraband.
There is a written policy for returning forgotten property
to detainees and staff follows procedures?
Property discrepancies are immediately reported to the
CDEO or Chief of Security.
Staff follows written procedures when returning property
to detainees.
CDFIIGSA facility procedures for handling detainee
property claims are similar with the ICE standard.
The facility attemp1s 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;
• VIS certified mail;
• The notice state that the detainee has 30 days in
which to claim the property, after which it will be
considered abandoned.
The facility cflSpoSBS of abandoned property in
accordance with written procedures.
• If a CDFIIGSA facHity, written procedure requires
the prompt forwarding of abandoned property to
ICE.

Yes

No

NA

r2l

0

0

r2l

0

0

r2l

0

0

r2l

0

0

r2l

0

0

121

0

0

r2l

0

0

r2l

0

0

r2l

0

0

r2l

0

0

r2l

0

0

Page 19
G-J24A Detention Inspection Form Worksheet for IGSAs

Rev: 09125103

Remarlcs

Per staff

VIeWed lost property
forms.
Warden and OlC are
notified.

Viewed post orders.

FUNDS AND PERSONAl. PROPERlY · RJding
When rated below Acceptable, faciities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compiiance.

Standard Rating:
~ Acceptable

0

o At-Risk ·

Deficient

o Repeat Finding

*Remarks: (Record significant facts, observations, other SOLNCeS used, etc.)
~m was clean and very well organized.
b6, b7c

or's SIgnature Date

.

~.;
/

Page 20
G-324A Detention bupec:tioa Fol'lll Worksheet for IGSAs
Rev: 09/25/03

GROUP lEGAL RIGHTS PRESENTATIONS
Policy: Faciities housing ICE detainees shan pennit authorized persons to make preseiilalions to groups of
detainees forthe purpose of Infoming them of U.S. immigration IfM and procedures, coosisIant... the S8CUIIy
and orderly operation of each faclly. ICE encourages such presentations, which instruct detainees about the
Immigration system and their r1Jhts and options wlhin it.
121 Check bent if No Group Presentations ware conducted within the past 12 months. Marte Standard as
Acceptable overall and continue on with next portion of worksheet.
Yes
No
Components
NA
R.....-ks
The Field Office is responsive to requests by attorneys
0
0
0
and accredited representatives for group presentations.
Upon receipt of concurrence by the Field Office Director,
the facility or authorized ICE Field Office ensures proper
0
0
0
notification to attorneys or accredited representatives in a
timely manner.
The facility follows policy and procedure when rejecting
or requesting modifications to objectionable material
0
0
0
provided or presented by the attorney or accredited
representative .
Posters announcing presentations appear in common
areas at least 48 hours in advance and sign-up sheets
0
0
0
are available and accessible.
Documentation is submitted and maintained when any
detainee is denied permission to attend a presentation
0
0
0
and the reason(s) for the denial.
When the number of detainees allowed to attend a
presentation is limited, the facility allows a sufficient
0
0
0
number of presentations so that all detainees signed up
may attend.
Detainees in segregation and unable to attend for
security reasons may request separate sessions with
0
0
0
presenters. Such requests are documented.
Interpreters are admitted when necessary to assist
0
0
0
attorneys and other legal representatives.
Presenters are afforded a minimum of one hour to make
the presentation and to conduct a question-an<i-answer
0
0
0
session.
Staff permits presenters to distribute ICE-approved
0
0
0
materials.
The facility permits presenters to meet with small groups
of detainees to discuss their cases after the group
presentation. ICE or authorized detention staff are
0
0
0
present but do not monitor conversations with legal
providers.
Group presenters who have had their privileges
suspended are notified in writing by the Field Office
Director or atsignee; and the reasons for suspension are
documented. The Headquarters Office for Detetnion and
0
0
0
Removal, Field Operations and Detention management
Division is notified when a group or individual is
suspended from making presentations.
The facility plays ICE-approved vkieotaped presentations
on legal rights, at regular opportunities at the request of
0
0
0
outside organizations.

Page 21
G-324A Detention hupeetion Form Worksheet for IGSAs

Rev: 0912510J

-

-

-

-

---

- --- - ---

- - ~ -- - -- - - - - --- -- --------------------

A copy of the Group Legal Rights Presentation policy,
including attachments, is available to detainees upon
r uest

o

o o

GROUP LEGAL RIGHTS PRESENTAUONS
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

f8l Acceptable 0

Deficient

o At-Risk

o Repeat Finding.:.-------.....

b6, b7c

Page 22
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

---------~-----------------

DET~EGREVANCEPROCEDURES

Policy: Every facility will develop and implement standard operating procedures (SOPs) for addrBSSi1g detainee
grievances in timely fashion. Each step in the process will occurwithin the prescribed time frame. Among oCher
things, a grievance will be processed, investigated, and decided (subject to appeal) in accordanceYtth the SOPS;
a grievance committee will convene as provided in the SOPS. Standard procedure will include provking the
detainee with a written response to any formal grievance, which wli include the basis for1he decision. The faciIty
will also establish standard procedures for handling emergency grievances. All grievances will receive !
supervisOlY review. Reprisal against the filer of a grievance will not be tolerated.
No
Components
Yes
NA
Remarks
Written procedures provide for the informal resolution
of oral grievances.
r8I
0
0
• If yes, the detainee has up to five days within
which to make hisJher 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.
r8I
0
0
• Illiterate, disabled, or non-English-spealdng
detainees receive special assistance when
necessary.
Every member of the staff knows how to identify
emergency grievances, including the procedures for
0
r8I
0
expediting them.
There are no documented substantiated cases of staff
harassing, disciplining, penalizing, or otherwise
0
0
r8I
retaliating against a detainee who lodges a complaint
• If yes, exPlain.
Procedures include maintaining a Detainee Grievance
Viewed log
Log.

•

If not, an alternative acceptable record keeping
system is maintained.
• "Nuisance complains" are identified in the
records.
• For quality control purposes, staff documents
nuisance complaints received but not filed.
Staff is required to forward any grievance that includes
officer misconduct to a higher official or, in a CDFJ1GSA
faCility, to ICE.

r8I

0

0

I8i

0

0

Page 23
G-324A Detention Inspection Form Worksheet for IGSAli
Rev: 09125103

~----~~~---~--~-------------------

DETAINEE GRIEVANCE PROCEDURES - Rating
When rated below Acceptable, facilities must attach a Ptan of Action for bringing operations into
compHance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compiance.
Standard Rating:
~ Acceptable

0

Deficient

o At-Risk

o Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, etc.)
b6, b7c

f

Page 24
G-J24A Detention Inspection Form Worksheet for IGSAII
Rev: 09/25/03

ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS
Policy: ICE requires that aU facilities housing ICE detainees provide clean clothing, bedcillQ, linens and towels to
every ICE detainee upon arrival. Further, facilities shall provide ICE detainees wIh regtUr 8lIChaI1geS of clothing,
linens, and towels for as long as 1hey remain in detention.

Yes

Components
The 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, temperatureappropriate, 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).
• One pair offacilm..icoc>t1ed footwear.
Additional clothing is available for changing weather
conditions or is seasonally appropriate.
New detainees are issued clean bedding, linens and
towel. They receive
• One mattress
• One blanket
One pillow
• Two sheets
One pillowcase
One towel
Additional blankets are issued based on local
weather conditions.
Detainees assigned to special work areas are clothed in
accordance with the requirements of the job.
Detainees are provided clean clothing, linen and towels.
• Socks and undergarments exchanged daily.
Outer garments at least twice weekly.
Sheets at least weekly.
Towels
at least weekly.
•
Pillowcases at least we~kJy.
Food service detainee volunteer workers permitted to
exchange outer garments daily.
Volunteer detainee workers are permitted to exchanges
of outer garments more frequently.

•

•

No

NA

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

•

•
•
•
•

•
•

Remarks
Inventory = 4 x population

•

Page 25
G-324A Detention .Inspedioa Form Worksheet for IGSAs
Rev: 09125103

ISSUANCE AND EXCHANGE OF CLOlllNG, BEDDING, AND TOWELS - Rating
When rated below Acceptable, facilities must attach a Plan of Action for OOr9ng operations into
compUance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for complance.

I

Standard Rating:

181 Acceptable 0
·aad~:

Deficient

o At-Risk

o Repeat Finding

(Record signi6cartt facts, observations, other sources used, etc.)

b6, b7c

Page 26
G-324A Detmtion Inspection Fonn Worksheet for IGSAs
Rev:09/2~3

MARRIAGE REQUESTS
r~

case-by-case consideration from ICE management.
Components
Yes
No
NA
Remarks
Sent to ICE AOIC.
The Field Office considers detainee marriage requests
~
0
0
on a case-by-case basis.

Policy: All detainee marriage requests will

The Field Offcie Director reviews every marriage request
rejected by an OIC or IGSA. Rejections are
documented.
It is standard practice to require a written request for
permission to marry.
The written request includes a signed statement or
comparable documentation from the intended spouse,
confirming marital intent.
The OIC provides a written copy of hislher decision to the
detainee and his/her legal representative.
When permission is denied, the OIC states the basis for
hislher decision.
The OIC provides the detainee with a place and time to
make wedding arrangements.

~

0

0

I2$l

0

0

I2$l

0

0

~

0

0

r8I

0

0

r8I

0

0

VIeWed requests, folders,
documents.

Viewed same

Viewed same

Legal VISitation Room

MARRIAGE REQUESTS
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:

[8l Acceptable

0

Deficient

o At-Risk

o Repeat Finding

*Remarks: (Record significant facts, observations, ot#ler sources used, etc.)
Each case was well documented. Facility Chaplain was quite knowledgeable and maintained organized
r
b6, b7c

Page 27
G-324A Decention Iaspedion Form Worksheet for [GSAs
Rev: 09/25103

NON-MEDICAL EMERGENCY ESCORTED TRIPS

Pollc}r. The Immigration and Customs Enforcment (ICE) may provide detainees with staff-escorted1rips into the
community for the purpose of visiting critically ill members of the detainee's immediate family, or for attending

funerals.

I8l Standard NA: Check this box if aU ICE Non-Medical Emergency Escorted Trips are handled only by
the ICE Field Office or Sub-Office in control of the detainee case.
Yes
Remarks
No
Components
NA
The OIC considers and approves, on a case-by-case
basis, trips to immediate family member's:
• Funeral
Deathbed
The facility recognizes mother, father, brother, sister,
spouse, child, stepparent, and foster parent as
"immediate family".
The IGSA facility notifies ICE of all detainee requests for
non-medical escorts.

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

D

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

•

The Field Office Director is the approving official for nonmedical escorted trips.
The detainee's Deportation Officer reviews the file before
forwarding a detainee's request, with recommendation,
to the approving official. Each recommendation
addresses the Individual's suitability for travel, e.g., the
kind of St.!pervision ~uired.
Detainees who require overnight housing placed in
approved IGSA facilities.
Each escort includes at least two officers.
The detainee under constant, direct visual
supervision of escortillg staff.
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 completion of the trip.
Escorting officers have the discretion to: a. Increase or
decrease minimum restraints in accordance with written
instruction, procedures and classification level of the
detainee.
Escort officers do not accept gifts/gratuities from a
detainee detainee's relative or friend for any reason.
Escort 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.
Do
not arrange to visit famHy or friends unless
•
approved before the trip.
Make no unauthorized phone calls.
• Know they are subject to search, urinalysis,
breathalyzer, or comparable test upon return to
the facility.
Standard procedure requires the immediate retum to the
facility of any_detainee who violates trip rules.

•

•

Page 28
G-J24A Detention IDspection Form Worksheet (or IGSAs
Rev: 09125103

NON MEDICAL EMERGENCY ESCORT - Rating
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

121 Acceptable 0

Def'lcient

~Hr-=~"". (Record

o

At-Risk

o Repeat Finding

significant facts, observations, other sources used, etc.)

b6, b7c

Page 29
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25103

RECREATION
Policy: It is ICE policy to provide access to recreational programs and activities to aU ICE detainees, to the
extent possible, under conditions of security and supervision that protect their safety and welfare.
Yes
Components
Remarlcs
No
NA
Viewed outdoor
Does the facility provide:

An indoor recreation program?
An outdoor recreation program?
The recreational specialist (for facilities with more than

I2J

0

0

350 detainees) tailors the program activities and offerings
to the particular detainee population.
Regular maintenance keeps recreational facilities and
equipment in good condition.
The recreational specialist or trained equivalent
supervises detainee recreation workers.
The recreational specialist or trainined equivalent
oversees recreation programs for Special Management
Unit and special-needs detainees.
Dayrooms offer sedentary activities, e.g., board games,
cards, television.
Outside activities are restricted to limited-contact sports.
Each detainee has the opportunity to participate in daily
recreation.
Detainees have access to recreation activities 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 conducts searches of recreation areas before and
after use.
All recreation areas under constant staff su~rvision.
Supervising staff is equipped with radios.
The facility provides detainees in the SMU at least one
hour of outdoor recreation time daily.
Detainees in disciplinary segregation receive a written
explanation when a panel revokes hislher recreation
privileges.
Does the OIC review the panel's decision before it
becomes effective.
Detainees in administrative segregation receive a written
explanation for denied recreationaIJ){i~ileges.
Volunteer groups present special programs or religious
activities.
Volunteers 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
volunteers.
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 six-month detainee to the OIC.

I2J

0

0

I2J

0

0

C2l

0

0

C2l

D

0

C2l
C2l

D
0
0

0
0
0

I2J

0

0

121

0

0

C2l
121
121

0
D
0
0

0
0
0
0

121

0

0

I2J

0

0

C2l

0

0

0

0

121

0

0

C2l

I2J

0

0

0

0

121

0

0

121

•
•

r8l

~

Page 30
G-324A Detention mspedion Form Worbheet for IGSAs
Rev: 09125103

recreation and indoor
games .

Currently about 12-15
detainee volunteers.

Vtewedsame
Basketball
Minimum of 1 hour daily

If it were to occur, but
there were no known
instances.

RECREA110N
It is ICE policy to provide access to recreational programs and activities to all ICE detainees, to the
extent possibte, under conditions of security and supervision that protect their safety and welfare.
The OIC documents all detainee-transfer decisions,
t8l
0
0
whether yes or no.
The detainee's written decision for or against an offered
t8l
0
0
transfer documented in hislher A-file.
Staff notifies the detainee's legal representative of hislher
0
0
t8l
decision to accept/decline a transfer.
If no recreation is available, the ICE District routinely
0
0
t8l
review transfer eligibility for all detainees after 60 days.
Does the A-file of every detainee is held more than 60
days without access to recreation contains either a
transfer-waiver signed by the detainee or the OIC's
0
~
0
Wlitten determination of the detainee's ineligibility for
transfer.
The detainee's legal representative is notified of the
0
0
r8l
detainee'sIOIC's decision.
Policy:

RECREAOON • Rating
When rated below Acceptable, facilities must attach a Ptan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

t8l Acceptable 0

o At-Risk

Deficient

o Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, etc.)

Recreation Supervisor said that movies are shown on weekends. He also maintains special ·Chinesesets for the Asian population. There are also various tournaments such as basketball, chess,
Style"

b6, b7c

:;1
7

Page 31
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25/03

I

RELIGIOUS PRACTICES
Policy: Fad&ties will provide ICE detainees of all faiths with reasonable and equable o(lpOf1ldies to parti:ipatB
in the practices of their faith, limited only by the constrain1s of safety, security, the orderty operations of the faciity
and budgetary considerations.
Components

Yes

No

NA

Detainees are allowed to engage in religious services.
Space is avaRable for detainees to conduct religious
services.
The facility allows detainees to observe the major "holy
days" of their religious falth.
• Ust any exceptions.
The facility accommodates recognized holy-.day
observances by:
• Providing special meals, consistent with dietary
resmctions.
HonOring fasting requlremen1s.
Facilitating religious services.
Allowing activity restrictions.
Each detainee is allowed religious items in hislher
immediate possession.
Volunteer's credentials are checked and verified before
letting himlher participate in detainee programs.
Members of faiths not represented by clergy conduct
may request to present their own services within security
allowances.
Detainees in the Special Management Unit to participate
in religious practices unless otherwise documented for
the safety and security of the facility.

JZI

[J

D

~

0

0

~

0

0

IZI

0

0

121

0

0

121

0

0

121

0

0

~

0

0

•
•

Rematfcs

•

REUGIOUS PRACTICES
When rated below Acceptable. facilities must attach a Plan of Action for bringing operations into
compfiance. For each element found out of comp/iance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:
~ Acceptable

0

Deficient

o At-Risk

o Repeat Finding

·Remartl::s: (Record significant facts, observations, other sources used, etc.)
b6, b7c

4

Page 32
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

DETAINEE TELEPHONE ACCESS

Policy: All facilities housing ICE detainees will permit detainees' reasonable and eqlilable access to telephones.
No
Components
Yes
NA
Remarks
Detainees allowed access to telephones during
established facility waking hours.

~

0

0

~

0

0

Page 4 of handbook

~

0

0

Viewed bulletin board

~

0

0

Viewed notices on bulletin
board in housing units.

181

0

0

8 phones per pod
68-102 detainees per pod

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

181

0

0

The facility administration promptly repor1s out-of-order
telephones to the facility's telephone service provider.

181

0

0

The facility administration monitors repair progress and
take appropriate measures to ensure that the required
repairs are begun and completed timely.

181

0

0

0

181

0

181

0

0

l8J
l8J

0
[J

0
0

l8J

0

0

[8l

0

0

~

0

0

l8J

0

l8J

0
IJ
0

l8J

0

0

181

0

0

181

0

0

181

0

0

Upon admittance, detainees are made aware of the
faci\itYs telephone access policy.
The telephone access rules are posted in each housing
area.
The facility makes a reasonable effort to provide key
information to detainees in languages spoken by any
significant portion of the facility's population.
Telephones are provided at a minimum ratio of one
telephone per 25 detainees in the facility population.

Detainees are afforded a reasonable degree of privacy
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 non-collect (special access) calls.
Spedal Access calls are at no charge to the detainees.
In facilities unable to fully meet this requirement initially
because of limitations of its telephone service, the ICE
makes alternate arrangements to provide required
access within 24 hours of a r~uest by a detainee.
No restrictions are placed on detainees attempting to
contact attorneys and legal seNice 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.
Use of general access phones is ordinarily not
restricted.
Any restrictions are documented.
The facility has a system for taking and delivering
emergency detainee telephone messages.
Emergency phone call messages are immediately given
to detainees.
Detainees are allowed to return emergency phone calls
as soon as possible.
Detainees in disciplinary segregation are allowed phone
calls relating to the detainee's immigration case or other
legal matters, including consuHation calls.
Detainees in disciplinary segregation are allowed phone
calls to consular/embassy officials.

[8l

[]

0

Page 33
G-J24A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

See comments

DETAINEE TELEPHONE ACCESS

Policy: All facilities housing ICE detainees will permit detainees' reasonable and equlable access" telephones.
Components

Yes

No

NA

Detainees in disclpHnary segregation are allowed phone
calls for fami emer ncies.
Detainees in lKtministrative segregation and protective
custody afforded the same telephoning privileges as
those in eneral
lation.
When detainee phone calls are monitored, notification is
posted by detainee telephones that phone calls made
by the detainees may be monitored. Special Access
calls are not monitored.

I8l

o
o

o
o

o

o

I8l
~

R8fINII'ks

DETAINEE TELEPHONE ACCESS - Rating
~----------------------------When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:

o Acceptable

0

Deficient

o At-Risk

~ Repeat Finding

--------------~--------------------~

*Remarks: (Record significantfacis, observations, other sources used, etc.)
The telephone system remains unchanged from the previous inspection. Telephones do not have privacy
panels. Telephones are still located under TVs in the housing units, making it difficult to have a
conversation or a reasonable degree of privacy.

b6, b7c

Page 34
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

VISITATION
Policy: ICE shall permit detainees to visit with family, friends, legal representa1ives, special interest groups and
the news mecfia.
Components

Yes

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

No

NA

~

0

0

(81

0

0

The visitation schedule and rules are available to the
public.

(81

0

0

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

181

0

0

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

181

A general visitation log is maintained.

(81

0
0

VISitors are searched and identified according to
standard requirements.

0
121
181

0
0
0
0
0

The requirement on visitation by minors is complied
with.

181

D

0

The detainees are permitted to retain personal property
item specified in the standard.
A visitor dress code is available to the public.

At facilities where there is no provision for visits by
minors, the ICE arranges for visits by children and
stepchildren, on request, within the first 30 days.
After that time, on request, ICE considers a transfer,
when possible, to a facility that will allow minor visitation.
At a minimum, monthly visits are allowed.
Detainees in special housing afforded visitation.

D

0

0
0

Posted in lobby
Metal detector

181

0

[8]

181
181

0
D

0
0

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

[8]

0

0

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

r2I

0

0

121

0

0

[8J

0

0

(81

D

0

181

0

0

Private consultation rooms are available for attorney
meetings. There is a mechanism for the detainee and
hislher representative to exchange documents.
There are written procedures governing detainee
searches.
When strip searches are required after (Wery contact
visit with a legal representative, the facility provides an
option for non-contact visits with I~al representatives.
Prior to each visit, legal service providers and assistants
are identified per the standard.

Rules are on visitation
request form.

(81

D

Legal visitation is available seven [T) days a week,
including holidays.

Remarks
Housing unit and
handbook

Page 35
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25/03

Unlimited

VISITATION

Policy: ICE shall permit detainees to visit with family, friends, legal representatives, special interest groups and
the news m$dia.
VIeWed list on bulletin
The current list of pro bono legal organizations is posted
in the detainee housing areas and other appropriate
181
0 boards in housing units.
D
areas.
The decision to permit or deny a tour is not delegated
181
0
0
below the level of Field Office Director.
Provisions for NGO visitation as stated in the Detention
[8J
0
0
standards are complied with.
Law enforcement officials, requesting to visit with a
Referred to CCA Chief of
detainee, are referred to the ICE Field Office for
Security.
[8J
0
D
approval.
Can visit if on approved
Former detainees or aliens in proceedings, requesting
list.
to visit with a detainee, are referred to the OIC or ICE
181
0
0
Field Office.

Procedures are in place, consistent with the detention
standard, for examinations by independent medical
service providers and experts.

181

D

0

Instances are rare, but
allowable.

VISITATION - Rating

When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:

181 Acceptable D Deficient

D

At-Risk

o Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, etc.)

b6, b7c

Page 36
G-324A Detention Inspeetion Form Worksheet for IGSAII
Rev: 09/25/03

VOLUNTARY WORK PROGRAM
Policy: In every faciity offering a voluntary work program, ICE detainees will have the opportunly to work and
earn money by participating. Whle not legally required, ICE affords detainee workers basic 0ccupeti0naI Safety
and Health Administration (OSHA) protections.

o Check here if the facility has a detainee work program and ICE delainHs are not authorized to work
at the IGSA facility. Mark NA on Form 0-324A, page 3 and move to next section.
Co
nts
Does the facility have a voluntary work program?
If yes, do detainees tx"'';'';t-le?
Detainee housekeeping meets neatness and cleanliness
standards.
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 Program.
The same procedures apply for replacement
workers as for "new" workers.
• Staff follows written procedures.
Where possible, physically and mentally challenged
detainees participate in the program.
The facility complies with work-hour requirements for
detainees, not exceeding:
• Eight hours a day.
Forty hours a week.
Detainee volunteers generally work according to fixed
schedule.
If a 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 program.
The voluntary work program meets:
• OSHA standards
NFPA standards
ACA
standards
•
Medical staff screens and formally certifies detainee food
service volunteers.
• Before the assignment begins
• As a matter of written procedure
Detainees receive safety equipment! training sufficient for
the assignment
Proper procedure is followed when an ICE detainee is
injured on the job.

•

Yes

No

NA

123

0

0

123

0

0

0

123

0

181

0

0

D

0

123

181

0

0

123

0

0

0

181

0

181

0

0

181

0

0

181

0

0

181

0

0

0

0

0

Remarks

Level1s can work outside
the secure perimeter.
This is allowable per
DMCP Standard.

None
Maximum allowed is:
7 hourslday
35 hours/week

•

•

Page 37
(;..J24A Detention Inspedion Form Worksheet for IGSAs
Rev: 09/25/03

Could be, but not always
forwarded to file per staff.

•

VOLUNTARY WORK PROGRAM - Rating

When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

t8l Acceptable 0

Deficient

o

At-RisK

o Repeat Finding

"Remarks: (Record significant facts, observations, other sources used, etc.)
*Advisory*

Per Interview with housing unit supeMsor, written justification is not always placed in the detainee's file
when removed from a work detail. This is usually the standard practice when a detainee quits a work detail.
DMCP Standard states that there must be written justification from the OIC placed in the detainee's file
wh ever
from a work detail.
b6, b7c

Page 38
G-324A Detention Inspection Form Worksheet for (GSAs
Rev: 09125103

•

Section II
Health Services
Standards

Page 39
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125/03

t,:~J~~:i;~/ .fl.)l/~X~~~E~;: Com~. . .··-

-

-;:.,~

{>.]~:

'1M

No

When a detainee has refused food for 72 hours, iris
standard practice for staff to refer him/her to the medical
department.

t8l , 0

0

CDFs and IGSAs immediately report a hunger strike to
the ICE.

t8l

0

0

The facility has established procedures to ensure staff
respond immediately to a hunger strike.

I8i

0

0

Policy and procedure require that staff isolate a hungerstriking 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.

~

0

0

I8i

0

0

Medical staff records the weight and vital signs of a
hunger-striking detainee at least once every 24 hours.

I8i

0

0

The OIC of the facility obtains a hunger striker's consent
before medical treatment.

I8i

0

0

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

181

0

0

During a hunger strike, staff documents and provides
the hunger-striking detainee three meals a day.

181

0

0

Staff maintains the hunger striker's supply of drinking
water/other beverages.

181

0

0

During a hunger strike, staff removes all food items from
the hunger striker's living area.

181

0

0

Staff is directed to record the hunger striker's fluid intake
and food consumption , does staff always use Hunger
Strike Monitoring Form 1-839. IGSA's use a similar
form .

I8i

0

0

The medical staff has written procedures for treating
hunger strikers.

181

0

0

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

I8i

0

0

Staff has received training in identification of hunger
strikes. Medical staff receives early training in hungerstrike evaluation and treatment. Staff remain current in
evaluation and treatment techniques.

'~¢i_' ~I~_,,", ~y

NA'

-

I

181

0

0

Page 40
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125/03

Staff has received
training however
documentation of this
needs to be more clearly
delineated.

....'-

~'.";.

"-:; '.-"

When rated below Acceptable, facilities must attach a Plan of ACtion for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action
and the estimated timetable for compliance.

Standard Rating:

181 Acceptable

o Deficient

o

At-Risk

o Repeat Finding

*Remarks: (Record significant facts, obseNations, other sources used, etc.)

Advisory· Recommend that documentation of training during orientation as well as annually have its own
category and the training outline be readily accessable. You might want to consider joint training sessions
since ICE, Medical and eeA all need this training. However due to the size of this facility this may not be
feasible.

b6, b7c

Page 41
G·324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25/03

i)'," '\"::) ;i~':'/i ,~; , > :y ~;:

.,""

'.',

, 1(: :,-'~~~; ;+ i";;f;"' ;, , "< ":,}:.,' '"

, ,,;' ~CCf;SS 'TQ:.MEDtc,.L;C~

~:P~i~j}~EV~': f~~~~iwill;· ~!b··~hd,,~aln~n ··~·;acCredi~~ed~~~~~Y;r~a[~~Piogfatti•.~~~·

1,,,g enaralwel-being:of
ICEdetSmees• ; •
" .\

"lit ;\ 1;; ~Comportalfts <~;

···.0·. '

: ,.... . .'"

" " " "": '

"

. ";C
" ',
;"\:.','"
"

'

IGSA facilities operate a health care facility in
compliance with State and Local laws and guidelines.
The facility's in-processing procedures of arriving
detainees include medical screening.

Yea

No

NA ...

0

0

r8'I

~

0

0

0

r8'I

0

0

0

r8'I

All detainees have access to and receive medical care.

For IGSAs. the district has access to a Managed Health
Care Coordinator.
The medical staff large enough to provide examine and
treat the facility's detainee population.

0

~

0

0

~

0

~

0

0

The facility has sufficient space and equipment to afford
each 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.

Page 42
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125/03

'."

i " '" ;:
" ' ; ' ,,,; ; "";.' ,,.': .' , '-"
n .. ; .•. .

': i

' ~i1'1a:~

. . ,<), .

The screenig area is
cramped and a long way
away from the x-ray
machine. There is
privacy but it does not
allow for timely
processi ng of new
screenings
There is not enough staff
to handle the volume at
this facility & therefore
they are are not seen in
sick call soon enough .
Many detainees told me
that they have submitted
3 and 4 sick call slips and
have not been seen yet.
One detainee told me he
had stomach pain for two
weeks & had not put in a
sick call slip because he
did not know the
procedure,

Recently there has been
an increase in the
detainee population by
250. There is also a high
detainee turn over rate .
This coupled with the fact
that recently 7 nurses
have resigned makes
staffing dangerously low
Again the design of the
cl inic is not conducive to
handleing the large
numbers of detainees
now at this facility.
They need a new fetal
heart monitor.

...

.. ... ..
c, ',:"

. c· .

T ,," ," " . ';'

.' ···

.':.c'

. ·c TO
. MEDICAL GARE. "'02',,
.',.;.,:;.
,
.. ' ' .

: .tc,C;n;~ , ACCESS

.

:': 51';', ·. >'

. , , ..•. , •• ;,c;:,;

..: •.~c

:

: .<CC.C

;"
,
: Policy: E;yeiy facility will establi~h and fTl8intain an accraditedJaccreditati0n-worthYL h~lth program fOJ', the
, ge~l we.ll-being of~CE deta~~ _ .:;
',.'
~
' ;, ' , . ..'.
' ', ' , ,.,,>':
There is a holdinglwaiting
The medical facility entrance includes a holdinglwaiting
area but it's not in the
room.
entrance. The
0
~
0 configration of the clinic is
a square within a squareand it is small
The medical facility's holding/waiting room under the
~
0
0
direct supervision of custodial staff.
Detainees in the holding/waiting room
0
~
0
have access to a toilet and a drinking fountain.
They have an excellent
Medical records are kept apart from other files. They
medical records
are:
department.
Secured
In
a
locked
area
within
the
medical
•
unit.
~
0
0
• With physical access restricted to authorized
medical staff.
• Procedurally, no copies made and placed in
detainee files.
[8l
Pharmaceuticals are stored in a secure area.
0
0
Medical screen ing includes a Tuberculosis (TB) test.
• Every arriving detainee receives a TB test.
• During the admission process.
• Detainee's TB-screening does not occur more
tg]
0
0
than one business day after his/her arrival at the
facility.
Detainees not screened are housed separate
from the general population.
The mental health
All detainees receive a mental-health screening upon
screenig is donearrival. It is conducted:
however I did find one
By
a
health
care
provider
or
specially
trained
•
chart that should have
officer;
[8l
0
0 been referred to a mental
• Before a detainee's assignment to a housing
health provider and was
unit.
not & later that same day
the detainee made a
suicide gesture.
The facility health care provider promptly reviews all 1[8l
794s (or equivalent) to identify detainees needing
0
0
medical attention.
The health care provider physically examines/assesses
They have fallen behind
arriving detainees within 14 days of admission.
on the P.E.s because of
[8l
0
0 the large work volume &
low staffing
Detainees in the Special Management Unit have access
[8J
0
0
to health care services .
Staff provides detainees with health- services request
The slick call slips are in
slips daily, upon request.
Spanish & English. No
other large language
• Request slips are available in the languages
groups
other than English, including every language
[gJ
0
0
spoken by a sizeable number of the facility's
detainee population .
• Service-request slips are delivered in a timely
fashion to the health care provider.
.

"'"

"

,

"

•

Page 43
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125/03

"

.'

· " . ::.. , ; . : . . ..
. ..; . >;.: .... :o' • •.. •. ..
' '' ;':;' : .''
. . .•: .. . . ~•.
'..
. .... ...
:,.«.":.,'",,, :.;..;... ........;,. . .,....
PolJcy: EyerY faCility ~ ~bliSh,~d rnaihtain an~ite(ilBcor~tlon~y·.t\~h .· p~rn~Nhe

generat we"eing;oO.~~~j~s..:;·,;:"< ~

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 required.
The plan includes an on-call provider.
The plan includes a list of telephone numbers for local
ambulances and hospital services.
The plan includes procedures for facility staff to utilize
this emergency health care consistent with security and
safety.
Detention staff is trained to respond to health-related
emergencles within a 4-minute response time .
In IGSAs, if staff is used to distribute medication, a
health care provider properly trains these officers.
The medical unit keeps written records of medication
that is distributed .
The 1-819 (or IGSA equivalent) is used to notify the
OIC/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/IGSA 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 Anumber and marked "MEDICAL CONFIDENTIAL".

;;"

o

~;' . ;;."

o

o

[J

[J

o
o
o
o
o
o
o
o

o

o

o

...•.

< .:::'\. . . . '.

o

o
o
o
o
o

o o
o o

Page 44
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125/03

--

._- -- - - ---_._-- _._- - - -.

.-

_._-----_._.

__.-._._--

- - - -- - - - -- - - -- - - - -

When rated below Acceptable, facilitles must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action
and the estimated timetable for compliance.

Standard Rating:

o Acceptable

o At-Rlsk

[gI Deficient

o Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, etc.)

The medical care given here is very good, however, the stucture of the building & clinic space is not
conducive to the number of detainees that they service. I concure with the advisory of the previous survey
that the size of the Pharmacy is substandard . Due to the nature of the mixed male & female population as
well as other security factors, it is necessary to conduct 7 counts a day & this slows down clinic flow. They
start their sick call at 0500 in order to attempt to accomidate the numbers that they need to see.

This facility is almost at risk due to low number of medical staff .

b6, b7c

.

.

Page 45
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25/03

'": :"i~E,>, ?r,.J;L"., ,\ ~~~IQf;}!Rl¥~NTION'ANO]~ve...riON".' '.!. . ~\'> :~;~~' ..:." ,' .~. , ;. ' ::~:
.', ~~} ~i}i~~n~t3ff~rit1'ri~'·~,ritfiCE~e~!nees "';Di ~;t~ined~.i8cognii~t'~ul~~~~i:rd:;~§~' sfclfC

· wm,. h~I.J)OI:e~liaIly...u~cidal. ir1dMd~1s wtth ~itivityi su~rvision. ~d:refe~s; ::"" 9Ii"~11y suic:~J:aetaf,1ee';,

.~I'-~~~~=:;',~r:[:~et~,(., . :~" • " .!~

·'[~~ic'·' :·· ·~;. '· •·.':;:,-.•.: .•.:.·:· ~.;" . ~:.·. ;::.:,'r,.1

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

o

Training prepares staff to:
•
Recognize potentially suicidal behavior;
•
Refer potentially suicidal detainees, following
facility procedures;
•
Understand and apply suicide-prevention
techniques.
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 detainee's arrival.

Written procedures cover when and how to refer at-risk
detainees to medical staff and procedures 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.
Medical staff has approved the room for this purpose.
Staff observes a suicide-watch detainee at least once
every 15 minute.

0

~

The staff is
knowledgeable however
documentation was
absent for the nursing
staffs orientation & only
partially completed for the
annual training . New
forms to correct this
problem have been
implemented.

o o

D

o

o

D

0

o

0

0

o

0

0

~

[]

[J

~

D

0

One chart that was
reviewed the nurse had
detected that the
detainee had a long
history of suicidal ideation
& had missed two doses
of their psychiatric
medication - but did not
refer this detainee to a
provider - the HSA was
notified & further
education for the staff is
planned

When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance . For each element found out of compliance, the plan of action will specify remedial action
and the estimated timetable for compliance.

Standard Rating:

[g] Acceptable

o Deficient

0

At-Risk

0

Repeat Finding

Page 46
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125/03

*Remarks: (Record significant facts, observations, other sources used, etc.)
Strong advisory to increase the number of medical staff & to have review training re: when to refer a
detainee to a provider as well as improving charting methods. Advised to have repeat suicide training
close to the the Holidays since the incidence of suicide increases at this time of year.

b6, b7c

Page 47
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125/03

.' .

<.::~ '

~ILLNESS ;ADVAMCEODnU:eTIVES'AMDDEATH ; __:"«'::~~" ':-:;:::::1

'( P.O~~A1I~~~hoUsi~ ICEdetIJih~;~~n.~~ poIiciEts aRdl>rooed~teS addresS~ the iSS~. of ;f!Tl~al >
IIlhessor ktjury: medlcaj ~oced dJmctiv~~~ndaetalnee death, to inclu'!e the proced"'fes to c!ltsure 'Proper. ;

[
iI: ==~:~~:~;i~jU~~~~~~~re:~ei:2u~~~\~~~t9~~~if:~(~:~%~:~rw::1
.
'.':>
,e

' be 18ken"if-the deathOf 8 ~,OCC. ursW
. h'le
.1 in tr8nsit

:.i,: . . ·.

.-.· "YC:COn,1Ponerit.;·,#;;" •..

.:';'

'

. , "
... ...
,yes.:, No '.· ."IlIA , ..:,..
'

,

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.
• The detainee's location.
• The limitations placed on visiting.
For IGSAs There are guidelines addressing State
Advanced Directive Form for 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 wish to
appoint 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"?

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

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 through the local ICE
representative.
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
DeQ.artment of Veterans Affairs notified.
An original or certified copy of a detainee's death
certificate is placed in the subject's a-file.

[gj

0

0

[gj

0

0

. --.... .. ' ... ·:F - ,

.:;~"

~ .::; .~

R.mIiHcs~~'· •

• : - '~" - ,- ; ~.

".! .:-

.

· ,; ~'I

Even though this facility is
not an IGSA it still meets
this component.

[gj

0

0

[gj

0

0

tzI

0

0

0

0

[gj

0

0

~

tzI

0

0

[gj

0

0

[gj

0

0

~

0

0

0

0

tzI

r8l

0

0

Page 48
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

This is such a new facility
that there have not been
DNR pts. ICE National
policies are in place and
are being followed
Same as above

No incidences of this
nature have taken place
at this facility.

.< ,<,,:{.;;': 'Tl;fWIt<IALll.~S, ADVANCEO; DIRECTIVES~ ~~ ~H, c i:" :
;:;~:" ,
; Pollcy:AU facilities bOusing tCt:detaine~ shall have policies and procedufeS ~c:kjr:essingth& issues:of:teimlnal .,
., ~!ness or injury, m~ical adva~. dl~, and d~inee dea~,.to lnclude.ttie p~ures to enSllT.p~r:, 1
InotlficaflD!'Js provicfed.to ICE ofticial~ famIlY.members and oth~r '"t!~!~ ~es \n1h~ eventof a delA!inee}
',· becorn.
i~1erminallY: III ~tnJ!Jl"ed or.,~th C:Wildetaihee
.. . " .' ..~
. _.~jll'factd
. ,,' 1ti@;;'~ pqIiCY wOlqo~...Proced
...,...:. . ·. y. res~ ;
be taken ifihe·death Of?ajletaJnee ,occuFS whUe oln tranSit ," ; ' : "
"
"'C' ;" ' ; ".:
/:~';t'C:," · ;},·
t;·;,:' ;,, " c·
Coin~nel1~ , ' ;t , ,. '1
y ..,:: J'iP " 'NA l' . . ;!~",. Rijmar~ : i; ., '"

"O't:::, '.

The facility follows established policy and procedures
describing when to contact the local coroner regarding
such issues as
• Performance of an autopsy.
• Who will perform the autopsy.
• Obtaining State approved death certificates.
•
Local transportation of the body.
ICE staff follow established procedures to properly close
the case of a deceased detainee.

[gI

D

0

[gI

D

D

I·
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action
and the estimated timetable for compliance.

Standard Rating:

181 Acceptable

D Deficient

o

At·Risk

o Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, etc.)
It was noted that their had been a death in July of 2003. This incident has been throughly investigated and
action has been taken to provide on site Psychology and Psychiatric medical support.

b6, b7c

Page 49
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125/03

•
Section III

Security and Control

Page 48
G-324A Detention Inspection Form Worksheet for JGSAs
Rev: 09125/03

CONTRABAND
Policy: All detention faclities will ensure the proper handling and disposal of all contraband. Ooeumen1ation of
contraband destruction is required.

Yes

No

NA

illegal contraband. Staff inventories, holds, and reports it
when necessary to the proper authority for
action/possible seizure.
Contraband that is government property is retained as
evidence for potential disciplinary action or criminal
prosecution.
Staff returns property not needed as evidence to the
proper authority. Written procedures cover the return of
such property.

r8'I

D

0

r8'I

D

0

r8'I

0

0

Altered property is destroyed following documentation
and using established procedures.
Before confiscating religious items, the OIC or
designated investigator contacts a religious authority.

r8'I

0

D

r8'I

0

0

0

r8'I

0

r8'I

0

0

Components

Remarks

The facility follows a written procedure for handling

Staff follows written procedures when destroying hard
contraband that is illegal.
Hard contraband that is illegal (under criminal statutes)
may be retained and used for offtcial use, e.g. training
purposes.
If yes, under specific circumstances and using
specified written procedures. Hard contraband is
secured when not in use.

Contraband is destroyed,
but no written procedures
could be located.

CONTRABAND
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:

r8'I Acceptable 0

o

Deficient

At-Risk

o Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, etc.)
Policy and procedures for CCA address the handling of contrabrand, however, no written policy was
tion .
b6, b7c

Uditor's Signature I Date

9/z/oi
{

Page 49
G-324A Detention Inspection Form Worksheet for IGSA!
Rev: 09125103

•

DETENTION ALES

Policy: Every facility will create a detention file for every ICE detainee booked into the facility, excluding only
detainees scheduled to depart within 24 hours. The detention file \\'ill contain copies and, in some cases, the
original of specified documents concerning the detainee's stay in the facility: classification sheet, medical
questionnaire, property inventory sheet, disciplinary documents, etc.
Components

Yes

No

NA

A detention file is created for every new arrival whose
stay will exceed 24 hours.
The detainee detention file contains either originals or
copies of documentation and forms generated during the
admissions process.
The detainee's detention file also contains documents
generated during the detainee's custody.
• Special requests
Any G-589s and/or l-77s closed-out during the
detainee's stay
Discipfinary formslSegregation forms
Grievances, complaints, and the disposition(s) of
same
The detention files are located and maintained in a
secured area. If not the cabinets are lockable and
distribution of the keys is limited to sUp8nlisors.
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 c/osed-out receipts for property and valuables,
the original 1-385 or equivalent and other documentation.
The officer closing the detention file makes a notation
that the file is complete and ready to be archived.
Staff makes copies and sends documents from the file
when appropriately requested by supervisory personnel
at the receiving facility Of office.

~

0

0

181

0

0

•
•
•

Appropriate staff has access to the detention files and
other departmental requests are accommodated by
making a request for the file. Each file is properly logged
out and in by a representative of the responsible
department.
Field offices controlling detention in IGSA facilities create
and maintain detention files on all detainees admitted to
IGSA facilities. These files contain the forms and
documents set forth for SPC/CDF detention files to the
extent that the field office creates them or the IGSA
forwards them.

0

181

0

rzl

0

0

181

0

0

18'1

0

0

18'1

0

0

r81

0

0

0

0

18'1

RemIII'ks

Files continue to not meet
the standard. No
grievance, complaint,
disciplinary or sag forms
are placed into the files.

-

Page 50
G-324A Detention Inspection Fonn Worksheet for IGSAs
Rev: 09125/03

-~~-~---------

DETENTION ALES Rating

When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compfiance.
Standard Rating:

o Acceptable D Deficient

o At-Risk

181 Repeat Finding

*Remarks: (Record sign;t;cant facts, observations, other sources used, etc.)

Per the response to the last review, the requirement of adding copies of the disciplinary, grievance,
complaint forms, etc., to the detention file is not contained in the current contract. All forms are maintained
at the facility and are avaUable to ICE personnel upon request
b6, b7c

Date

Q/2/o1
~I

Page 51
G-J24A Detention Inspection Form Workllheet for IGSAs
Rev:09/25/0J

DISCIPlINARY POlICY

I

Policy: All facilities housing ICE detainees are authorized to impose disciplile on detainees whose behavior is
not in compliance with facility rules and regulations.
Components
Yes
No
NA
Remarks
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 or retaliatory.
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
of physical exercise
•
The rules of conduct, sanctions, and procedures for
violations are defined in writing and communicated to all
detainees verbally and in writing.
The following conspicuously posted in Spanish and
English or other dominate languages used in the facility:
• Rights and Responsibilities
Prohibited Acts
Disciplinary Severity Scale
Sanctions
Iho, where posted
When minor rule violations or prohibited acts occur,
informal resolutions are encouraged.
If informal resolutions are not appropriate, Incident
reports and Notice of Charges are promptly forwarded to
the designated supervisor.
Incident reports are investigated within 24 hours of the
incident report The Unit Disciplinary Committee (UDC)
or equivalent does not convene before investigations
have ended.
An intermediate disciplinary process is used to adjudicate
minor infractions.
A discipHnary panel (or equivalent in IGSAs) adjudicates
infractions. The panel:
• Conducts hearings on all charges and
allegations referred by the UDC
Considers
written reports, statements, physical
•
evidence, and oral testimony
• Hears pleadings by detainee and staff
representative
• Bases its findings on the preponderance of
evidence
Imposes only authorized sanctions
A staff representative is available, if requested for a
detainee facing a disciplinary hearing
The facility permits hearing postponements or
continuances when conditions warrant such a
continuance. Reasons for are documented.

•

r&I

0

0

r&I

0

0

r&I

0

0

r8I

0

0

0

0

0

(81

0

0

181

0

0

r8I

0

0

181

0

0

r8I

0

0

181

0

0

181

0

0

•
•

•
•
•
•

Handbook and video

•

Page 52
G-324A Detention Inspection Form Worluheet for IGSAs
Rev: 09125103

. .. -

- - - _.. _---

- -_ .

!

DlSCIPLWARY POLICY

Policy: All facilities housing Ice detainees are authorized to Impose discipline on detainees whose behavior is
not In compliance with facility rules and regulations.
Yes
Componen1$
The duration of punishment set by the
OIC/recommended by the disciplinary panel does not
exceed established sanctions. The maximum time in
disciplinary segregation does not exceed 60 days for a
sil'19le offense.
Written procedures govem the handling of confidentialinformant information. Standards include criteria for
re~niztng ·substantial evidence"
All forms relevant to the incident, investigation,
committee/panel reports, etc., are completed and
distributed as required.

I

No

NA

~

0

0

~

0

0

r8I

0

D

Remarks

OISCIPUNARY POUCY
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

181 Acceptable 0

Deficient

o At-Risk

1

o Repeat Finding

"Remarks: (Record signiflc8nt facts, observations, other sources used, aw.)

b6, b7c

Page 53
G-324A DetentioD Inspection Fonn Worksheet for IGSAs
Rev: 09/25103

EMERGENCY (CONTINGENCY) PLANS
Policy All fac:i1itIes holding ICE detainees wil respond to emergencies with a predetermined standardized plan to
minimize the harming of human life and the destruction of property. It is recommended that SPCS and CDFs enter
into agreement, via Memorandum of Understanding (MOU), with federal, local and state agencies to assist in tines
of emergency.
i
No
NA
Remarks
Yes
Components
No Detainee or detainee groups exercise control or authority
over other detainees.
Detainees are protected from :
Personal abuse
Corporal punishment
• Personal injury
Disease
• Property damage
Harassment from other detainees
Staff are trained to identify signs of detainee unrest.
What type of training and how often?
Staff effectively disseminates information on facility climate,
detainee attitudes, and moods to the Officer In Charge (OIC)
There is a designated person or persons responsible for
emergency plans and their implementation. Sufficient time
is allotted to the person or group for development and
implementation of the plans.
The plans address the following issues:
• Confidentiality
• Accountability (copies and storage locations)
Annual review procedures and schedule
• Revisions
Contingency plans include a comprehensive general section
with procedures ~ficable to most emergency situations.
The facility has cooperative contingency plans with
applicable:
Local law enforcement agencies
• State agencies
• Federal agencies
All staff receive copies of Hostage Situation Management
policy and procedures.
Staff is trained to disregard inStructions from hostages,
regardless of rank. Within 24 hours after release hostages
are screened for medical and psychological effects.
Emergency plans include emergency medical treatment for
staff and detainees during and after an incident.
The food service maintain at least 3-days' worth of
emergency meals for staff and detainees.
Written plans locate shut-off valves and switches for all
utilities (water, gas, electric).
Written procedures cover:
WorkIFood Strike
• Disturbances
• Escapes
• Bomb Threa1s
• Adverse Weather
• Intemal Searches

181

0

0

~

0

0

181

0

0

181

0

0

181

0

0

181

0

0

181

0

0

181

0

0

181

0

0

181

0

0

r8I

0

0

181

0

0

181

0

0

[8J

0

0

•

•
•

•

•

•

•

•

Page 54
G-.J24A Detention Inspection FOnD Worksheet for IGSAs
Rev: 09125/03

Initial orientation training
and annual updates

EMERGENCY (CONTINGENCy) PlANS
Policy All facilities holding ICE detainees wil respond to emergencies v.ith a predetermined standafdized plan to
minimize the harming of human life and the destruction of property. It is recommended that SPes and CDFs enter
into agreemert, via Memorandum of Understanding (MOU), will federal, local and state agencies to assist in tines
of emergency.
Remarks
Components
Yes
No
NA

•
•
•
•

Facility Evacuation
Detainee Transportation System Plan
Internal Hostages
Civil Disturbances

EMERGENCY (CONTINGENCy) PlANS

When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

181 Acceptable 0

o At-Risk

Deficient

o Repeat Finding

-Remarks: (Record significant facts, observations, other sourCes used, etc.)
E Plans r~uire updates at the corp. level for updating.
b6, b7c

Date

Wh1
I

Page 55
G-324A Detention Inspection Form Worlubed for IGSAs
Rev: 09125103

ENVIRONMENTAL HEALTH AND SAFETY

,

Policy: Every faciIIly"';lI control ftammable, toxic, and caustic materials through a hazardous materials program.
The program will include, among other things, the identification and labeling of hazardous materials In
accordance with applicable standards (e.g., National Fire Protection Association [NFPA»; identification of
incompatible materials, and safe...handling procedures

Ves

No

NA

181

0

0

181

0

0

•
•

181

0

0

•
•

181

0

0

181

0

0

181

0

0

181

0

0

181

0

0

r8l

0

0

181

0

0

181

0

0

r8l

0

0

r8I

0

0

Components
The facility has a system for storing, issuing, and
maintaining inventories of hazardous materials.
Constant inventories are maintained for all flammable,
toxic, and caustic substances usedIstored in each section
of the facility.
The manufacturer's Material Safety Data Sheet (MSOS)
file is up-to-date for every hazardous substance used.
The files list all storage areas, and include a
plant diagram and legend.
The MSOSs and other information in the files are
available to personnel managing the facility's
safety program.
All personnel using flammable, toxic, and/or caustic
substances follow the prescribed procedures. They:
Wear personal protective
Equipment.
Report hazards and spills to the
designated official.
The MSOSs are readily accessible to staff and detainees
in the work areas.

Remarks

•
•

Hazardous materials are always issued under proper
supervision.
• quantities are limited.
• Staff always supervises detainees using these
substances.
''flammable- and "combustible" materials (liquid and
aerosol) are stored and used according to label
recommendations.
Lighting fixtures and electrical equipment are installed in
storage rooms and other hazardous areas meet National
Electrical Code requirements.
All toxic and caustic materials stored in their original
containers in a secure area.
Excess flammables, combustibles, and toxic liquids are
disposed of property and in accordance with MSDSs.
Staff directly supervises and accounts for products with
methyl alcohol. Staff receive a list of products containing
diluted methyl alcohol, e.g., shoe dye. All such products
clearly labeled as such. "Accountability" includes issuing
such products to detainees in the smallest workable
_quantities.
Every employee and detainee using flammable, toxic, or
caustic materials receives advance training in their use,
storage, and disposal.
The facility complies with the most current edition of
applicable codes, standards, and regulations of the
National Fire Protection Association and the

Page 56
G-324A Detention IDspedion Form Worksheet for (GSAs
Rev: 09/25/03

------------------------------------------

ENVIRONMENTAL HEALTH AND SAFETY

wi.

Policy: Every fac:Iity
control flammable, tolClc, and caustic materials through a hazardous materials program.
The program will inclUde, among other things, the identification and labeling of hazardous materials in
accordance with applicable standards (e.g., National Fire Protection Association [NFPAJ); identification of
incompatible materials, and safe-handing procedures
NA
Components
Yes
No
Remarks
Occupational Safety and Health Administration (OSHA).
A technically qualified officer conducts the fire and safety
181
0
0
inspections.
The Safety Office (or officer) maintains files of in~ction
181
0
0
reports? Including corrective actions taken.
The facility has an approved fire prevention, control, and
0
181
0
evacuation plan.
The plan requires:
• Monthly fire inspections.
• Fire protection equipment strategically located
throughout the facility.
181
0
0
• Public posting of emergency plan with
accessible buRdinglroom floor plans.
• Exit signs and directional arrows.
• An area-specific exit diagram conspicuously
posted in the diagrammed area.
[]
[] Fire drills are quarterly
Fire drills are conducted and documented monthly.
IZI
A sanitation program covers barbering operations.
181
0
0
The barbershop has the facilities and equipment
181
0
0
necessary to meet sanitation requirements.
The sanitation standards are conspicuously posted in the
181
0
0
barbershop.
Written procedures regulate the handHng and disposal of
181
0
0
used needles and other sharp objects.
All items representing potential safety or security risks
are inventoried and a designated individual checks this
181
0
0
inventory weekly.
Standard cleaning practices include:
• Using specified equipment; cleansers;
disinfectants and detergents.
181
0
0
• An established schedule of cleaning and followup inspections.
The facitity follows standard cleaning procedures.
181
0
0
[J
SQill kits are readily available.
181
0
A licensed medical waste contractor disposes of
181
D
D
infectiousJbio-hazardous waste.
2taff are trained to prevent contact with blood and other
181
D
D
body fluids and writtenp!ocedures are followed.
Do the methods for handling/disposing of refuse meet all
181
D
D
regulatory requirements.
A IicensedlCertifiedlTrained pest-control professional
inspects for rodents, insects, and vermin.
181
D
0
• At least monthly.
• The pest-control program includes preventive
spraying for indigenous insects.
Drinking water and wastewater is routinely tested
181
0
D
according to a fixed schedule.
Emergency power generators is tested at least every two
181
0
0 Generators are shared

Page 57
G-324A Detention Inspedion Form Worksheet for IGSAs
Rev: 09125/03

ENVIRONMENTAL HEALTH AND SAFETY
Policy: Every facIity win control flammable, toxic, and caustic materials 1hrough a hazardous materials program.
The program will include, among other things, the identification and labeling of hazardous materials in
accordance with applicable standards (e.g., National Fire Protection Association [NFPA]); identification of
incompatible materials, and safe-handling procedures

Yes

Components

No

NA

weeks.

•
•

Remarks
with the county facility
directly behind this facility
and are maintained by the
county .

ENVIRONMENTAL HEALTH AND SAFETY
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
comp/iance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

[81 Acceptable

o Deficient

o At-Risk

o Repeat Finding
....;....::._--_....

*Remarks: (Record significant facts, observations, other sources used, etc.)
Inventory record keeping has improved. Individual bottles are now inventoried. One diluted 5 gal. container
was not labeled. Explanation was it was placed on the bottom so they would know what the product was

b6, b7c

te

?/doy'

Page 58
G-324A Detention Inspedlon Form Worksheet for IGSAs
Rev:09f25103

HOLD ROOMS IN DETENTION FACILITIES

Policy: Hold rooms will be used only for temporary detention for detainees awaiting removal, transfer, EOIR
hearings, medical treatment, iltra-facility movement. or other processing into or out of the facility.
Components

Yes

No

NA

The hold room is situated in a location within the secure
perimeter.
The hold rooms well ventilated, well lighted and all
activating switches located outside the room.
The hold rooms contain sufficient seating for the
number of detainees held.
No bunkslcotslbeds or other related make shift sleeping
apparatuses are permitted inside holdrooms.
The walls of the hold rooms escape proof.
• The hold room ceilings are escape and tamper
resistant
Individuals are not held in hold rooms for more than 12
hours.
Male and females are segregated from each other at a"
times.
Every effort is made to ensure that detained detainees
under the age of 18 are not held with adult detainees.
Detainees are provided with basic personal hygiene
items such as water, soap, toilet paper, cups for water,
feminine l'lY9iene items, diapers and wipes.
In older facilities officers are within visual or audible
range to allow detainees access to toilet facilities on a
regular basis.
All detainees are given a patdown search for weapons or
contraband before being placed in the room.
Officers closely supervise the detention hold rooms
using direct supervision (Irregular visual monitoring.).
Hold rooms are irregularly monitored every 15
minutes.
• Unusual behavior or complaints are noted.
When the last detainee has been removed from the
hold room, it is given a thorough inspection.
• Cleaning.
• Evidence of tampering with doors, locks,
windows, grills, plumbing or electrical fixtures is
reported to the shift supervisor for corrective
action or repair.
There is a written evacuation plan.
• There is a designated officer to remove
detainees from the holdrooms in case of fire
and/or building evacuation.
An appropriate emergency service is called immediately
upon a determination that a medical emergency may
exist.

f81

0

0

l8I

0

0

r8I

0

0

f81

0

0

f81

0

0

f81

0

O·

f81

0

0

f81

0

0

[81

0

0

0

0

r;g]

[81

0

0

r81

0

0

r81

0

0

r8l

0

0

181

0

0

•

Remarks

Still awaiting contract
modification

Page 59
G-324A Detention Inspection Form Worksheet for IGSAs

Rev: 09125103

.. -.

-.-.--~.---~------------------

HOLD ROOMS IN DETENTION F.ACJLmES - Rating
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:

t81 Acceptable

o Deficient

o

At-Risk

o Repeat Findings

*Remarks: (Record significant facts, observations, other sources used, etc.)
No substantial change from last review. However, staff is well aware of requirement to limit hold room time
Contract modification still pending.

to 12 ho;r or less. Every effort is made to do so.
b6, b7c

Date

9///01
~
I

Page 60
G-324A Detentioa laspectioa Form Worksbeetfor (GSAs
Rev: 09123103

•

KEY AND LOCK CONTROL
(SECURnY, ACCOUNTABIUTY AND MAINTENANCE,
Policy It is the policy of the ICE SeNice to maintain an efficient system for the use, accountability and
maintenance of all keys and locks.
Components
Yes
No
NA
Remarks
The security ofllcerts). or equivalent in IGSAs. has attended
Approved training is
0
181 0 currently pending
an approved locksmith training program.
The security officer. or equivalent in 1GSAs, has responsibly
for all administrative duties and responsibilities relating to
0
r8I
0
keys, locks etc.
The security officer, or equivalent in IGSAs, provides
0
0
r8I
training to employees in key control.
The security officer, or equivalent In IGSAs, maintains
r8I
0
0
inventories of all keys, locks ancllocking devices.
The security officer follows a preventive maintenance
Active quarterly PMP in
program and maintains all preventive maintenance
181
0
0 place.
documentation.
Facility policies and procedures address the issue of
r8I
0
0
compromised keys and locks.
The security offlc:er. or equivalent in IGSAs, develops policy
and procedures to ensure safe combinations integrity.
181
0
0
Only dead bolt or dead lock functions are used in detainee
accessible areas.
Non-authorized locks (as specified in the Detention
Standard) are not used in detainee accessible areas.
The facility does not use grand master keying systems.
All worn or discarded keys and locks cut up and properly
disposed of .

181

0

0

181
181

0
0

0
0

181

0

0

Padlocks and/or chains are not used on cell doors.

181

0

0

r8I

0

0

181

0

0

181

0

0

r8I
r8I
181

D
0
0

0
0
0

181

0

0

The entrance/exit door locks to detainee living quarters, or
areas with an occupant load of 50 or more people,
conform to
• Occupational Safety and Environmental Health
Manual, Chapter 3
National
Fire Protection Association Life Safety
•
Code 101.
The operational keyboard sufficient to accommodate all
the facility key rings including keys in use is located in a
secure area.
Procedures in place to ensure that key rings are:
• Identifiable
• Numbers of keys on the ring are cited?
• K~ cannot be removed from issued key rings
Emergency keys are available for all areas of the facility.
The facilities use a key accountability system.
Authorization is necessary to issue any restricted 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 I>ublic

Suggested logbook be
created for all destroyed
keys.
Padlocks used on seg
rec. cages

Page 61
G-324A Detention Inspection Form Wombed for (GSAs
Rev: 09/25/03

--~-----

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABLnY AND MAINTENANCE)
Policy It is the poley of the ICE Service to maintain an efficient system for the use, accountability and
maintenance of all keys and locks.
Components

Yes

No

NA

~

0

0

~

0

0

Remarks

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 hetd 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 immediately
notified.
Detainees are not permitted to handle keys
assigned to staff.

•

•

KEY AND LOCK CONTROL - Rating
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:

~ Acceptable

0

o At-Risk

Deficient

o Repeat Finding

"Remarks: (Record significant facts, observations, other sources used, etc.)
Very good key accountability. Chit accountability is responsibility of the officer. Standard requires locksmith
training by the BOP, however, BOP has not been conducting any training for any other agencies or CDFs.
This ~ been sending their officers to • 4 hr. basic introduction for service and repair.
b6, b7c

11 9/?/g(
ure I Date!

I

Page 62
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25103

POPULATION COUNTS - Rating
Po6cy: All detention faciflties shaH ensure around-the-clock accountability for all detainees. ThIs requires that
they conduct at least one fonnal count of the detainee population per shift, with adcltional formal and informal
counts conducted as necessary.
Components

Yes

No

NA

Staff conducts a formal count at least once each shift.

~

[J

[J

Activities cease or are strictly controlled while a formal

~

0

0

0
0
181
181
181

~

[J

r8J

0

[J

0
0

0
0
0

181

0

0

181

0

0

181

0

0

181

0

0

count is being conducted.
Do certain operations continue during formal counts.
Is a certain amount of movement tolerated during a
formal count
Formal counts in all uni1s take place simultaneously.
Officers do not allow detainee participation in the count
A face-ta-photo count follows each unsuccessful
recount.
Officers positively identify each detainee before counting
himlher as present.
Written procedures cover informal and emergency
counts.
• They followed during informal counts .
• During emergencies:
The control officer (or other designated position)
maintains an out -count record of all detainees
temporarily leaving the facility.
This training is documented in each officer's training
folder.

Remarks

Population Counts
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

r8J Acceptable 0

o At~isk

Deficient

o Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, eh:.)

b6, b7c

I Date

9/z/o </
I

I

Page 63
G-J24A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

POST ORDERS
Policy: ICE provides officers aM necessary guidance for carT)ing out their duties. This guidance includes 1he post
orders established for every post, which are reviewed at least annuaHy, and given to each officer upon
assignment to that post.

Com

.....

Every Fixed post has a set of post orders.
Each set contains the latest inserts (emergency
memoranda etc.) and revisions.
One indMdual or department is responsible for keeping
all post-orders current with revisions that take place
between reviews.
The !GSA maintains a complete set (central file) of post
orders.
The centra! file accessible to all staff.
The OIC or Contract /IGSA equivalent initiate/authorizes
all post-order changes.
The OIC or Contract /IGSA equivalent has signed and
dated the last page of every section.
A review/updating/reissuing of post orders occurs
r~ularty. At a minimum, Annually.
Proeedures keep post orders and logbooks secure from
detainees at all times.
Every armed-post officer qualifies with the post
weapon(s) before assuming post duty.
Armed-post post orders provide instructions for escape
attempts.
The post orders for housing units track. the event
schedule.
Housing-unit post officers record all detainee activity in a
log. The post order include instructions on maintaining
the logbook.

Yes

No

NA

181

[]

[J

181

0

0

181

0

0

0
181
181

0
0
0

~

181

0

0

~

0

0

181

0

0

181

0

0

181

0

0

181

0

0

181

0

0

Rematf(s

0
0

POST ORDERS - Rating
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

o Deficient

[81 Acceptable

D Repeat Finding

"Remarks: (Record significant facts, observations, other sources used, etc.)

b6, b7c

£

UditOf'SSiQliature I Date

Page 64
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

SECURITY INSPEC110NS
Policy: Post assignments in the facility's high-risk areas, where special security procedures must be folowed,
.
will be restricted to exPerienced personnel with a thorough grounding it facility
Yes
No
NA
Rena'ks
Components
The faciity has a comprehensive security inspection poley.
The policy specifies:
• Posts to be inspected
• Required inspection forms
t8J
0
0
• Frequency of inspections
• Guidelines for checking security features
• Procedures for reporting weak spots,
inconsistencies, and other areas needing
improvement
Every officer is required to conduct a security check of
Logbook
~
0
0
hislher assigned area. The results are documented.
Documentation of security i
s is kept on file.
r8I
0
0
Procedures ensure that recurring problems and a failure to
take corrective action are reported to the appropriate
r8I
0
0
manager.
The front-entrance officer checks the ID of everyone
Super job here
0
0
r8I
entering or exiting the facility.
All visits officially recorded in a visitor logbook or
Super
t8J
0
0
electronically recorded.
[]
The facility has a secure visitor pass system.
r8I
0 Excellent
[]
Every Control Center officer receives specialized training.
181
0
The Control Center is staffed around the clock.
0
r8I
0
Policy restricl.s staff access to the Control Center.
~
0
0
[]
[]
Detainees do not have access to the Control Center.
~
[]
[]
Communications are centralized In the Control Center.
~
Officers monitor all vehicular traffic entering and leaving
0
0
ti?J
the facility.
II~.

The facility mainiains 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
Name of employee responsible for the vehicle
during the facility visit
Officers thoroughly search each vehicle entering and
leaving the faci/J!y.
The facility has a written polcy and procedures to prevent
the introduction of contraband into the facility or any of its
components.
Tools being taken into the secure area of the facility are
inventoried before enterirn:3 and prior to departure.
The SMU entrance has a sallyport.
Written procedures govern searches of detainee housing
units and personal areas.
Housing area searches occur at irregular times.

Good procedures here

•

~

0

0

r8I

0

0

r8I

0

0

r8I
0

0

0
t8l

~

0

~

0

•

0

0
0

Page 65
G-324A Detention Inspedion Fonn Worksbeet for IGSAs
Rev: 09/25/03

SECURITY INSPEC11ON8

Policy: Post assignments in the fac:Iily's high-risk areas, where special security procedures must be foIowed,
wtli be restrIct8d to experienced
wtth a1horouah .,.'
....
in fai:illy VI" In au. ....
Components
Yes
No
NA
Renwb
Every search of the SMU and other housing units
L

documented.
Storage and supply rooms; walls, light and plumbing
fixtures, accesses, and drains, etc. undergo frequent,
.~!egular searches. These searches are documented.
Walls, fences, and exits, including exterior windows, are
.
.... for defects once each shift.
Daily procedures include:
Perimeter alarm system tests.
Physical checks of the perimeter fence.
Documenting the results.
VISitation areas receive frequent, irregular inspections.

•
•
•

0

0

0

0

181

0

0

181

0

0

181

[]

[J

181

181

I

Documentation not
supplied
Pod officers

SECURITY INSPEC110NS - Rating
When rated below Acceptable, facilties must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:

•

181 Acceptable 0

Deficient

o At-Risk

o Repeat Finding

*Remarks: (Record significant facts, observations, other sources used, etc.)

b6, b7c

Page 66
G-324A Detention hupection Form WorlBMet for IGSA!
Rev: 09125/03

--

..

---- - - - - - - - - - - - - - - - - --

SPECIAL MANAGEMENT UNT (SMU)
Administrative Segregation
Policy: The Special Management Unit required in every faciity isolates certain detainees from the general
population. The Special Management Unit wll 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 [Disciplinary Segregation}- standard).
NA
No
Renaks
Yes
Components
The Administrative Segregation unit provides
non-punitive protection from the general population and
individuals undergoing discip6nary segregation.
• Detainees are placed in the SMU
(administrative) in 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 placement in the
SMU (administrative).
A supervisory officer conducts another review after the
detainee has spent seven days in administrative
segregation.
• Every week thereafter for the first month.
• 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
justification.
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 FJeld 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 FJeld
Ope.rations Branch Chief for ORO.
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 has remained

~

0

0

~

0

0

181

0

0

~

0

0

181

0

0

181

0

0

f8]

0

0

~

D

D

Page 67
G-J24A DetentioD IDspedion Form. Worksheet for IGSA!
Rev: 09125103

SPECIAL MANAGEMENT UNIT (SMU)
Adminis1rative Segregation
Policy: The Special Nlanagement Unit required in wery facility isolates certain detainees from the general
population. The Special Management Unit will consist of two sections. One, Adrnini!trative Segregalon, houses
detainees isolated for their own protection; the other for detainees being disciplined for wrongdoing (see the
·Special Management Unit [Disciplinary Segregationr standard).
Components
Yes
No
NA
Remarks
in administrative segregation for seven consecutive
days.
Administratively segregated detainees enjoy the same
general privileges as detainees in the general
~
0
0
population.
The SMU well ventilated.
• Adequately lighted.
~
0
0
• Appropriately heated.
• Maintained in a sanita!ycondition.
All cells are equipped with beds.
0
0
• Every bed securely fastened to the floor or wall. ~
The number of detainees in any cell does not exceed
the occupancy limit.
• When occupancy exceeds recommended
capacity, do basic living standards decline?
~
0
0
• 00 criteria for objectively assessing living
standards exist?
• If yes, are the criteria included in the written
procedures?
The segregated detainees do not have fewer
opportunities to exchangellaunder clothing, bedding,
~
D
D
and linen than detainees in the general population.
Detainees receive three nutritious meals per day.
• From the general population's menu of the day. r8I
0
0
• Do detainees eat only with disposable utensils.
• Is food ever used as punishment.
Each detainee maintains a normal level of personal
hygiene in the SMU.
181
0
0
• The detainees have the opportunity to shower
and shave at least three times a week.
• If not explain.
The detainees are provided:
• Barbering services.
• Recreation privileges in accordance with the
"Detainee Recreation" standard.
• Non-legal reading material.
181
0
0
• Religious material.
• The same correspondence privileges as
detainees in the general population.
• Telephone access similar to that of the general
population.
Personal
legal material.
•
A health care professional visits every detainee at least
three times a week.
181
0
0
• The shift supervisor visits each detainee daily.
Weekends
and
holidays.
•
Procedures comply with the "VISitation" standard.
~
0
0
• The detainee retains visiting privileges.

Page 68
G-324A Detention Inspection FOnD Worksheet for IGSAs
Rev: 09/25103

SPECIAL MANAGEMENT UNIT (SMU)
Acirninis1rative Segregation
Policy: The Special Management Unit required in wery facility isolates certain detainees from the general
population. The Special Management Unit wil 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 [Disciplinary Segregation]" standard).
Yes
RernM"ks
Components
No
NA

•

The visiting room available during normal
visiting hours.
Visits from clergy are allowed.
Detainees do not have have less law-library access than
the general population.
• Are they required to use the law library
separately, as a group? If so:
• Legal materials brought to them.
The SMU maintains a permanent log.
• Detainee-related activity, e.g., meals served,
recrea1ion visitors etc.
SPC procedures include completing the SMU Housing
Record (1-888) immediately upon a detainee's
placement in the SMU.
• Staff completes the form at the end of each
shift.
• CDFs and IGSA facilities use Form 1-888 (or
local equivalent).
Staff record whether the detainee ate, showered,
exercised and took any medication during every shift.
• Logs record all pertinent information, e.g., a
medical condition, suicidal/assaultive behavior,
etc..
• The medical officerlhealth care professional
signs each individual's record during 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 for each week the detainee is in
Administrative Segregation.
• These weekly records are retained in the SMU
until the detainee's return to the general
popUlation.

fgI

[]

[]

181

0

0

jgl

0

0

jgl

0

0

181

0

0

I8J

0

0

Page 69
G-324A DeteDtion Inspection Fonn Worksheet for IGSAs
Rev: 09/25103

SPECIAL MANAGEMENT UNIT (SMU) - Rating
Adminis1rative Segregation
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance. the plan of action Will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

t8I Acceptable 0

Deficient

o At-Risk

o Repeat Finding

"Remarks: (Record significant facts, observations, other sources used, etc.)

I Date

q/Z~'I
~ f

Page 70
G-324A Detention Inspection Fonn Worksheet for IGSAs
Rev: 09/25/03

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation) .

Policy: Each faalily will establish a Special Management Unit in which to isolate certain detainees from the
general population. The Special Management Unit witt have two sections, one for detainees in Administrative
Segregation; the other for detainees being ~regated for disciplinary reasons.
Components

Yes

No

NA

Officers placing detainees in disciplinary segregation
follow written procedures.
The sanctions for violations committed dumg one incident
do not exceed 60 d~
A completed Disciplinary Segregation Order accompanies
the detainee into the SMU.
The detainee receives a copy of the order within
24 hours of placement in disciplinary
segregation.
Standard procedures include reviewing the cases of
individual detainees housed in disciplinary detention at
set intervals.
After each formal review, the detainee receives
a written copy of the decision and reason(s) for

181

0

0

181

0

0

•

181

0

0

•

181

0

0

181

0

0

181

0

0

181

0

0

r8I

0

0

181

0

0

181

0

0

181

0

0

181

0

0

181

0

0

~

[J

[J

it
The conditions of confinement in the SMU are
proportional to the amount of control necessary to
protect detainees and staff.
Detainees in disciplinary segregation have fewer
privileges than those housed in administrative
segregation.
Uving conditions in disciplinary SMUs modified to
reinforce acceptable behavior.
• If yes, does staff prepare wtitten documentation
for this action.
Does the ole sign to indicate apPJoval.
Every detainee in disciplinary segregatiOn receive the
same humane treatmenJ:, ~ardless of offense.
The quarters used for segregation are:
• Well-ventilated .
• Adequately lighted.
• Appropriately heated.
Maintained in a sanitary condition.

•

•

All cells are equipped with beds.
The beds securely fastened to the floor or wall of
the cell.
The number of detainees confined to each cell or room
do not exceed the number for which the space was
designate.
Does the ole 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.
Detainees in the SMU have the same opportunities to
exchange clothing, bedding, etc., as other detainees.
Detainees in the SMU receive three nutritious

•

•

Page 71
G-324A Detention IaspectioD Form Worksheet for (GSA!
Rev: 09125103

Remarks

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)
Policy: Each facility will establish a Special Management Unit in which to Isolate certain detainees from the
general population. The Special Management Unit will have two sections, one for detainees in Administrative
Segregation; the other for detainees being segregated for disciplinary reasons.
Components

Yes

No

NA

r8I

0

0

r8I

0

0

r8I

0

0

r8I

0

0

r8I

0

0

r8I

0

0

r8I

0

0

r8I

0

0

mealsldays.
• Selected from the Food Service's menu of the
day.
• Food is not used as punishment
Detainees are allowed to maintain a normal level of
personal hygiene, including the opportunity to shower
and shave at least three timeslweek.
The detainees receive, unless documented as a threat
to security:
• Barbering services.
• Recreation privileges.
• Other-than-Jegal reading material.
• Religious material.
• The same correspondence privileges as other
detainees.
• Personal legal material.
When phone access is limited by number or type of calls,
timits do not apply apply to the following:
• Calls about the detainee's immigration case or
other legal matters.
• Calls to consular/embassy officials.
• Calls during family emergencies (as determined
by the OICIWarden).
A health care professional visits every detainee in
disciplinary segregation every day, Monday through
Friday.
• The shift supervisor visit each segregated
detainee daily
• Weekends and holidays.
SMU detainees are allowed visitors, in accordance with
the "Visitation- standard.
SMU detainees receive legal visits, as provided in the
"VISitation- standard.
• Legal seNice providers notified of security
concerns arising before a visit.
VISits from clergy are allowed.
• The clergy member given the option of
visiting/not visiting the segregated detainee.
• Violent/uncooperative detainees 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 case-by-case basi.
Staff
document every incident of denied access
•
to the law library.

Page 72
G-324A Detention Inspection Form Worksheet for IGSAs

Rev: 09125103

Remarks

SPECIAl MANAGEMENT UNIT
(Disciplinary Segregation)
Policy: Each facility will establish a Special Management Unit in which to isolate certain detainees from the
general population. The Special Management Unit will have two sections, one for detainees in Administrative
Segregation; the other for detainees being segregated for disciplinary reasons.
Yes
No
NA
Remartts
Components
All detainee-related activities are documented, e.g.,
f8J
0
0
meals served, recreation activities, visitors etc.
Is the SPC's, the Special Management Housing Unit
Record (1-888) is prepared as soon as the detainee is
placed In the SMU.
t8l
0
0
• All 1-8885 filled out by the end of each shift
• The CDFIIGSA facility use Form
• 1-888 (or equivalent local form).
SMU staff records whether the detainee ate, showered,
exercised, took medication, etc.
• Details about the detainee logged, e.g., a
medical condition, suicidallviolent behavior, etc.
• The health care official sign individual records
after each visit.
I8l
0
0
• 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 SMU.
• The SMU retains these records until the
detainee leaves the SMU.

Page 73
G-324A Detentioft Impeclion Form Worksheet for IGSAs
Rev: 09125103

SPECIAL MANAGEMENT UNIT - Rating
(Disciplinary Segregation)
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:
~ Acceptable

0

Deficient

o At-Risk

o Repeat Finding

·Remarks: (Record significant facts, observations, other sources used, etc.)

b6, b7c

<;/2/0</

I Date ~ ,

Page 74
G-324A Detention Inspeetion Form Worksheet for IGSAs
Rev: 09/25/03

TOOL CONTROL
Poficy: It is the policy of all facilities that all employees shall be responsible for complying with the tool control
policy. The Maintenance SUpervisor shal mainlai'l a computer generated or typewriten Master Inventory list of
tools 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.
Components

There is an individual who is responsible for developing a
tool control procedure and an inspection system to
insure accountability.
Department heads are responsible for implementing this
standard in their departments.
Tool inventories are required for:
• Maintenance Department
• Medial Department
• Food Service Department
• Electronics Shop
• Recreation Department

•

Yes

No

NA

181

0

0

r8I

0

0

r8I

0

0

181

0

0

181

0

0

r8I

0

0

181

0

0

181

0

0

181

D

0

rgJ

0

0

r8I

0

D

r8I

0

0

ArmOry

The facility has a facility policy for the regular inventory of
all tools.
• The policy se1s minimum time lines for physical
inventory and all necessary documentation.
• ICE facilities use AMIS bar code labels when
required.
The facility has a tool classification system. Tools are
classified according to:
• Restricted (dangerouslhazardous)
• Non Restricted (non--hazardous).
Department heads are responsible for implementing
tool-control procedures.
The facility has policies and procedures in place to
ensure that all tools are marked and readily identifiable.
The 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 are readily notice.
Each facility has procedures for the issuance of tools to
staff and de1ainees.
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.
• Necessary documentation/review for all incidents
of lost tools.
Broken or wom out tools are surveyed and disposed of in
an appropriate and secure manner.
All private or contract repairs and maintenance workers
under contract to the ICE, or other visitors, submit an
inventory of all tools prior to admittance into or departure
from the facility.

Page 75
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25103

Remarks

[

TOOL CONTROL - Rating

When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

t8l Acceptable 0

o At-Risk

Deficient

o Repeat Finding

*Remarks: (Record significant faets, observations, other sources used, etc.)
All proced\.1f8S for the inventory and use/distribution of all items in the maintenance section were excellent.
b6, b7c

I Date

9/z/c;{
I

7

Page 76
G-324A Detention Irupection Form Worksheet for IGSAII
Rev: 09125103

TRANSPORTATION

(Land Transportation)
Policy The Immigration and Naturalization Service will take all necessary precautions to protect the lives, safety,
and welfare of our officers, the generaf public, and those in ICE custody during the transportation of detainees.
Standards have been established for professional transportation under tile supervision of experienced and
trained Detention Enforcement Officers or authorized contract personnel.

o S1andanl NA: Check this box if alICE TransPQl1Btion . . handled only by the ICE Field Office or SUbOffice in control of the detainee case.

No

NA

(gJ

0

0

(gJ

0

0

181

[]

[]

~

0

0

(gJ

0

0

rgJ

0

0

rgJ

0

0

(gJ

0

0

~

0

0

181

0

0

~

[]

rgJ

0

0
0

Yes

Components
Transporting officers comply with applicable local, state,
and federal motor vehicle laws and regulations. Records
support this finding of compliance.
Every transporting officer required to drive a commercial
size bus has a valid Commercial Driver's Ucense (COL)
issued by the state of employment.
Supervisors maintain records for each vehicle operator.
Officers use a checklist during every vehicle inspection.
Officers report deficiencies affecting operability.
• Deficiencies are corrected before the vehicle
goes back into service.
Transporting officers:
• Umit driVing time to 10 hours in any 15 hour
period.
• Drive only after eight consecutive off~uty hours.
• Do not receive transportation assignments after
having been on duty, in any capacity, for 15
hours.
Drive a SO-hour maximum in a given work week;
a 7O-hour maximum during eight consecutive
days.
During emergency conditions Oncluding bad
weather), officers may drive as long as
necessary and safe to reach a safe
area-exceedil'lg_ the 10-hour limit.
Two officers with valid CDLs required in any bus
transporting detainees.
When buses travel in tandem with detainees,
there two qualified officers per vehicle.
An unaccompanied driver transport an empty
vehicle.
Before the start of each detail, the vehicle is thoroughly
searched.
Positive identification of all detainees being transported is
confirmed.
All detainees are searched immediately prior to boarding
the vehicle by staff controlling the bus or vehicle.
The facility ensures that the number of detainees
transported does not exceed the vehicles manufacturers
occupancy level.
Protective vests are provided to all transporting officers.
The vehicle crew conducts a visual count once all
~ssengers are on board and seated.

•

•

•

•
•

Page 77
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25103

Remarks

TRANSPORTATION
(Land Transportation)
Policy The Immigration and Naturalization SeNice wil18ke all necessary precautions to protectthe lives, safely,
and welfare of our officers, the general public, and those in ICE custody during the transpot1ation of detainees.
Standards have been established for professional transportation under the supervision of experienced and
trained Detention Enforcement Officers or authorized contract personnel.

o

S1andard NA: Check lIIis box if all ICE Transportation are handled only by ... ICE Field 0I'IIce or SubOffice in control of the detainee case.
Components
Yes
No NA
Remarks

•

Additional visual counts are made whenever the
vehicle makes a scheduled or unscheduled stop.
Policies and procedures are in place addressing the use of
restraining equipment on transportation vehicles.
Officers ensure that no one contacts the detainees.
• One officer remains in the vehicle at a/l times
when detainees are present.
Meals are provided during long distance transfers.
The meals meet the minimum dietary standards,
as identified by dieticians utilized by the Service.
The vehicle crew inspects all Food Service pickups before
accepting delivery (food wrapping, portions, qualtty,
quantity, thermos-transport containers, etc.).
Before accepting the meals, the vehicle crew
raises and resolves questions, concerns, or
Service
discrepancies
the
Food
with
representative.
drinking-water
Basins,
latrines,
and
containersldispensers are cleaned and sanitized
on a fixed schedule.
Vehicles have:
Two-way radios.
• Cellular telephones.
• Equipment boxes stocked in accordance with the
Use of Force Standard.
The vehicles are clean and sanitary at all times.
Personal property of a detainee transferring to another

•

~

D

D

I'&l

D

0

~

D

0

I'&l

0

D

•

•

•

Radio and cell phones
are issued to officer.

~

0

0

J8I

[1

J]

181

D

D

I'&l

D

0

fac~ity:

•
•

Is inventoried.
Is inspected.
Accompanies 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

•

•

Page 78
G-J24A Detentioa Inspection Form Worksheet for IGSAs
Rev: 69Il51OJ

TRANSPORTATION
(land Transportation)
Policy The Imm~ratIon and Naturalization Service wlilake aU necessary precautions to protect 1he lives. safely.
and welfare of our officers, the general public, and those in ICE custody during the transportation of detal1ees.
Standards have been established for professional transportation under the supervision of experienced and
trained Detention Enforcement Officers or authorized contract personnel.

o Standard NA: Check this box if..,ICE Transportation are handled only by the ICE Field Office or SubOffice in control of the detainee case.
Components

•

Yes

No

NA

Remarks

Passenger list is not exclusivety men or women or
minors

TRANSPORTATION -Rating
(Land Transportation)
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compliance. For each element found out of compliance. the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

o Deficient

t8I Acceptable

OAt-Risk

o Repeat Finding

"Remarks: (Record significant facts, observations, other sources used, etr;.)
Van inspected was good. Bus #44 inspected and is deficient. Not clean (old food and napkins on floor).
Seat back are deteriorating with inner straps exposed and falling off. Definite safety hazard (could be used
/~s a x : . ~A has plans to replace Ihe bus or at a minimum replace Ihe seats.
b6, b7c

~

{J/2/{)f:

Auditors Signature I Date ~ /

Page 79
G-324A Detentimt Inspection Form Worksheet for IGSAs

Rev: 09125103

USE OF FORCE
Policy: The U.S. Department of Homeland Security authorizes the use afforce only as a last alternative after
aU other reasonable eflbrts to resolve a situation have faled. Only that amount of force necessary to gain control
of the detainee, to protect and ensure the safety of detainees, staff and others, to prevent serious property
damage and 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:
Components
Yes
No
NA
Remarks
Written policy authorizes staff to respond in an
immediate-use-of-force situation without a supervisor's
~
0
0
presence 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
~
0
0
the detainee or others, officers must try to resolve the
situation without resorting to force.
Written policy asserts that calculated rather than
~
0
0
immediate use of force is feasible in most cases.
The fadlity subscribes to the prescribed Confrontation
Avoidance Procedures.
• Ranking detention official, health
professional, 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 use the Use-of-Force Team Technique.
• Under staff supervision.
Staff members are trained in the performance of the
Use-of-Force Team Technique.
All use-of-force incidents are documented and reviewed.
Staff:
• Does not use force as punishment
• Attempts to gain the detainee's voluntary
cooperation before resorting to force
• Uses only as much force as necessary to
control the detainee.
• Uses restraints only when other nonconfrontational means, including verbal
persuasion, have failed or are impractical.
Mecica1ion may only be used for restraint purposes when
authorized by the Medical Authority as medically
necessary.
Use-of-Force Team follow written procedures that
attempt to prevent injury and exposure to communicable
disease(s).
Standard procedures associated with using four-point
restraints include:
• Soft restraints (e.g., vinyl)
• Dressing the detainee appropnately for the
temperature.
• A bed, mattress, and blanketlsheet.
• Checking the detainee at least every 15
minutes.
Logging
each check.
•
Turning
the
bed-restrained detainee often
•
enough to prevent soreness or stiffness.

~

0

0

181

0

0

~

0

0

181

[]

[J

~

0

0

~

0

0

~

0

0

181

0

0

Page 80
G-324A Detention Inspection Fonn Worksheet for IGSAs
Rev: 09I2S1OJ

USE OF FORCE

Policy: The U.S. Department of Homeland Security authorizes the use of force only as a last alternative after
aU other reasonable effor1s to resolve a situation have failed. Only that amount of force necess ary to gain control
of the detainee, to protect and ensure the safely of detainees, staff and others, to prevent serious property
damage and 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:
Components

Yes

No

NA

181

0

0

181
181

[]

l]

0

0

181

0

D

181

0

0

181

0

0

181

D

0

181

0

0

181

0

0

181

0

0

181

0

0

•

Medical evaluation of the restrained detainee
twice per eight-hour shift.
When qualified medical staff is not
immediately available, staff position the
detainee "face-up".
The shift supervisor monitors the detainee's
position/condition every two hours.
He/she allow the detainee to use the rest
room at these times under safeguards.
All detainee checks are logged.
In immediate-use-of-force situations, staff contacts
medical staff once the detainee is under control.
When the OIC authorizes use of non-lethal weapons:
• Medical staff is consulted before staff use
pepper spray/non-lethal weapons.
Medical staff review the detainee's medical
file before use of a non-lethal weapon is
authorized.
Special precautions are taken when restraining pregnant
detainees.
• Medical personnel are consulted
Protective gear is worn when restraining detainees with
open cuts or wounds.
Staff documents every use of force and/or non-routine
application of restraints.
It standard practice to review any use of force and the
non-routine application of restraints.
All officers receive training in self-defense, confrontationavoidance techniques and the use of force to control
detainees.
Specialized training is given Officers are
certified in all devices they use.
The officers are thoroughly trained in the use of soft and
hard restraints.
In SPCs is the Use of Force form is used. In other
facilities (IGSAs / CDFs) this form or its equivalent is

•

•

•

•

used.

Page 81
G-324A Detention Inspection Form Worksheet for IGSAs
Rev: 09/25103

Remarks

USE OF FORCE - Rating
When rated below Acceptable, facilities must attach a Plan of Action for bringing operations into
compfiance. For each element found out of compliance, the plan of action will specify remedial action and
the estimated timetable for compliance.

Standard Rating:

IZI Acceptable 0

Deficient

D

At-Risk

o Repeat Finding

"'Remarks: (Record significant facts, observations, other sources used, etc.)

b6, b7c

uditor's Signature / Date

Page 82
G-J24A Detention Inspection Form Worksheet for IGSAs
Rev: 09125103

•

STAFF DETAINEE COMMUNICAllONS
Policy: Proced..... must be in place to .1oW for fonMI.nd informld contact between by facllly staff
and ICE staff and ICE de...... and to permit detainees to make writIIIn requests to ICE s1atf and receive
an answer In an acceptable time fr. . ..
No
NA
R....a
Ves
Com
The ICE Field Office Oirector ensures that weekly
181
0
0
announced and unannounced visiI& occur at the IGSA..
Detention and Deportation Staff conduct scheduled
181
0
0
weekly visits with detainees held in the IGSA.
ICE staff visit each pod at
Scheduled visits are posted in ICE detainee areas.
0
181 0 least every other day.
VIsits are logged.
Visiting staff observe and note current climate and
fZI
0
0
conditions of confinement at each IGSA.
ICE information request Forms are available at the IGSA
0
0
181
for use by ICE detainees.
The IGSA treats detainee correspondence to ICE staff as
0
0
181
Special COllvGt"'.""ence.
ICE staff respond to a detainee request from an IGSA
181
0
0 All reponses are logged
within 72 hours.
ICE detainees are notified ion writing upon admission to
the facility of their right to correspond with ICE staff
0
0
0
regarding their case or conditions of confinement.

Staff Detainee Communicalion$ - Rating
When rated below Acceptable, facilities must at2ach a Plan of Action for bringing operations into
compliance. For each etement found out of compflance, the plan of action will specify remedial action and
the estimated timetable for compliance.
Standard Rating:

o Deficient

181 Acceptable

o At-Risk

o Repeat Finding

"'Remarks: (Record siglificant facts, obseIvations, other sources used, etc.)

b6, b7c

r

Date

Page 83
G-324A Detention Inspection Fonn Worksheet for IGSAs
Rev: 09125103